The European Accessibility Act: A Website Checklist

The European Accessibility Act, often shortened to EAA, is one of those regulations that arrived with a lot of noise and then quietly became part of normal business life. Since June 28, 2025, certain products and services sold in the EU must meet accessibility requirements, and online shops are explicitly on the list. This note is a practical summary for small businesses and their web teams. It is not legal advice, and national rules differ, so confirm the details for your own country and situation.

Who is covered

The EU’s business guidance lists online shops, ticketing platforms and banking services among the covered services, along with products like computers, phones, e-readers and payment terminals. Two commentary pieces add that the rules reach companies based outside the EU if they sell to customers in it. The requirement applies to products and services placed on the market after June 28, 2025, with transition arrangements for equipment already in use.

The microenterprise exemption

The EU page says service providers with fewer than 10 employees and under €2 million in turnover are exempt. It does not describe an equivalent exemption for makers or sellers of physical products, so check which category you fall into. Separately, any business can argue that compliance would be a disproportionate burden, but it must provide evidence, which has to be reviewed every five years. One of the commentary articles suggests that even exempt businesses record why they qualify, in case anyone asks, and encourages them to improve accessibility anyway. A small online shop with its own staff and revenue near the limits should look at the numbers carefully rather than assume.

What “accessible” means for a website

The EU guidance lists general principles: services should work for people with cognitive disabilities, be compatible with assistive technology like screen readers and voice control, offer varied ways to input and read information, be navigable with a consistent layout, give users enough time, and avoid flashing content that can trigger seizures. For web content, commentary from Squiz points to WCAG 2.1 Level AA as the working standard and to the four principles of perceivable, operable, understandable and robust. Penalties vary by country; that article cites up to €250,000 in France as an example.

A practical checklist

1. Decide whether you are in scope

Do you sell to EU customers online, or offer booking, banking-like or ticketing services?
Count employees and turnover honestly, and write down the result and the date.

2. Audit with both tools and people

Run automated checkers, but do not stop there. Siteimprove’s guide says automated tools find only about half of issues, so add manual tests: keyboard-only navigation, a screen reader pass, zoom to 200 percent, and a look at colour contrast.
Test the journeys that matter: finding a product, adding to cart, checking out, contacting you.

3. Fix by impact

Prioritise problems that block core tasks and affect many users on important pages.
Assign an owner and deadline to each fix, and note what you deferred and why.

4. Check your theme and plugins

Squiz recommends making sure your content system and templates support accessibility, and that third-party tools and plugins are accessible too. A single inaccessible checkout widget can undo the work on everything else.
Look at forms in particular: labels, error messages, focus order.

5. Build it into routine

Add a short accessibility checklist for new pages, images and campaigns.
Train whoever writes content: alt text, headings and link wording are everyday habits.

6. Keep records and a feedback route

Publish an accessibility statement and give visitors a way to report problems.
Keep test notes and fix logs so you can show a good-faith process if a complaint arrives.

What not to rely on

Be sceptical of any product that promises compliance by pasting one line of script on your site. None of the sources above describe a shortcut like that; they all point to auditing, fixing the underlying pages and keeping records. A monitoring tool can help you spot regressions, but it cannot replace decisions about how your pages are built.

When this can wait

You are a qualifying microenterprise offering services and have documented it. Still improve what is cheap, such as contrast, alt text and form labels.
You do not sell to EU residents and have no plans to.

Even then, accessible sites tend to be easier for everyone to use, including customers on phones in poor light. If you want help auditing a theme or fixing the most common problems, see our themes and our services.