Which websites must comply with the European Accessibility Act?

The European Accessibility Act applies to services provided to consumers after 28 June 2025, in every EU member state. For websites, the question is not whether a site exists but whether it sells something. E-commerce is explicitly in scope, and the obligation covers the online sale of any product or service — not only products the Act regulates elsewhere.

A purely informational brochure site, with no transactional function and no connection to a service the Act covers, is generally out of scope. Many agency clients are not.

Article 2 of the directive lists the consumer services covered. The ones an agency meets most often:

• E-commerce services — online shops and booking flows, of any product or service.
• Consumer banking services.
• Passenger transport service elements: websites, mobile services, e-tickets and real-time travel information.
• Electronic communications services.
• Audiovisual media access.

Microenterprises providing services are exempt. The definition is specific: fewer than 10 persons, and an annual turnover or balance sheet total not exceeding €2 million. Both conditions apply, and the exemption covers services — a microenterprise selling products still carries the product obligations.

An agency's client with 12 staff and a €400,000 shop does not qualify. Neither does one with 5 staff and €2.4 million in turnover. Check the numbers before passing the exemption on.

The directive does not name WCAG. In practice, EN 301 549 is the European standard used to evidence conformity, and its web clauses map to WCAG 2.1 Level AA. That is the baseline a functional assessment works against. (A newer edition adding WCAG 2.2 was published in September 2026 but has not yet been cited in the Official Journal for this directive.)

The BFSG is the national transposition and applies from 28 June 2025. Offering or providing a service that breaches it can draw a fine of up to €100,000 under § 37(2); other breaches carry lower caps. Enforcement runs through the market surveillance authority and the arbitration body for accessibility.

Two separate penalties sit in Article 47 of the law of 11 February 2005, per Arcom: up to €25,000 for failing the declarative obligations — a missing or inaccurate accessibility statement — and up to €50,000 for non-conformity with the accessibility requirements themselves. Both are renewable every six months while the breach persists.

The sequence that fits an SME budget: assess the site against WCAG 2.1 AA, fix what fails, publish an accessibility statement, and keep the dated record. France's €25,000 penalty attaches precisely to the statement agencies forget.

Dossier produces that assessment for €149 per site: findings mapped to success criteria with the failing markup quoted, a plain-language summary your client can read, a draft accessibility statement, and the limits of automation stated in writing. Assessments, not audits — we say so on the cover.

1. Directive (EU) 2019/882 (European Accessibility Act), EUR-Lex
2. European Commission — European Accessibility Act overview
3. EN 301 549 v3.2.1 (ETSI), clauses 9–11
4. BFSG (Germany), § 37(2) — gesetze-im-internet.de
5. Arcom (France) — sanctions under Article 47 of loi n° 2005-102

Country penalty figures current as of 18 September 2026. This page is general information, not legal advice.