The European Accessibility Act: What US Businesses Selling Into the EU Need to Know
The European Accessibility Act is an EU directive that applies to listed products and services offered to consumers in the EU after 28 June 2025, including e-commerce and consumer banking. If your US business sells online to EU consumers, it is worth knowing what is in scope, who is exempt, and what a sensible technical target looks like.
By George Shvaya · · 6 min read
This page is general information, not legal advice. It sticks to what the text of Directive (EU) 2019/882 says. Each EU member state transposed the directive into its own national law, and the details of enforcement sit there, which is a question for counsel in the markets you sell into.
What the directive covers
The table summarizes the scope provisions most relevant to a business website or online store. Article numbers refer to the directive text linked above.
| Provision | What the directive says |
|---|---|
| When it applies | Products placed on the market after 28 June 2025; services provided to consumers after 28 June 2025 (Article 2). |
| Services covered (selected) | E-commerce services, consumer banking services, e-books, passenger transport services, electronic communications, access to audiovisual media services (Article 2(2)). |
| Microenterprise exemption | Microenterprises providing services are exempt from the accessibility requirements (Article 4(5)). |
| Microenterprise definition | Fewer than 10 employees and annual turnover, or annual balance sheet total, not exceeding EUR 2 million (Article 3(23)). |
| Audience | Products and services offered to consumers in the EU. |
Two details are easy to miss. First, the list is specific: the directive applies to the products and services it names, not to every website. A brochure site for a US contractor is a different situation from an online store taking orders from consumers in Germany. Second, the microenterprise exemption in Article 4(5) applies to services, and the definition in Article 3(23) is narrow: “an enterprise which employs fewer than 10 persons and which has an annual turnover not exceeding EUR 2 million” (or a balance sheet total of the same).
What this means for a US business
If you sell to consumers in the EU through a website or app, and what you sell falls in one of the covered service categories, the directive is relevant to you. The practical questions are the ones you would ask for any market: who your customers are, which of your services they use, and whether your business size puts you inside the microenterprise exemption. If the answers are unclear, that is the point to involve counsel familiar with the member states you sell into.
The engineering question is simpler, and it is the same one US law already raises. For state and local governments the ADA Title II rule names WCAG 2.1 AA, and for businesses open to the public the Justice Department’s guidance points to WCAG as helpful guidance (see Does the ADA apply to business websites?). A site built and tested to WCAG is in a better position everywhere.
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Practical steps (our recommendation)
The steps below are our recommendation for an online business, not a requirement read from the directive.
- Map what you offer to EU consumers. List the services that reach them, such as the store, account area and support, and check each against the covered categories.
- Check the exemption honestly. Headcount and turnover or balance sheet total decide the microenterprise question for services.
- Adopt a technical target. We recommend WCAG 2.2 Level AA for new work, which also covers 2.1 AA except the retired 4.1.1 Parsing criterion. Our WCAG 2.1 vs 2.2 comparison explains the difference.
- Test the paths that matter. Product discovery, cart, checkout, login and account settings, with a keyboard and a screen reader as well as automated tools. Our WCAG 2.2 checklist lists every A and AA criterion.
- Fix in code, not with an overlay. The FTC found that one overlay vendor’s claim to make any site WCAG compliant was deceptive; we cover that in accessibility overlays and the FTC.
A quick first look is free: our accessibility checker runs a set of automated checks on any public page, and the WCAG glossary entry covers the terms used above.
Frequently asked questions
When did the European Accessibility Act start to apply?
Directive (EU) 2019/882 applies to listed products placed on the market after 28 June 2025 and to listed services provided to consumers after 28 June 2025. This is general information, not legal advice.
Does the European Accessibility Act cover e-commerce?
Yes. Article 2(2) lists e-commerce services among the services the directive applies to, alongside consumer banking services, e-books, passenger transport services, electronic communications and access to audiovisual media services.
Are small businesses exempt from the European Accessibility Act?
Microenterprises providing services are exempt from the accessibility requirements under Article 4(5). The directive defines a microenterprise as an enterprise with fewer than 10 employees and an annual turnover, or an annual balance sheet total, not exceeding EUR 2 million. The exemption is for services; check the directive for how it applies to products.
Does the EAA name a WCAG version?
This article does not rely on a WCAG version being named in the directive. Our recommendation, as a working technical target for websites and apps offered to EU consumers, is WCAG 2.1 or 2.2 Level AA, because those are the most widely used standards for testing web accessibility.
About the work
Webvello is a web development and AI search optimization company founded in 2024, based in Roseville, California, with 50+ projects delivered across 37+ cities. Our accessibility service covers audits, remediation in code, accessible rebuilds and ongoing monitoring. Founder George Shvaya came to the web from cybersecurity and systems engineering.
Source: Directive (EU) 2019/882 on EUR-Lex, linked above. This page is general information, not legal advice, and does not address national transposition, enforcement or penalties.
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