The European Accessibility Act: what UK businesses selling into the EU need to know

Many UK businesses sell to customers in EU countries through their own website, app or booking system. Since June 2025, the European Accessibility Act (EAA) has set accessibility requirements for a range of products and services sold to EU consumers, including online shops. This guide explains what the Act covers, how it can apply to a UK business, how it relates to EN 301 549 and WCAG, and how it differs from UK law. It is general information, not legal advice; for advice about your organisation, speak to a lawyer who knows the rules in the EU countries you sell to.

What is the European Accessibility Act?

The European Accessibility Act is Directive (EU) 2019/882 on the accessibility requirements for products and services. Because it is a directive, it works through national law: Article 31 required EU member states to adopt and publish their own laws by 28 June 2022 and to apply them from 28 June 2025. In practice, the detailed obligations, enforcement bodies and penalties are set by each member state. Article 30 says penalties must be effective, proportionate and dissuasive.

Which products and services does it cover?

Article 2 covers certain products placed on the market after 28 June 2025, such as consumer computers and operating systems, payment and self-service terminals, smartphones and e-readers. It also covers these services provided to consumers after that date:

• electronic communications services, such as telephony;
• services providing access to audiovisual media services;
• elements of air, bus, rail and waterborne passenger transport services, including websites, mobile apps, electronic tickets and travel information;
• consumer banking services;
• e-books and dedicated software;
• e-commerce services.

The Directive defines e-commerce services as services provided at a distance, through websites and mobile device-based services, by electronic means and at the individual request of a consumer, with a view to concluding a consumer contract. Recital 43 adds that the e-commerce obligations should apply to the online sale of any product or service, so for most businesses this is the category that matters.

Some content is excluded, such as pre-recorded media and office documents published before 28 June 2025, and third-party content the business does not fund, develop or control.

Can it apply to a UK business?

Yes, in some cases. The Directive defines a service provider as any person who provides a service on the Union market or makes offers to provide such a service to consumers in the Union. Being based in the UK does not, by itself, take a business outside that definition. If you sell to EU consumers online, assume the Act may apply and check the national law of the countries you sell to.

The Act is about consumers, meaning people buying outside their trade, business, craft or profession, so a purely business-to-business service is less likely to be caught.

Who is exempt?

Article 4(5) exempts micro-enterprises providing services from the service accessibility requirements and the related obligations. The Directive defines a micro-enterprise as one that employs fewer than 10 people and has an annual turnover not exceeding EUR 2 million, or an annual balance sheet total not exceeding EUR 2 million. The exemption does not cover micro-enterprises dealing in products, although they are excused from documenting the assessment described below.

Article 14 also allows a business to rely on the accessibility requirements not applying where compliance would fundamentally alter the basic nature of a product or service, or would impose a disproportionate burden. This is not an informal opt-out: the business must carry out and document an assessment against the criteria in Annex VI, keep it for five years, and, for services, renew it when the service changes, when an authority asks and at least every five years.

What does the Act require from an online service?

Annex I sets out the requirements. For services, they include making websites, related online applications and mobile apps accessible in a consistent and adequate way by making them perceivable, operable, understandable and robust. For e-commerce services specifically, the Annex includes:

• providing accessibility information about the products and services being sold, where the responsible economic operator supplies it;
• making identification, security and payment functions perceivable, operable, understandable and robust;
• providing identification methods, electronic signatures and payment services that meet the same four principles.

Article 13 adds duties for service providers. They must publish, in an accessible form, information explaining how the service meets the requirements; Annex V says this goes in the general terms and conditions or an equivalent document. Providers must also keep the service compliant as it changes, correct any non-compliance and tell the competent national authorities when the service does not comply.

Under Article 32, service contracts agreed before 28 June 2025 may continue unaltered until they expire, but no longer than five years from that date.

How do EN 301 549 and WCAG fit in?

Article 15 says products and services that conform to harmonised standards published in the Official Journal of the European Union are presumed to conform with the Act, as far as those standards cover its requirements. The main European standard for ICT accessibility is EN 301 549, which, according to the European Commission, draws heavily on the Web Content Accessibility Guidelines (WCAG) published by the W3C.

AccessibleEU, the European Commission's accessibility resource centre, reports that EN 301 549 v4.1.1 was published in September 2026. It adopts WCAG 2.2 as the benchmark for websites, software and digital documents, and it is the first version developed with the EAA in mind, with an annex linking its requirements to the Act. AccessibleEU also says that until the Commission formally cites v4.1.1 in the Official Journal, the current reference remains EN 301 549 v3.2.1 (2021), which is based on WCAG 2.1 Level AA. Working to WCAG 2.2 Level AA also covers the 2.1 criteria, so it is a practical target.

How is this different from UK law?

In Great Britain, the main domestic law is the Equality Act 2010. GOV.UK states that all UK service providers have a legal obligation to make reasonable adjustments under it. The Equality and Human Rights Commission's code of practice explains that this duty is anticipatory: service providers must consider the barriers disabled people could face and act before an individual tries to use the service. The Act does not name a technical standard.

Public sector bodies have extra duties under the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018. GOV.UK says they should meet WCAG 2.2 AA and publish an accessibility statement. Those regulations do not apply to private businesses. A UK business selling into the EU may therefore need to think about both the Equality Act at home and the EAA for its EU customers. Our guide to UK website accessibility and the Equality Act covers the domestic side.

What practical steps should you take?

• Map your EU sales: list the EU countries where consumers buy from you and the sites, apps and checkouts they use.
• Check the size test: decide whether you meet the micro-enterprise definition, and record why.
• Audit against WCAG 2.2 AA: combine automated checks with keyboard, zoom and screen reader testing of login, search, basket and payment.
• Check third-party components: payment, cookie, chat and review tools often introduce barriers, so ask suppliers how they test.
• Publish accessibility information: add the Annex V description to your terms and conditions or an equivalent page.
• Document any exceptions: if you rely on disproportionate burden for part of a service, complete and keep the Article 14 assessment.
• Build it into change control: re-test after redesigns and updates, and keep a record of fixes.
• Check national rules: confirm which authority enforces the Act in your main EU markets.

If you would like an independent review of your site or app, our website accessibility audit tests key journeys against WCAG and gives a prioritised list of fixes.

Sources

• EUR-Lex: Directive (EU) 2019/882 on the accessibility requirements for products and services
• European Commission: European Accessibility Act
• AccessibleEU: The European accessibility standard EN 301 549 has been updated
• European Commission: Web Accessibility Directive standards and harmonisation
• GOV.UK: Understanding accessibility requirements for public sector bodies
• EHRC: Code of practice for services, public functions and associations, Chapter 7: reasonable adjustments