Accessibility is now law — what the European Accessibility Act means for your site

This guide is practical orientation, not legal advice. Confirm your specific obligations with a qualified adviser.

What changed on 28 June 2025

For years, accessibility was sold as a kindness or a nice-to-have. That framing is now out of date. The European Accessibility Act (Directive (EU) 2019/882) has applied since 28 June 2025, and it moves a wide range of consumer-facing digital services from "should be accessible" to "must be accessible, by law."

If your site sells to consumers in the EU, accessibility is now a compliance question with a deadline that has already passed — which means the sharpest version of this isn't "you should improve accessibility," it's "you may already be non-compliant."

Who it applies to

The EAA targets products and services aimed at consumers. On the web, that prominently includes:

• E-commerce — any site selling goods or services to consumers
• Banking and payments — consumer banking interfaces
• Transport — booking and ticketing services
• E-books and digital publications
• Telecoms and audiovisual access services

There are exemptions — notably, microenterprises (broadly, fewer than 10 staff and turnover or balance-sheet total of €2m or less) providing services are generally out of scope, and there's relief where compliance would impose a "disproportionate burden." Note the exemption covers services, not products a microenterprise places on the market. And these reliefs are narrower than people hope, with the burden of justifying one falling on you. Don't assume you're exempt; check.

In Ireland, the Act is transposed by S.I. No. 636 of 2023, with designated enforcement authorities and penalties for non-compliance.

The standard you're measured against

The EAA doesn't ask for vibes — it points at a technical standard: EN 301 549, the European accessibility standard, which for web content maps closely to WCAG 2.1 Level AA. Practically, that means the things accessibility practitioners have long recommended are now the legal baseline:

• Sufficient colour contrast
• Descriptive alt text on meaningful images
• Full keyboard navigation — nothing mouse-only
• Screen-reader compatibility — proper semantics and labels
• Clear focus states, logical reading order, accessible forms

Our framework scores this as P2 (WCAG 2.2 AA & EAA compliance) in the Accessibility & Performance pillar. We hold the bar at WCAG 2.2 AA — a small step beyond the current legal floor — because 2.2's additions (focus appearance, target size, dragging alternatives) are exactly where real users still get stuck. The standard is catching up too: EN 301 549 is moving to v4.1.1, which aligns it with WCAG 2.2 AA, so today's best practice is tomorrow's baseline.

Why this sits in an AI readiness framework

It might look odd to find a legal-compliance topic in a guide about AI. It isn't. The work that makes a page accessible is largely the same work that makes it machine-readable:

• Proper heading hierarchy and landmarks help screen readers and LLMs parse structure.
• Alt text describes images to assistive tech and to AI engines that can't see pixels.
• Keyboard-navigable, semantic markup is the same clean DOM agents rely on.

Accessibility and AI-readiness are two outcomes of one underlying discipline: a clean, structured, substrate layer that serves every consumer of your content — human or machine. Do it once, satisfy both.

The other half of the pillar: performance

The pillar is Accessibility & Performance for a reason. Fast, stable pages are the companion baseline — Core Web Vitals (P1) and a stable, server-rendered ground-truth layer (P3) that personalisation and immersive design sit on top of without hiding it from agents. Accessibility is the part that's now legally mandatory; performance is the part users and engines silently punish you for missing. Both are table stakes, not differentiators.

What to do this week

1. Decide honestly whether you're in scope — most consumer e-commerce is, and the microenterprise services exemption is narrow.
2. Run a free automated scan (axe, Lighthouse, WAVE) on your top templates to surface critical failures fast.
3. Fix the high-impact basics first: contrast, alt text, keyboard traps, form labels, focus visibility.
4. Commission a proper EN 301 549 / WCAG 2.2 AA audit for anything customer-facing, and keep the report — documented conformance is your evidence if challenged.