European Accessibility Act: does it apply to your website?
The EU accessibility rules have applied since 28 June 2025. Who they cover, why many small service firms are exempt, fines in SK, AT and DE, and a 15-minute check.

Nikolay Tolmachev, Founder, Tolman Studios
7 min readWebsites
In short
Under 10 peopleand turnover or balance sheet up to €2 million: service businesses this small are exempt
- The European Accessibility Act covers consumer services such as online shops, banking, passenger transport, e-books and telecoms. A site that only presents your business is not on the list.
- Micro-enterprises that provide services are exempt: fewer than 10 people and annual turnover or balance sheet total of no more than €2 million.
- Exempt or not, the basics (keyboard, contrast, labels, alt text) take 15 minutes to check and help every visitor.
On this page
Since 28 June 2025 the European Accessibility Act has applied to many websites that sell to consumers. Online shops, banks, airlines and e-book stores are covered. A small service business with fewer than 10 people is exempt, and so is a site that only presents what you do.
So for many owners who read this, the short answer is "probably not". Below I show how to check it in four steps and what the fines look like in Slovakia, Austria and Germany. There is also a 15-minute test that is worth doing either way. I'm not a lawyer. This is my reading of the official texts, with links, so you can check them yourself.
What is the European Accessibility Act?
It is an EU directive from April 2019, Directive (EU) 2019/882. Each country had to turn it into its own law by June 2022, and those laws apply from 28 June 2025. The goal is that people with disabilities can buy and use common products and services on their own. That includes people who are blind and use a screen reader, people who can't use a mouse, and people who need large text.
For websites, the requirements follow the same four ideas as WCAG, the W3C web accessibility guidelines. Content must be perceivable, operable, understandable and robust. In practice the European standard EN 301 549 uses WCAG 2.1 level AA as the measure for web pages.
Does it apply to my website?
Go through these four questions in order. If you answer "no" at any step, the act doesn't cover your website.
- Do you sell to consumers? The act covers services "provided to consumers". If you only work with other companies, it doesn't cover you.
- Is your service on the list? The list is short: e-commerce (selling online, with the contract made on the site or app), consumer banking and payments, passenger transport by air, bus, rail and water (websites, apps, e-tickets, travel information), e-books, phone and internet services, and access to TV and video services. A presentation site for a dentist, a law office or a plumber is not on it.
- Are you a micro-enterprise? That means fewer than 10 people, plus annual turnover or a balance sheet total of no more than €2 million. Micro-enterprises that provide services are exempt from the accessibility requirements for services.
- Still covered? Then your site has to meet the requirements, and you must publish information that explains how your service meets them. If a fix would be a disproportionate burden, you can rely on that only after a written assessment. You repeat it at least every five years.
There is one grey zone. The directive defines e-commerce as services at a distance "with a view to concluding a consumer contract". Read literally, online booking with payment can fall under that. If online booking is your main way of selling and you have 10 or more people, treat your site as covered and ask your adviser.
Slovakia's law is worded more broadly. Instead of "e-commerce" it says "information society services", a term from the Slovak e-commerce act. This can include more online services sold to consumers, so in Slovakia the grey zone is bigger. The micro-enterprise exemption is the same.
The exemption covers services only. If you make, import or sell products such as payment terminals or e-readers, other duties apply.
Some old content doesn't have to be fixed. Videos and office files such as PDFs published before 28 June 2025 are outside the rules. So is archived content that is no longer updated.
What are the national laws and fines?
Each country wrote its own law, with its own fines and its own authority. Here are three of them: Slovakia, where I'm based, plus Austria and Germany.
| Country | Law | Who checks | Maximum fine for a service |
|---|---|---|---|
| Slovakia | Act No. 351/2022 Coll. (zákon o prístupnosti výrobkov a služieb) | Slovak Trade Inspection (SOI) | €200 to €6,000 for an inaccessible service or missing information, up to €20,000 or €30,000 for other breaches, never above 3% of last year's turnover |
| Austria | Barrierefreiheitsgesetz (BaFG), BGBl. I No. 76/2023 | Sozialministeriumservice | €80,000, or €50,000 for small and medium-sized firms |
| Germany | Barrierefreiheitsstärkungsgesetz (BFSG) | Market surveillance authority | €100,000 |
These amounts are maximums. The directive says fines must be "effective, proportionate and dissuasive" and must go together with steps to fix the problem. The Slovak law goes further. If you fix an inaccessible service after the inspection finds it, SOI does not impose the fine for that breach. A fine of €30,000 in Slovakia is for not cooperating with the inspection at all.
In Austria consumers can report a website to the Sozialministeriumservice. So can the consumer association VKI, the disability council, the Chamber of Labour and the Chamber of Commerce (WKO). The office has eight weeks to answer in writing.
How common are the problems?
Very common. Every year WebAIM, a non-profit at Utah State University, scans the home pages of the top million websites with an automatic tool. In February 2026 it found detectable WCAG failures on 95.9% of them. On average there were 56.1 errors per page. Most of them are the same few mistakes.
- Low contrast text83.9%
- Images without alt text53.1%
- Form fields without labels51%
- Empty links46.3%
- Empty buttons30.6%
- No page language set13.5%
Source: WebAIM Million 2026 report, top 1,000,000 home pages
All six are cheap to fix on a small site. Automatic tools only catch some of the problems, so a quick manual check still matters.
What can I check myself in 15 minutes?
Open your home page and your contact or order page on a laptop. Then go through this list. The numbers in brackets are the WCAG 2.2 criteria, in case your developer asks.
A 15-minute accessibility check
- Keyboard only. Put the mouse away and press Tab. Can you reach every link, button and form field, and do you always see where you are? (2.1.1, 2.4.7)
- Nothing hides the focus. A sticky header or cookie banner must not cover the element you just tabbed to. (2.4.11)
- Zoom to 200%. Text should get bigger without being cut off or overlapping. (1.4.4)
- Contrast. Check your text colour against the background with the free WebAIM Contrast Checker. Normal text needs at least 4.5:1, large text 3:1. (1.4.3)
- Images. Every image that carries meaning needs a short text description (alt text). The free WAVE tool from WebAIM shows the missing ones. (1.1.1)
- Forms. Every field has a visible label, not only grey placeholder text. Error messages say in words what went wrong. (3.3.1, 3.3.2)
- Icon buttons have names. A WhatsApp or menu icon needs a text label that a screen reader can read. (2.4.4, 4.1.2)
- Small tap targets. Buttons and links should be at least 24 by 24 pixels, or have enough space around them. (2.5.8)
- Page language. The code of each page says which language it is in, for example lang="sk". Screen readers use it to pick the right voice. (3.1.1)
If most of these pass, your site is in better shape than most of the web. If several fail, don't panic. On a small site the fixes usually take days, not weeks (my estimate).
I'm exempt. Should I still care?
Yes, though not because of fines. Accessibility helps far more people than the law has in mind. Someone reading your prices on a phone in the sun needs good contrast. A customer in their seventies needs text that zooms. Clear labels help everyone who fills in your form in a hurry.
It also helps search. Alt text, real headings and a set page language are the same signals Google and AI assistants use to understand a page. I wrote more about that in what a business website should do in 2026.
How do I handle accessibility on my sites?
I build every site with WCAG 2.2 level AA as the target. This site aims for the same. It works fully with a keyboard and has a visible focus ring and a "skip to content" link. It has enough contrast and the correct language on every page. Visitors who switched motion off in their settings see no animation.
I don't use accessibility overlay widgets. I fix the problems in the site itself. If your current site fails the 15-minute check, I can look at it and tell you what the fixes would involve. You can see what's included on my websites page, or write to me with your website address.
Questions people ask
I run a salon with 4 people and an online booking form. Does the law apply to me?
No. A business with fewer than 10 people and turnover or balance sheet of no more than €2 million is a micro-enterprise. Micro-enterprises that provide services are exempt from the accessibility requirements.
Does an accessibility plugin or overlay make my site compliant?
The law does not mention plugins. The requirements are about the site itself: text, contrast, keyboard use, labels and code. I fix those in the site and do not use overlay widgets.
Do I need an accessibility statement?
Only if the law covers you. Then you must publish information that explains how your service meets the requirements, in a form people with disabilities can use. Most businesses put it on a separate page.
WCAG 2.1 or 2.2: which one should I aim for?
The European standard EN 301 549 builds on WCAG 2.1 level AA. WCAG 2.2 is the newer W3C version and adds a few checks, such as tap target size. A site that meets 2.2 AA also covers the 2.1 AA checks, so I aim for 2.2 AA.
What happens if a covered website is not accessible?
The national authority can order you to fix it and can fine you. In Slovakia the fine for an inaccessible service is up to €6,000 and the inspection drops it if you fix the problem. Austria allows up to €80,000, Germany up to €100,000.
Sources
- Directive (EU) 2019/882 on the accessibility requirements for products and services (Articles 2, 3, 4, 13, 14, 30, 32), EUR-Lex, Official Journal of the EU, checked 18 August 2026
- Zákon č. 351/2022 Z. z. o prístupnosti výrobkov a služieb (§ 2, § 8, § 10, § 12), Slov-Lex, checked 18 August 2026
- Barrierefreiheitsgesetz (BaFG), BGBl. I Nr. 76/2023 (§ 3, § 6, § 36), RIS, Austrian Federal Legal Information System, checked 18 August 2026
- Barrierefreiheitsstärkungsgesetz (BFSG) (§ 2, § 3, § 37), Gesetze im Internet, German Federal Ministry of Justice, checked 18 August 2026
- Web Content Accessibility Guidelines (WCAG) 2.2, W3C, checked 18 August 2026
- The WebAIM Million: 2026 report on the accessibility of the top 1,000,000 home pages, WebAIM, checked 18 August 2026
Facts and prices are as of the dates in the sources.

Nikolay Tolmachev
Founder, Tolman Studios
I build websites, AI chatbots and ads for small businesses, working from Slovakia. Before that I spent over 4 years managing IT projects. I hold PMP and Certified ScrumMaster certificates.