European Accessibility Act

The European Accessibility Act is the EU directive that turned digital accessibility from good practice into a legal requirement across a defined set of products and services. It applies from 28 June 2025.

For most of our clients it arrives not as a legal question but as a commercial one: a European customer's procurement process asks whether you conform.

What it covers

Consumer-facing products and services — e-commerce, consumer banking, e-books, electronic communications, transport services, and the hardware and software involved in delivering them.

It is a directive, not a regulation. Each member state implements it in national law, which means the enforcement mechanism, the penalties and some of the detail vary by country. A single European answer does not exist, which is why legal advice on this is worth the cost and a blog post is not a substitute for it.

Which standard actually applies

The Act states functional requirements. It does not name a technical standard.

In practice, conformance is demonstrated through EN 301 549, the European standard for accessibility of ICT products and services.

⚠️ EN 301 549 currently references WCAG 2.1, not 2.2. This catches teams out in both directions. Building to WCAG 2.2 when the obligation names 2.1 is a choice you are free to make, and paying for 2.2 conformance while believing it was mandatory is a budgeting error. Check the version the obligation names.

Whether it reaches B2B SaaS

Strictly, the scope is consumer-facing, so pure B2B tooling frequently falls outside it.

That distinction is thinner in practice than on paper. If your customer is covered, the requirement arrives through their procurement regardless of whether the law reaches you directly. A bank subject to the Act will ask its vendors to demonstrate conformance, because its own obligation depends on the software it runs.

This is the same mechanism that makes a VPAT request appear in a deal with a company that has no legal duty of its own.

Exemptions are narrower than they look

Microenterprises providing services are exempted from the service obligations.

Disproportionate burden provisions exist, and they require a documented assessment rather than an assertion. "It would be expensive" is not the test, and an undocumented claim is worth nothing when somebody asks.

Treat exemption as something to establish with advice, not something to assume.

What to do about it

Find out whether you are in scope, properly, with legal input. The answer determines everything else and it is cheap to get.

Establish which standard and version the obligation names, rather than assuming the newest.

Test before a customer asks. An accessibility audit against the right version turns an unknown into a list, and a list into a plan.

Write the report before the deal needs it. The expensive version of this is discovering the requirement during procurement with a customer waiting.

Where teams get it wrong

• Assuming B2B means out of scope. The obligation arrives through the customer.
• Building to 2.2 because it is newer. EN 301 549 names 2.1.
• Assuming the microenterprise exemption applies. It is narrow and it is about services.
• Claiming disproportionate burden without the documented assessment it requires.
• Treating one national implementation as the European position. It is a directive.
• Reading a blog post instead of getting advice. Including this one.