Short answer: the European Accessibility Act (Directive (EU) 2019/882) has applied since 28 June 2025. It is EU law, so it does not apply within the UK as UK law, and a UK business selling only to UK customers is not caught by it. But it does apply to UK businesses that sell covered products or services to consumers in the EU, such as an online shop that takes orders from customers in France or Germany. Service providers with fewer than 10 staff and turnover or balance sheet of no more than €2 million are exempt.
The Act is now being enforced. On 4 June 2026 a French court ordered Carrefour to make its online shop fully accessible within six months, and in March 2026 the Dutch regulator reported that 61% of the large webshops it tested could not be used to place an order with assistive technology. This guide explains what is covered, who is exempt, where B2B fits, and what to do next.
This article is general information, not legal advice. Each EU country has written the directive into its own law, and the details differ, so take advice for the countries you sell into.
Key takeaways
- The European Accessibility Act has applied since 28 June 2025. It is not UK law, but it covers UK businesses selling in-scope products or services to consumers in the EU.
- Covered services include e-commerce, consumer banking, e-books, electronic communications and passenger transport websites, apps and ticketing.
- Service providers with fewer than 10 staff and turnover or balance sheet of no more than €2 million are exempt.
- The Act targets consumer-facing products and services, so a purely B2B shop is generally outside it, but a shop open to consumers is not.
Why an EU law reaches UK businesses
The EAA is a directive, so each member state has turned it into national law. Since Brexit those laws do not apply in Great Britain, and the UK has not adopted a copy of the Act.
What matters is the market, not where your company is based. The directive covers products placed on the EU market and services provided to consumers in the EU. The EU's Your Europe portal says the requirements apply to products and services placed on the market after 28 June 2025. A UK company that actively sells to EU consumers is providing that service in the EU, in the same way that UK sellers must follow EU consumer and product safety rules when they sell there. Law firm Clifford Chance notes in a May 2026 briefing that the Act reaches products "manufactured outside, and later made available within the EU market".
In practice:
- UK shop, UK customers only: the EAA does not apply. UK law still does (see below).
- UK shop that ships to and takes orders from EU consumers: assume your e-commerce service is in scope, unless you are a microenterprise.
- UK manufacturer or brand whose covered products are sold in the EU: the product rules can apply, whether you sell directly or through an EU importer or distributor.
Which products and services are covered
Article 2 of the directive lists what is in scope. Everything else is outside it.
Services
| Service | What it includes |
|---|---|
| E-commerce | Selling to consumers at a distance through websites and apps |
| Consumer banking | Banking services provided to consumers, such as accounts, payments and consumer credit |
| E-books | E-books and the software used to read them |
| Electronic communications | Telephone and messaging services, with some exceptions |
| Audiovisual media access | Services that give access to TV and video content, such as streaming platforms and electronic programme guides |
| Passenger transport | For air, bus, rail and waterborne transport: websites, apps, e-tickets, travel information and some self-service terminals (urban and regional services have narrower duties) |
| Emergency communications | Answering calls to the EU emergency number 112 |
Products include consumer computers and operating systems, smartphones and other consumer communication devices, e-readers, TV equipment for digital television, and self-service terminals such as card payment terminals, ATMs, ticketing and check-in machines.
For most UK businesses reading this, the relevant entry is e-commerce. If you sell physical goods online to EU consumers, it is your website or app, and the buying journey on it, that has to be accessible, not the goods themselves (unless the goods are themselves covered products, such as phones or e-readers).
The microenterprise exemption
Article 4(5) exempts microenterprises that provide services from the accessibility requirements. The directive defines a microenterprise as a business that:
- employs fewer than 10 people, and
- has annual turnover of no more than €2 million, or an annual balance sheet total of no more than €2 million.
So a UK online shop with six staff and £800,000 turnover is outside the services rules, even if it sells across the EU. Many small UK sellers will fall under this line. Three points to watch:
- It covers services only. Microenterprises that make or sell covered products are not exempt, although they get lighter paperwork.
- Check the test each year. If you grow past 10 staff or the financial thresholds, the exemption ends.
- Larger businesses can claim "disproportionate burden", but only with a documented assessment, which Your Europe says must be reviewed every five years. It is not a blanket opt-out.
Does the European Accessibility Act apply to B2B?
Mostly no. The Act is built around consumers, meaning people buying for themselves rather than for their business:
- The e-commerce definition covers services provided "at the individual request of a consumer with a view to concluding a consumer contract".
- Banking is limited to consumer banking services.
- Computers, phones and similar devices are covered as consumer products.
A trade-only wholesaler or a SaaS tool sold only to businesses is therefore generally outside the Act. Two caveats:
- Mixed sites count. If your website lets members of the public order as well as trade customers, the consumer side is in scope.
- Some products are used with consumers. Self-service terminals such as payment terminals and ticket machines are bought by businesses but used by the public, and they are covered.
If you are unsure whether you sell to consumers, look at who can actually complete a purchase on your site.
What the Act expects of a website
Annex I of the directive sets functional requirements rather than naming a technical standard. Websites and apps must be perceivable, operable, understandable and robust, which are the four principles behind the Web Content Accessibility Guidelines (WCAG). They must also work with assistive technology, and the customer support you offer must be accessible.
In practice, auditors and regulators measure websites against WCAG, usually through the European standard EN 301 549, which applies WCAG Level AA success criteria (WCAG 2.1 in the version most widely used) to web content. The French court in the Carrefour case used France's RGAA framework, which is also based on WCAG. Aiming for WCAG 2.2 AA, the latest version, covers WCAG 2.1 AA as well.
Under Article 13, service providers also have to publish information on how their service meets the requirements, which most businesses do with an accessibility statement.
There is some transition time. Services may keep using products they were already lawfully using before 28 June 2025 until 28 June 2030, and self-service terminals already in use can stay until the end of their useful life, up to 20 years. This does not give websites a general grace period.
How the Act is being enforced
Enforcement is national and takes different forms:
| Country | Development |
|---|---|
| Netherlands | On 24 March 2026 the ACM said it had tested about 100 of the largest webshops plus telecom and energy sites. On 61%, customers using assistive technology could not place an order, and 33% had serious problems. The ACM said companies that do not improve enough risk enforcement |
| France | On 4 June 2026 the Tribunal judiciaire de Caen ordered Carrefour France to make its e-commerce services fully accessible within six months, with daily penalties for delay, in a case brought by disability groups apiDV and Droit Pluriel. Carrefour had argued it already met 71% of the criteria; the court said the site must be fully accessible |
| France | In early May 2026 the Tribunal judiciaire de Lille dismissed a similar action against Auchan E-Commerce. That decision is under appeal |
These cases involve large retailers. We have not found a published enforcement action against a UK-based seller, but complaints and regulator checks are possible in any country where your customers live.
What UK law requires at home
The UK has no private-sector equivalent of the EAA, but accessibility is already a legal duty. GOV.UK guidance says all UK service providers must make reasonable adjustments for disabled people under the Equality Act 2010 (or the Disability Discrimination Act 1995 in Northern Ireland). Public sector websites must also meet the Public Sector Bodies Accessibility Regulations 2018, using WCAG 2.2 AA. For a private UK business, WCAG 2.2 AA is a sensible target that also covers most of what EU auditors look for. Our website accessibility checklist for UK businesses goes through the checks one by one.
What to do now
- Decide whether you are in scope. Do consumers in EU countries buy from you? Do you have 10 or more staff, or more than €2 million turnover or balance sheet? Write down your conclusion and the date.
- Test the checkout with a keyboard only. Can you reach every field, button and the payment step without a mouse? Inaccessible order buttons and CAPTCHAs were among the problems the ACM found.
- Try a screen reader. NVDA on Windows and VoiceOver on Mac and iPhone are free. Check that product names, prices, images and form errors are read out clearly.
- Run an automated check, then a manual review. Make It Flow's accessibility check runs Lighthouse audits for alt text, colour contrast, form labels, button names and ARIA, and shows example elements that fail. Automated tools find only some problems, so treat it as a starting point, not a compliance certificate.
- Fix the structure. Screen reader users move around a page by its headings. Our heading checker shows any page's H1 to H6 outline and flags missing H1s and skipped levels. Check text colours with the colour contrast checker, and see our guides to alt text and broken links and redirect chains.
- Publish an accessibility statement. Say which standard you aim for, list known issues, and explain how customers can get help or report a barrier.
For a fuller walkthrough of the fixes, see how to make your website accessible with WCAG.
Selling to the US too?
The same work helps in the US. The Americans with Disabilities Act (ADA) has no EU-style list of covered services, but the Justice Department's web guidance says the ADA applies to the websites of businesses open to the public. It does not set one technical standard for private businesses, but it points to WCAG as helpful guidance, and WCAG 2.1 AA is the benchmark most often used in US accessibility lawsuits and settlements. A site that meets WCAG 2.1 or 2.2 AA for EU customers is in a much stronger position in the US as well. As with the EU rules, take local advice if you have significant US sales.
Frequently asked questions
Does the EAA apply to UK companies?
Yes, if they sell covered products or services to consumers in the EU. The Act is not UK law, so it does not govern sales within the UK. But a UK online shop that sells to EU consumers should assume its e-commerce service is covered, unless it is a microenterprise with fewer than 10 staff and turnover or balance sheet of no more than €2 million.
Does the European Accessibility Act apply to the UK?
Not as UK law. The UK left the EU before the Act applied from 28 June 2025 and has not adopted it. Within the UK, the Equality Act 2010 duty to make reasonable adjustments applies instead, and public sector websites must meet the 2018 accessibility regulations.
What does the European Accessibility Act mean for UK businesses selling into the EU?
If you sell covered services, most often e-commerce, to EU consumers, your website or app and its buying journey need to meet the Act's accessibility requirements, usually measured against WCAG 2.1 AA. You also need to publish information on how you meet them, typically an accessibility statement. Penalties are set by each EU country, and enforcement happens in the country where your customers are.
Does the European Accessibility Act apply to B2B?
Mostly no. It covers products and services for consumers, so a website that sells only to business customers is generally outside it. If members of the public can also buy from your site, the consumer side is in scope. Some products bought by businesses, such as payment terminals and ticket machines, are covered because the public uses them.
What are the penalties?
The directive leaves penalties to each member state, so they vary. In France, for example, courts can order a business to comply within a deadline, with daily penalties for delay, as the Caen court did with Carrefour.
Is there a UK version of the Act?
No. UK private businesses are covered by the Equality Act 2010 duty to make reasonable adjustments, and public sector websites must meet the 2018 accessibility regulations. There is no UK law that mirrors the EAA for private sector websites.
Sources
- EUR-Lex: Directive (EU) 2019/882 on the accessibility requirements for products and services
- Your Europe: Services, goods and their digital accessibility
- European Commission: European Accessibility Act
- ACM: Klant met beperking kan bij merendeel grote webwinkels niet terecht (24 March 2026, Dutch)
- GOV.UK: Understanding accessibility requirements for public sector bodies
- Clifford Chance: Bridging the accessibility gap, the European Accessibility Act (May 2026, PDF)
- Deque: France's major court decision supporting digital accessibility under the EAA
- ADA.gov: Guidance on web accessibility and the ADA
Written by the MakeItFlow team
We build the website audit these guides are based on. Every fact is checked against the primary sources listed above and this guide was last reviewed on 31 October 2026 . How we research and check
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