What the European Accessibility Act means for web agencies

By the A11yKeeper team · Updated October 16, 2026 · Not legal advice

In short

  • The European Accessibility Act (Directive (EU) 2019/882) has applied since 28 June 2025, with some transition periods up to 2030.
  • It covers services such as e-commerce, consumer banking, e-books, electronic communications and parts of passenger transport.
  • Businesses outside the EU can be covered when they offer covered services to consumers in the EU.
  • Service microenterprises (fewer than 10 staff and no more than €2 million turnover or balance sheet) are exempt from the service requirements.

Which of your clients are likely in scope?

Start with clients who sell to consumers in the EU online: shops, banks and other consumer banking or payment providers, publishers of e-books, and air, bus, rail and ferry operators (their websites, apps and e-tickets). A local business that doesn't sell online, or a service microenterprise, is less likely to be covered. Make a simple list: does the client sell to EU consumers, and how big are they?

Which standard do websites have to meet?

The EAA doesn't name a standard in its text. It gives a presumption of conformity to harmonised standards once their reference is published in the Official Journal of the EU. The European standard for this is EN 301 549: version V4.1.1, published in September 2026 for the EAA, aligns its web requirements with WCAG 2.2, while the earlier V3.2.1 used WCAG 2.1. W3C says content that conforms to WCAG 2.2 also conforms to WCAG 2.1, so WCAG 2.2 AA is a sensible target to test against.

What agencies can do now

  1. List every client site and mark which ones sell to EU consumers.
  2. Run a baseline scan on each one. Our free checker covers 10 pages per site.
  3. Fix shared templates first: headers, footers, menus and product cards repeat on every page.
  4. Help the client prepare the accessibility information the EAA asks service providers to make public (Article 13 and Annex V).
  5. Monitor monthly, because new content and plugins bring new issues.

How to talk to clients without overpromising

Say what you can stand behind: "We check your site every month with automated tools, fix what we find, and flag what needs a manual review." Don't promise a legal outcome, and suggest a lawyer for legal questions.

A11yKeeper helps agencies do exactly this: scan a client site today and send a white-label report, with scheduled monthly checks across all client sites coming soon. See how it works for agencies.

Questions

When did the European Accessibility Act start to apply?

Member states had to apply their national EAA rules from 28 June 2025. There are transition periods: service contracts agreed before that date can run until they expire, but no longer than five years, and products already used to provide a service can stay in use until 28 June 2030.

Does the EAA apply to businesses outside the EU?

The directive counts as a service provider anyone who provides a covered service on the EU market or offers it to consumers in the EU, so a business based elsewhere that sells covered services to EU consumers can be covered.

Are small businesses exempt?

Microenterprises that provide services (fewer than 10 staff and annual turnover or balance sheet total of no more than €2 million) are exempt from the accessibility requirements for services. Microenterprises that deal in products are not exempt in the same way, so check each client's situation.

Which technical standard is used?

The directive itself doesn't name a standard. Meeting a harmonised standard gives a presumption of conformity once its reference is published in the Official Journal of the EU. EN 301 549 V4.1.1 (September 2026) was written for the EAA and aligns its web requirements with WCAG 2.2; the earlier V3.2.1 used WCAG 2.1. Check whether V4.1.1 has been cited in the Official Journal yet.

Can an automated scan show that a client meets the EAA?

No. Automated checks find part of the issues and are a good way to monitor sites, but they can't decide whether a business meets the law. Clients with legal questions should ask a lawyer.

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