The European Accessibility Act, Explained for People Who Run a Website (Not a Legal Department)
I get the same message every few weeks now. A friend, a client, someone from a Slack group: "Hey, does this EAA thing apply to my shop? Someone sent me a scary email."
Short answer: if you sell to consumers in the EU through a website or an app, probably yes. Longer answer below, in plain English, because the directive itself is 50 pages and most of the summaries online are written by people trying to sell you an overlay widget.
I'm not a lawyer. I'm the person who gets called when the lawyer says "make the website compliant" and someone has to turn that sentence into a to-do list. This is that to-do list.
What the EAA actually is
The European Accessibility Act is Directive (EU) 2019/882. It was adopted in 2019, every EU country had to turn it into national law, and the obligations have applied since 28 June 2025.
The idea is simple: a defined set of products and services sold to consumers has to be accessible to people with disabilities, and the rules have to be the same across the EU so a company doesn't need 27 different versions of its checkout.
The list of services it covers includes, among others:
- E-commerce services. Any store selling online to an EU consumer, wherever the store is based.
- Consumer banking services
- Electronic communications (telecom) services
- Access to audiovisual media services
- Parts of passenger transport (websites, apps, ticketing)
- E-books and e-readers
For most people reading this, the relevant line is the first one. If you take money from EU consumers on a website, the EAA is talking about you.
"But I'm a small business"
There is an exemption, and it matters, so let's be precise about it.
Microenterprises providing services are exempt. A microenterprise is a business with fewer than 10 employees and annual turnover or balance-sheet total of 2 million euros or less. You need to meet both the headcount limit and one of the financial limits.
Two things people get wrong here:
- The exemption is for service providers. If you manufacture or import products that are in scope (say, self-service terminals or e-readers), the microenterprise exemption does not apply the same way.
- Ten employees is not a lot. The moment you hire the eleventh person, or your turnover crosses two million, you are in scope for the whole flow, not just the home page.
There is also a "disproportionate burden" defence (Article 14): you can argue that meeting a requirement would cost more than it is reasonably worth for your business. In practice this requires you to document the assessment and keep it for five years, and it is not a blanket "we're small so we didn't bother." If you ever want to use it, you need to have done the homework first.
What "accessible" means in practice
The directive doesn't list technical rules itself. It points at a European standard, EN 301 549, which for websites and apps essentially says: meet WCAG 2.1 Level AA.
If you have never looked at WCAG, it is the W3C's Web Content Accessibility Guidelines: about 50 testable criteria at Level AA. Things like:
- Every image that carries meaning has a text alternative
- Text has enough contrast against its background
- Everything works with a keyboard, not only a mouse
- Form fields have labels a screen reader can announce
- The page declares its language
- Users can zoom to 200% without the layout breaking
- Nothing flashes, nothing auto-plays sound without a way to stop it
None of this is exotic. Most of it is "write the HTML properly." The problem is that almost nobody does: the WebAIM Million 2025 study found that 94.8% of the top one million home pages fail at least one WCAG 2 check, with an average of 51 errors per page. Low contrast text shows up on 79% of pages, and more than half of the images they found had no usable alt text.
So the bar is not high. It is just that nobody has been clearing it.
Two more practical points from the EAA:
- The whole flow counts. For e-commerce that means search, product page, cart, checkout, confirmation, and the account pages. Fixing the landing page and calling it done is not compliance.
- You need an accessibility statement. A published page saying what standard you meet, what you know is not accessible yet, and how someone can contact you about it. This is a document, not a widget.
How it works in Sweden
Because this is a directive, each country wrote its own law. In Sweden it is lag (2023:254) om vissa produkters och tjänsters tillgänglighet, with the details in förordning (2023:676). Same date: 28 June 2025.
Supervision is split by sector. Konsumentverket (the Swedish Consumer Agency) is the lead coordinating authority, with PTS (the Post and Telecom Authority) and a few others covering their own areas. For a normal online shop, Konsumentverket is the one that would knock.
A common confusion: Sweden has had a separate law for public-sector websites since 2019, usually called DOS-lagen, enforced by DIGG. That one applies to municipalities, agencies and so on. The EAA is the private-sector counterpart. If you are a company, DOS-lagen was never your problem. The EAA is.
What enforcement looks like
I want to be careful here, because the people selling panic are not doing you a favour.
In the EU, enforcement is through market surveillance authorities. They can order you to fix things, and national law sets penalties. In Sweden the law allows for injunctions backed by fines (vite). There is no "accessibility lawsuit industry" here yet.
In the United States there is. More than 5,000 digital accessibility lawsuits were filed in 2025, roughly 70% of them against e-commerce sites, and almost half the federal cases hit companies that had already been sued once. I wrote about what that looks like for real-estate sites in New York in an earlier post. The EAA gives European complainants a clear standard to point at, and I would expect the curve here to bend in the same direction, slower.
The honest framing: the risk today is a regulator order and a bad week, not a seven-figure judgment. The risk is growing. And the fix is mostly cheap if you start now, and expensive if you start after the letter arrives.
Three things to do this quarter
1. Find out where you stand. Run an automated audit against your main pages and your checkout. Automated tools catch the majority of common failures (missing alt text, contrast, unlabeled fields, empty links) in seconds. I co-built Alfa Audit exactly for this: add a URL, get a ranked list of what to fix with the WCAG criterion next to each item. Free to start.
2. Fix the top of the list, not all of it. A good audit ranks by impact. The critical and high items are usually a day or two of developer time on a typical site. Do those, re-run, and keep the report. A dated audit trail that shows you are improving is worth more to a regulator than a perfect score you got last Tuesday.
3. Publish an accessibility statement. Standard you aim for, known gaps, a contact address, the date. If you don't want to write it from scratch, Legal Craft generates one and can link it to your live audit report.
Then, and only then, worry about the long tail: manual testing with a screen reader, keyboard-only walkthroughs, PDFs. Those matter, but they come after the basics.
What not to do
Do not install an "accessibility overlay" and consider the job done. These are the JavaScript widgets that add a little icon and promise compliance in one line of code. They do not fix your HTML, screen-reader users widely dislike them, and in the US they have been named in lawsuits against the very companies that installed them. If a vendor tells you a widget makes you EAA compliant, that is your signal to end the call.
The one-paragraph version
If you sell to EU consumers online and you have 10 or more employees (or more than 2 million euros turnover), the EAA applies to your whole purchase flow and has since June 2025. The technical bar is WCAG 2.1 AA. You also need an accessibility statement. Start with an automated audit, fix the critical items, publish the statement, keep the reports. That is most of it.
This post is general information, not legal advice. The directive and the Swedish act are the sources; check the specifics for your sector and country, and talk to a lawyer if there is real money on the line.
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