European Accessibility Act: is your website compliant?

The European Accessibility Act (EAA) has been EU law since June 28, 2025. If you run an online shop, a booking platform, or any commercial website that sells products or services, your site is probably in scope. And right now, most sites don't meet the requirements.

That's not a guess. The WebAIM Million 2026 report tested one million websites and found that 95.9% had detectable accessibility failures, with an average of 56.1 errors per page. Closer to home, the ACM tested roughly 100 of the largest Dutch webshops in March 2026. The result: 61% are not accessible. At more than half of those, placing an order with assistive technology is flat-out impossible.

The good news: the most common accessibility problems are also the easiest to fix. You don't need expensive consultants for the basics.

TL;DR: The EAA applies to businesses with 10+ employees or over €2M turnover that offer digital services (webshops, booking platforms, banking). Your site needs to meet WCAG 2.2 Level AA. Six error types cause 96% of all detected failures: low contrast, missing alt text, unlabeled forms, empty links, empty buttons, and missing page language. Free tools like WAVE and Lighthouse can find these. Start there, not with an overlay widget.

Table of contents

• What the European Accessibility Act requires
• Does this apply to your business?
• What WCAG 2.2 means for your website
• The six failures almost every website has
• How to test your website right now
• Quick wins that make the biggest difference
• Why accessibility overlays don't count
• What enforcement looks like in the Netherlands
• Practical checklist
• Key takeaways

What the European Accessibility Act requires

The EAA is Directive (EU) 2019/882, adopted in April 2019 with an application date of June 28, 2025. It requires that a range of digital products and services are accessible to people with disabilities. Think of it as the GDPR, but for accessibility instead of privacy.

The directive covers:

• E-commerce: webshops, online marketplaces, booking platforms
• Banking: internet banking, payment apps, account portals
• Electronic communications: telephone, messaging, video calling services
• Transport: digital ticketing, check-in, real-time travel information
• Audiovisual media: streaming services and related consumer equipment
• E-books: reading software and dedicated e-readers

If your business offers any of these digitally, your website and apps need to be accessible.

Each EU member state transposed the directive into national law. In the Netherlands, the implementation is the Implementatiewet toegankelijkheidsvoorschriften producten en diensten, which took effect on June 28, 2025.

Does this apply to your business?

There is one major exemption: micro-enterprises (businesses with fewer than 10 employees and annual turnover under €2 million) are fully exempt when they provide services. So a freelance web designer with a portfolio site, a small local shop with a basic webshop, or a sole proprietor with a booking page: no legal obligation under the EAA.

But here's the threshold to watch: the moment you have 10 employees or exceed €2M turnover, you're in scope. And enforcement bodies tend to look at companies just above that line, because that's where awareness is typically lowest.

Even if you're exempt, accessibility is still good business. According to Eurostat, 24% of the EU population aged 16 and over has some form of disability, roughly 90 million people. In the Netherlands alone, the ACM estimates 2.5 million citizens face barriers when using digital services. These are potential customers you're turning away if your site isn't accessible.

What WCAG 2.2 means for your website

The technical standard behind the EAA is EN 301 549, which incorporates the Web Content Accessibility Guidelines (WCAG) from the W3C. The current version is WCAG 2.2, published in October 2023, and Level AA is the target.

WCAG is built on four principles. Your content must be:

1. Perceivable: users can see or hear it (alt text on images, sufficient color contrast, captions on video)
2. Operable: users can interact with it (keyboard navigation works, no time traps, clickable targets are large enough)
3. Understandable: users can follow it (clear language, consistent navigation, helpful error messages in forms)
4. Robust: assistive technologies can interpret it (valid HTML, proper ARIA attributes, no code that confuses screen readers)

WCAG 2.2 added several new requirements over 2.1. The ones most relevant to a typical WordPress site: interactive elements must be at least 24×24 CSS pixels (2.5.8 Target Size), keyboard focus must not be completely hidden behind sticky headers or cookie banners (2.4.11 Focus Not Obscured), login processes can't require a CAPTCHA without an accessible alternative (3.3.8 Accessible Authentication), and users shouldn't have to re-enter information they already provided in the same session (3.3.7 Redundant Entry).

The six failures almost every website has

The WebAIM Million 2026 report analyzed one million home pages and found that just six error types account for 96% of all detected accessibility failures:

WordPress sites specifically averaged 52.8 errors per page. That is slightly better than the overall average of 56.1, but still far from compliant.

The pattern is telling. These aren't obscure technical issues. Low contrast text means your grey-on-light-grey body text or your pastel call-to-action buttons are unreadable for people with low vision. Missing alt text means a screen reader user has no idea what your product images show. Unlabeled form fields mean your contact form, search bar, or newsletter signup is unusable with assistive technology.

How to test your website right now

You don't need a consultant to find these issues. Three free tools will get you started:

WAVE: The most beginner-friendly option. Enter your URL or install the browser extension, and WAVE shows errors visually on your page. You see exactly where the missing alt text or low contrast is. Takes about 30 seconds per page.

Google Lighthouse: Already built into Chrome. Open DevTools (F12), go to the Lighthouse tab, check "Accessibility," and run it. You get a score from 0 to 100 plus a list of specific issues. No installation needed.

Equalize Digital Accessibility Checker: A WordPress plugin that scans your posts and pages inside the editor every time you save. It runs 45+ automated checks aligned to WCAG 2.2 and keeps everything on your server. If you run WordPress, this is the most practical ongoing tool.

One honest caveat: automated tools catch roughly 30–40% of WCAG issues. The rest (whether your heading structure makes logical sense, whether a screen reader user can follow your navigation flow, whether your custom interactive components actually work with a keyboard) requires manual testing. But that 30–40% covers the most common and most impactful failures. Start there.

Quick wins that make the biggest difference

In order of impact:

1. Fix color contrast. Use the WebAIM Contrast Checker to test your theme's text and background colors. Normal text needs a 4.5:1 ratio; large text needs 3:1. Most issues are in theme CSS, and your developer can fix these in an afternoon.
2. Add alt text to all images. Every image that conveys meaning needs descriptive alt text. Decorative images get an empty alt="". Go through your media library systematically.
3. Label your form fields. Every input needs a <label> element linked to it via the for attribute. Check your contact form, search box, newsletter signup, and checkout. Popular WordPress form plugins often miss this if you don't configure them carefully.
4. Check keyboard navigation. Tab through your entire site without a mouse. Can you reach every link, button, and form field? Can you see where the focus is? If your theme removes the focus outline with outline: none in CSS, fix that immediately.
5. Verify heading structure. One <h1> per page (your title), then <h2> for sections, <h3> for subsections. Never skip levels. Never use a heading tag just because you want bigger text.
6. Replace image CAPTCHAs. Standard image or math CAPTCHAs fail WCAG 2.2's accessible authentication requirement. Switch to Cloudflare Turnstile or hCaptcha with an audio alternative.
7. Set the page language. Add lang="en" (or lang="nl") to your HTML tag. Most WordPress themes do this, but check: 13.5% of websites get this wrong.

The WP Accessibility plugin by Joe Dolson can automatically fix several of these: it adds skip navigation links, improves focus indicators, and corrects language attributes. It's free and widely trusted.

Why accessibility overlays don't count

You've probably seen the ads: "Make your website accessible with one line of JavaScript." Tools like accessiBe and UserWay promise instant compliance through an overlay widget.

They don't deliver. An overlay cannot fix missing alt text, because it doesn't know what your images show. It cannot restructure broken heading levels. It cannot make an inaccessible checkout flow usable with a keyboard. It adds a layer on top of existing problems without solving them.

Worse, several major disability organizations have filed legal challenges against overlay vendors. The overlays can actually make sites harder to use for some people by interfering with the assistive technology they already rely on.

The EAA requires your underlying website to be accessible. An overlay widget is not a compliance strategy.

What enforcement looks like in the Netherlands

In the Netherlands, the ACM (Autoriteit Consument & Markt) is the primary enforcement body for e-commerce accessibility. They can impose fines up to €900,000. Consumers can file complaints through ConsuWijzer since June 2025.

The ACM's current approach is correction first, fines later. Their March 2026 report was a warning shot: we tested your webshops, 61% fail, improve or face consequences. Digital accessibility is explicitly listed as a 2026 enforcement priority.

Elsewhere in Europe, things are moving faster. In November 2025, three French disability organizations filed emergency injunctions against Auchan, Carrefour, E.Leclerc, and Picard Surgelés for non-compliance. Italy has started issuing 90-day remediation notices with fines up to 5% of annual turnover. Spain has the steepest penalty range: up to €1 million.

The trajectory is clear. The ACM won't stay in "awareness mode" forever. If you're above the micro-enterprise threshold and running a webshop, this is the window to get compliant before enforcement escalates.

Practical checklist

Use this to assess where you stand:

• Run a WAVE or Lighthouse accessibility audit on your home page, one product/service page, and your contact page
• Check and fix color contrast ratios (4.5:1 for normal text, 3:1 for large text)
• Add descriptive alt text to all meaningful images
• Verify all form fields have proper <label> elements
• Tab through your site using only the keyboard. Can you reach and use everything?
• Verify heading structure: one H1, then H2 → H3 without skipping
• Confirm your HTML has a lang attribute set correctly
• Replace image CAPTCHAs with an accessible alternative
• Check that cookie banners and popups don't trap keyboard focus
• Publish an accessibility statement (templates available at ondernemersplein.overheid.nl)

Key takeaways

• The EAA is in force since June 28, 2025. It applies to businesses with 10+ employees or €2M+ turnover offering webshops, booking platforms, banking, or similar digital services.
• Micro-enterprises (under 10 employees and under €2M turnover) are exempt for services, but accessibility still makes business sense.
• Six error types cause 96% of detected failures. All are fixable without specialized tools.
• Automated testing catches 30–40% of issues. That covers the most impactful problems. For the rest, you'll need manual testing or expert help.
• The ACM is actively auditing Dutch webshops. France, Italy, and Spain already have enforcement actions. The window to fix your site before fines arrive is now.