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

*2026-06-07 · Accessibility & Performance*

> Since 28 June 2025 the European Accessibility Act has made web accessibility a legal obligation, not best practice. Here's the scope, the standard, and why the same work pays off with AI engines too.

> 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out of date.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](/framework#performance). 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.