What the European Accessibility Act requires from your website before June 2025

Directive (EU) 2019/882 applies from 28 June 2025. It covers e-commerce, consumer banking, e-books, passenger transport and electronic communications services sold to consumers in the EU. The web reference behind it is EN 301 549, whose clause 9 restates the WCAG 2.1 Level A and AA success criteria. Microenterprises providing services are exempt.

Key takeaways

• The directive was adopted on 17 April 2019. Member States had to transpose it by 28 June 2022 and apply the measures from 28 June 2025, under Article 31.
• Scope is a closed list, not every website. Article 2 names five categories of product and six categories of service, with e-commerce among them.
• A microenterprise employs fewer than 10 people and has annual turnover or a balance sheet total no higher than €2 million. Microenterprises providing services are exempt.
• The only version of EN 301 549 cited in the Official Journal is V3.2.1 (2021-03), and it was cited under the public sector directive rather than this one.
• Service contracts agreed before 28 June 2025 can run unchanged for up to five years, and self-service terminals already in use for up to 20 years, under Article 32.

What the directive actually covers

Article 2 splits the scope in two. On the product side it lists consumer computer hardware and operating systems, e-readers, and consumer terminal equipment used for electronic communications or for reaching audiovisual media services. It also lists self-service terminals: payment terminals, ATMs, ticketing machines and check-in machines.

On the service side it lists electronic communications services, access to audiovisual media, consumer banking services, e-books with their dedicated software, and e-commerce. Parts of air, bus, rail and waterborne passenger transport are covered too, as is answering 112 emergency calls.

E-commerce is the entry point that pulls most web work into scope. A brochure site with no transaction is not automatically covered; a checkout that sells to consumers in the EU is. That distinction decides whether June 2025 is a legal deadline or an internal quality target.

Who is exempt, and what exempt does not mean

The directive defines a microenterprise as an enterprise employing fewer than 10 people with annual turnover or an annual balance sheet total not exceeding €2 million. Article 4(5) then exempts microenterprises providing services from the service requirements. The exemption is narrow, and it does not travel with a company into product obligations.

Above that threshold, Article 14 offers two arguments rather than an exemption. The requirements apply only where compliance would not fundamentally alter the basic nature of the product or service, and would not impose a disproportionate burden. Both are assessments the operator performs against the criteria in Annex VI.

Under Article 14(6) of Directive (EU) 2019/882, an operator that has received funding provided for the purpose of improving accessibility cannot invoke the disproportionate burden exception. The assessment must be documented, kept for five years, and repeated by service providers at least every five years (EUR-Lex, 7 June 2019).

Which technical standard is actually cited

The directive works through presumption of conformity. Meet a harmonised standard whose reference is published in the Official Journal, and you are presumed to meet the corresponding requirement. That makes the published reference the operative document, not the standard engineers happen to know.

Today the only version of EN 301 549 cited in the Official Journal is V3.2.1 (2021-03). It was cited by Commission Implementing Decision (EU) 2021/1339 of 11 August 2021, applicable from 12 February 2022, under the public sector directive rather than under this one. Standardisation request M/587, adopted on 14 September 2022, asks CEN, CENELEC and ETSI to revise EN 301 549 for this directive by 15 September 2025.

Standardisation request M/587 (Commission Implementing Decision C(2022) 6456, 14 September 2022) sets 15 September 2025 as the delivery date for the revised EN 301 549. That is almost three months after the directive starts to apply, so the revision cannot support a June 2025 release plan.

The engineering conclusion is dull and stable. Build against EN 301 549 V3.2.1 and WCAG 2.1 Level AA now, and treat the revision as a later delta.

What WCAG 2.1 Level AA asks a front-end team to do

WCAG 2.1 became a W3C Recommendation on 5 June 2018 and defines 78 success criteria across three conformance levels. Level AA means satisfying every Level A and Level AA criterion, or providing a conforming alternate version. Clause 9 of EN 301 549 restates those criteria as numbered requirements for web content.

Day to day, the criteria concentrate in a short list of decisions:

• sufficient text contrast and a visible focus indicator;
• alternative text for images and a declared page language;
• programmatic labels for form fields and accessible names for links and buttons;
• keyboard operability with no focus traps;
• layouts that survive resize and reflow.

Most of those are decided in the design system, not in individual templates. That puts them inside the contract between design tokens and code and inside the type, color and contrast rules of a screen brand system.

The WebAIM Million, published in February 2024, tested the home pages of the top 1,000,000 sites. It detected WCAG 2 failures on 95.9% of them, averaging 56.8 errors per page, and six issue types accounted for 96.4% of all errors detected (WebAIM, February 2024).

A remediation order that fits a release schedule

Start where detection is cheap and coverage is broad. Six issue types dominated the WebAIM sample:

• low contrast text, 81.0%;
• missing image alternative text, 54.5%;
• missing form input labels, 48.6%;
• empty links, 44.6%;
• empty buttons, 28.2%;
• missing document language, 17.1%.

Fix them at the source. Contrast is a token decision, labels and accessible names are component decisions, and document language is a layout decision. Patching page by page produces a green scan and a regression three releases later.

Then walk the transactional path with a keyboard only: listing, product, cart, checkout, account. This is where the directive has teeth for e-commerce, and where most of the JavaScript sits, so it overlaps with the work that moves largest contentful paint. Only after that is manual testing with assistive technology worth booking, because it should find design problems rather than missing labels.

Automated tools detect a subset of failures. A page that passes every automated check can still be unusable, so the scan closes the cheap gap and never replaces the audit.

What the CMS has to carry

Accessibility fails permanently when the content model has no field for it. Alternative text, caption tracks, table headers, link purpose and page language are content, not styling. They need required fields with validation, not optional notes. This is the argument for modelling content so it survives a redesign, applied to a legal requirement.

The practical test is whether an editor without a technical background can publish an inaccessible page unimpeded. If they can, the remediation has a shelf life measured in weeks. Guidance helps; a required field with a character minimum is what holds.

Spain: which instrument applies and to whom

In Spain the directive is transposed by Ley 11/2023, de 8 de mayo, published in the BOE on 9 May 2023. Its Título I carries the accessibility requirements for products and services, and its preamble repeats the directive calendar: transposition by 28 June 2022, effective application on 28 June 2025.

Spanish public sector sites already live under a separate regime. Real Decreto 1112/2018, de 7 de septiembre, transposes Directive (EU) 2016/2102 and has applied to public administrations, their websites and their mobile apps since 2018. A studio serving both markets now maintains two regimes over the same technical reference. That argues for one accessibility baseline in the design system, not two project standards.

Budget matters here. Many Spanish SMEs built their current site in the last subsidy cycle, including work funded through the Kit Digital programme, and those sites will be adapted rather than rebuilt. Adapting a design system costs less than adapting 300 pages, which is the case for doing component work first.

What to document before 28 June 2025

If you rely on fundamental alteration or disproportionate burden, Article 14 turns the argument into paperwork with a lifespan. The assessment has to follow the Annex VI criteria, be documented, and be kept for five years after the product was last made available or the service last provided. Service providers redo it when the service changes, on request from an authority, and at least every five years.

Operators relying on the exception also have to inform the relevant market surveillance authority. Microenterprises dealing with products are relieved of the documentation duty, though an authority can still ask them for the facts behind the assessment.

Article 32 buys time in two specific places, not in general. Service contracts agreed before 28 June 2025 may continue unchanged until they expire, for no more than five years from that date. Member States may also allow self-service terminals lawfully in use before then to run to the end of their economic life, up to 20 years.

FAQ