Accessibility Law 2025: Does It Apply to Your Site?

What the new accessibility rules cover

The act is about consumers. It lists the products and services covered, and for services it requires that the digital interface, the information about the service and the support around it are perceivable, operable, understandable and robust. For a website, that is in practice the European standard EN 301 549, which points to WCAG at level AA. PTS supervises most services; other authorities cover their own sectors.

Who is exempt

Two exemptions matter to small companies. The first is the micro-enterprise rule: a service provider with fewer than ten employees and turnover or balance sheet total at or below two million euro is not obliged to comply for services. The exemption is for services; manufacturers and importers of covered products do not get it. The second is that the act simply does not apply to business-to-business services, because it protects consumers.

E-commerce and consumer services

E-commerce services is the category that reaches most private companies. It covers services provided at a distance, through websites or apps, at the request of a consumer, with a view to concluding a consumer contract. A webshop is the obvious example, but online booking with payment, subscriptions and digital services sold to private customers can fall under it too. If your company is above the micro-enterprise thresholds and sells to consumers online, assume you are covered and verify.

There is a transition rule for service contracts concluded before 28 June 2025, which may continue unchanged until 28 June 2030. It does not cover new customers on an existing site, so in practice a live webshop above the thresholds should be working towards compliance now, not in 2030.

WCAG as the practical benchmark

Whether or not the law reaches you, WCAG level AA is the benchmark every agency and auditor uses, and it is what the harmonised standard points to. The good news is that most of it is ordinary good craft. The failures that stop real people are usually the same handful.

• Text contrast too low against the background, especially grey on white and text over images.
• Images without alternative text, and icons used as buttons with no label.
• Forms whose fields have no visible labels, or whose errors are shown only in red.
• Keyboard traps: menus, modals and carousels that cannot be operated without a mouse.
• Missing heading structure, so screen readers cannot skip to the relevant part.
• Videos without captions, and PDFs that are scanned images rather than text.

A site built well from the start passes most of this without extra effort, which is why accessibility belongs in the website brief rather than in a repair project a year later.

First steps if you are covered

1. Confirm scope: count employees, check turnover, and decide whether what you sell online is a consumer service.
2. Run an audit against WCAG AA of the pages that matter: product pages, cart, checkout, account, and the information about the service.
3. Fix the blocking issues first: contrast, labels, keyboard operation and error messages in the purchase flow.
4. Publish an accessibility statement describing how the service meets the requirements and how users can report problems.
5. Add accessibility to your acceptance criteria for every future release, so it does not decay.

When you do not need to buy anything: if you are a micro-enterprise with a brochure site, the law does not require an audit, and a competent rebuild or redesign will fix most issues as a side effect. Do not pay for an accessibility remediation project you are not obliged to run unless your customers are asking for it. If you are in scope, our UX audit includes an accessibility check, and a new build through our business website package is done to WCAG AA. Unsure which side of the line you are on? A free 15-minute call is usually enough to say.

Frequently asked questions