If you run a small business in the UK and someone has told you the European Accessibility Act now applies to your website, the honest answer is: probably not — and the law that does apply to you has been in force since 2010. Both halves of that sentence matter, because the second one is the one nobody sells you a subscription for.
This guide is written for the person who has to decide something: whether to spend money on accessibility work, and on what basis. Every legal reference below is quoted from the primary source, and where we could not read something ourselves, we say so.
This is not legal advice. We build and measure websites; we are not solicitors. Where a decision turns on your specific trading arrangements, take advice from someone who is.
What the Act actually is
The European Accessibility Act is Directive (EU) 2019/882. It sets accessibility requirements for a defined list of products and services, and Member States have had to apply their national versions of it from 28 June 2025 (Article 31(2)).
It is not a general "all websites must be accessible" law. Article 2 lists what is in scope, and the list is specific.
Products (Article 2(1)) include consumer computers and their operating systems, payment terminals, ATMs, ticketing and check-in machines, consumer terminal equipment for electronic communications and for audiovisual media, and e-readers.
Services (Article 2(2)) are:
- electronic communications services;
- services providing access to audiovisual media services;
- listed elements of air, bus, rail and waterborne passenger transport;
- consumer banking services;
- e-books and dedicated software; and
- e-commerce services.
That last one is the entry most small businesses need to read. The Act defines an e-commerce service (Article 3) as a service "provided at a distance, through websites and mobile device-based services by electronic means and at the individual request of a consumer with a view to concluding a consumer contract". In plain terms: a website through which a consumer can buy something.
A brochure website with a phone number is not an e-commerce service. A website with a shop, a booking-and-pay flow, or an online quote-to-contract journey looks a great deal like one.
The question that decides it is not where you are — it is who you sell to
The Directive defines a service provider as "any natural or legal person who provides a service on the Union market or makes offers to provide such a service to consumers in the Union" (Article 3).
So the hook is the market, not the registered address. A UK business that ships to consumers in Ireland, France or Germany, prices in euros, or takes orders from EU consumers is offering a service on the Union market. A UK business selling to UK customers only is not — the Act does not reach it, because the UK is no longer a Member State and no UK statute has transposed this Directive.
The microenterprise exemption — read this before you spend anything
Article 4(5) says, in full:
Microenterprises providing services shall be exempt from complying with the accessibility requirements referred to in paragraph 3 of this Article and any obligations relating to the compliance with those requirements.
And the Directive defines the term itself (Article 3): a microenterprise is "an enterprise which employs fewer than 10 persons and which has an annual turnover not exceeding EUR 2 million or an annual balance sheet total not exceeding EUR 2 million".
So a genuine microenterprise providing a service — the great majority of the businesses we work with — is exempt from the service requirements even when it is selling into the EU. Note two limits on that, because they are easy to miss:
- The exemption is for microenterprises providing services. Microenterprises dealing with products are not exempted in the same way; their relief is lighter paperwork, not exemption.
- Fewer than 10 people is a hard condition, not a rough guide, and the Directive expects the test to be met genuinely rather than engineered around.
If you are over that line and selling into the EU, the next thing to look at is Article 14, which lets an operator apply the requirements only to the extent they do not impose a disproportionate burden — assessed against the criteria in Annex VI, documented, and (for service providers) renewed at least every five years. One sentence from the Directive's own recitals is worth committing to memory, because it kills the most popular excuse: "Lack of priority, time or knowledge should not be considered to be legitimate reasons."
What the law says about your website if you are in scope
Annex I sets functional requirements rather than a code checklist. For services, it requires information about the service to be made available "via more than one sensory channel", presented "in fonts of adequate size and suitable shape … using sufficient contrast, as well as adjustable spacing between letters, lines and paragraphs", and websites and mobile apps to be made accessible "in a consistent and adequate way by making them perceivable, operable, understandable and robust".
Those four words — perceivable, operable, understandable, robust — are the four principles of the Web Content Accessibility Guidelines. Which brings us to the detail almost every accessibility sales page gets wrong.
The currency trap: the standard the law points at is not the newest standard
Article 15 of the Act gives the usual European mechanism: a product or service that conforms to a harmonised standard whose reference has been published in the Official Journal of the European Union is presumed to conform to the accessibility requirements.
For digital accessibility that standard is EN 301 549. And here is the part worth knowing before you buy anything advertised as "WCAG 2.2 compliance":
- The version the Official Journal points at is EN 301 549 v3.2.1 (2021-03), published there by Commission Implementing Decision (EU) 2021/1339 of 11 August 2021 (OJ L 289, 12.8.2021, pp. 53–55), which amended the earlier Decision (EU) 2018/2048 for the public-sector Web Accessibility Directive.
- That standard builds on WCAG 2.1, not WCAG 2.2. The European Commission's own guidance says of the two most recent versions: "Both versions build heavily on WCAG 2.1."
- And the Commission is explicit about what happens when the W3C publishes something newer: "New versions of the WCAG or of EN 301 549 do not automatically change the legal obligations."
WCAG 2.2 exists, it is good, and building to it is a perfectly sensible decision. But "WCAG 2.2 compliant" is a supplier's marketing phrase, not the wording of any instrument that binds you — and if someone quotes it at you as a legal requirement, that tells you something useful about the someone.
What actually binds a UK business: the Equality Act 2010
This is the part the EAA panic tends to crowd out. Under section 29 of the Equality Act 2010, a service provider "must not discriminate against a person requiring the service by not providing the person with the service", and "a duty to make reasonable adjustments applies to … a service-provider".
Section 20 sets out what that duty comprises — three requirements, covering a provision, criterion or practice, a physical feature, and the provision of an auxiliary aid, each requiring "such steps as it is reasonable to have to take to avoid the disadvantage". And section 20(6) says it plainly for anyone publishing information:
Where the first or third requirement relates to the provision of information, the steps which it is reasonable for A to have to take include steps for ensuring that in the circumstances concerned the information is provided in an accessible format.
A website is how most businesses now provide information and offer services. The duty is anticipatory in service provision — it is not a duty to wait until a disabled customer complains — and the standard is reasonableness, which scales with the size of the business. There is no page-count threshold, no exemption for being small, and no technical standard named in the Act. What there is, is a duty to take reasonable steps.
That is the honest legal picture for a UK small business: not a directive with a deadline, but a fifteen-year-old duty that most websites quietly fail.
And if you are a UK public sector body
Different regime again. The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 (SI 2018/952) require public sector bodies to comply with "the accessibility requirement", which regulation 3 defines as "the requirement to make a website or mobile application accessible by making it perceivable, operable, understandable and robust". Conformity is presumed where the relevant harmonised standard is met (regulation 9), and a published, honest accessibility statement naming what is not accessible and why is part of the obligation (regulation 8).
If you contract for a school, a council, an NHS body or a charity delivering an essential public service, this is the regime your work sits under — and the accessibility statement is a deliverable, not an afterthought.
So what should you actually do?
Sorted into what the law requires, what we would recommend, and what is our opinion — because a guide that blurs those three is not much use.
Required (if you trade in the UK): take reasonable steps so a disabled customer can use your service. In practice that means the basics — text a person with low vision can read, a site that works with a keyboard and a screen reader, forms with labels, and an alternative route to reach you.
Recommended: build and measure against WCAG 2.2 AA. It is a superset of the version the European standard currently references, it is the level UK public procurement expects, and it is the only widely-understood yardstick. Then get it measured, not asserted.
Our opinion: the legal question is the least interesting reason to do this. The Department for Work and Pensions' Family Resources Survey puts the number of disabled people in the UK at 16.8 million, or 25% of the population, in 2023–24 — up from 19% a decade earlier. A site that fails contrast, breaks on a keyboard or hides its phone number behind an unlabelled icon is losing enquiries from a quarter of the market, and none of those people email you to say why they left.
What we do about it, and what we publish
We are not going to tell you our own sites are "compliant" — nobody honest can, because automated testing finds only a minority of real barriers and the word implies a certificate nobody issues. What we can do is show the measurement.
Every deployment of this website and of all seven of our public demos runs a blocking accessibility gate in continuous integration: an axe-core WCAG 2.2 A/AA audit at phone and desktop widths, plus our own pixel-level contrast probe that reads the colours actually painted on screen in both the light and dark themes. If either fails, the build does not ship. When we last measured this site, that pair of gates covered 6,502 individual elements across 48 page renders.
We know exactly what that catches, because we have watched it catch things — including 306 real contrast failures on our own pages, in a theme that our own earlier audits had never entered. That story is in the eight faults we find on almost every small-business website, and the reason a brand colour keeps causing it is in colour, contrast and the ground it lands on.
If you would like a straight answer about your own site rather than a scare about a directive, get in touch — we will tell you what we measured, what it means, and whether it is worth fixing.
Sources quoted in this guide, all read directly: Directive (EU) 2019/882 (Articles 2, 3, 4, 14, 15, 31 and Annex I); Commission Implementing Decision (EU) 2021/1339, OJ L 289, 12.8.2021; the European Commission's guidance on changes to the accessibility standard; the Equality Act 2010, sections 20 and 29; the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018; and the Department for Work and Pensions' Family Resources Survey for 2023–24.
Kieran Bourne is the founder of Neubor, a Stoke-on-Trent web development and AI studio. Neubor runs blocking WCAG 2.2 AA gates on its own website and on every demo it publishes, and publishes what they measure.