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

“But we left the EU!”

That’s usually the first reaction when I mention the European Accessibility Act to a UK client. And it’s true, the UK isn’t covered by the directive. The catch is that the Act follows the market, not your business address. If you sell covered products or services to consumers in the EU, it applies to you, wherever you’re based.

The Act has applied since 28 June 2025, so if you run an online shop that sells into Europe, this isn’t something to put on next year’s to-do list. Let’s go through what it covers, who’s exempt and what you can do about it.

A quick note before we start: I build accessible websites for a living, but I’m not a lawyer. Use this as a starting point and check the details for your business with a legal adviser.

What is the European Accessibility Act?

The European Accessibility Act is an EU directive, Directive (EU) 2019/882⁠ (opens in a new tab), which sets common accessibility requirements for a range of everyday products and services. Each EU member state has written it into its own national law, and each one enforces it, so penalties vary from country to country.

What does it cover?

The Act covers products and services that people rely on every day, including:

E-commerce, whatever your online shop sells.
Consumer banking services.
E-books and the software used to read them.
Passenger transport services by air, bus, rail and water, including their websites, apps and ticketing.
Telephony services and the equipment that goes with them.
Audio-visual media services, such as TV broadcasting and the equipment people use to watch it.
Computers, operating systems and smartphones.
Self-service terminals like ATMs, ticket machines and check-in kiosks.

For most of our clients the big one is e-commerce. If consumers in the EU can buy from your website, your product pages, basket, account area and checkout all need to be accessible.

The European Union flag waving outside a modern office building. Image: “European Union Flag Waving Against Modern Building”⁠ (opens in a new tab) by aleksandre lomadze⁠ (opens in a new tab), Pexels License⁠ (opens in a new tab), via Pexels.

Who’s exempt?

There’s one important exemption. Microenterprises providing services, meaning businesses with fewer than 10 employees and an annual turnover or balance sheet total of €2 million or less, don’t have to meet the accessibility requirements for those services.

Note that this covers services only. A microenterprise that makes covered products, such as e-readers or ticket machines, isn’t exempt for those products.

There are also some transition periods:

Services can keep using products they were lawfully using before 28 June 2025 until 28 June 2030.
Service contracts agreed before 28 June 2025 can carry on unchanged until they end, for up to five years from that date.
Self-service terminals already in use can stay in service until the end of their useful life, for up to 20 years after they first went into use.

Don’t read the transition periods as “we’ve got until 2030”. A new or redesigned website launched today is expected to meet the requirements now.

What does “accessible” mean here?

The Act says products and services must be perceivable, operable, understandable and robust for people with disabilities. If those four words sound familiar, that’s because they’re the four principles of the Web Content Accessibility Guidelines (WCAG).

In practice, the European standard used to show that websites and apps comply, EN 301 549, builds on WCAG 2.1 Level AA⁠ (opens in a new tab). So if your website meets WCAG 2.1 AA, you’re in a good position.

What about the UK itself?

Accessibility isn’t only an EU concern. In the UK, the Equality Act 2010 already requires businesses to make reasonable adjustments so disabled people aren’t put at a disadvantage, and that includes services offered online. Building to WCAG 2.1 AA helps you on both sides of the Channel.

Where to start

If you sell to customers in the EU and you’re not sure where you stand, this is what I’d do:

Check whether you’re in scope. Do you sell covered products or services to consumers in the EU? Are you above the microenterprise thresholds?
Get an accessibility audit. Test your website against WCAG 2.1 AA, starting with the routes through your site that make you money: finding a product, adding it to the basket and checking out.
Fix the checkout first. A customer who can’t use your checkout can’t buy from you, full stop.
Test with real assistive technology. Automated tools only catch some issues. Try your site with a keyboard alone and with a screen reader.
Publish an accessibility statement. Explain how accessible your service is, what you’re working on and how people can tell you about a problem.
Make it part of how you work. Accessibility isn’t a one-off project. Check new features before they go live, not after a complaint.

How we can help

We test our own website against WCAG 2.1 AA with automated checks on every page and by hand with a keyboard and screen readers, and you can read how in our accessibility statement. We do the same for our clients.

Our colleague Pri recently looked at how 30 UK IVF clinic websites hold up, including on accessibility, in What first impression is your IVF website creating for patients?. It’s a good example of how much variation there is out there.

If you’d like to know how your website measures up, our audits are a good place to start, or book a call and we’ll talk it through.