European Accessibility Act: who it covers

What the directive says

Directive (EU) 2019/882, adopted on April 17, 2019, sets common accessibility requirements across the EU. They apply to services provided to consumers after June 28, 2025.

For a website, the category that matters is e-commerce. The directive defines it as a service provided at a distance, through a website or an app, at the request of a consumer, with a view to concluding a consumer contract. It also covers consumer banking, e-books, electronic communications, access to audiovisual media, and several parts of passenger transport, including websites and ticketing.

For e-commerce, the text requires a service that is perceivable, operable, understandable and robust, including identification, security and payment. The site must also pass on the accessibility information of the products it sells, when their manufacturer provides it.

Who is covered, and who is exempt

The directive targets a service, not a type of company. Where you stand depends on what your website lets people do, and on the size of your business.

• Your website sells to consumers: it is an e-commerce service under the directive, even if your company is based outside the EU and sells to consumers who live there.
• Your website only sells to businesses: the directive covers services provided to consumers only.
• Your website presents your business but does not let anyone conclude a contract online: it falls outside the definition of e-commerce. Other obligations may apply depending on your status.
• Your company employs fewer than 10 people, and its annual turnover or its balance sheet total does not exceed 2 million euros: it is a microenterprise, exempt for the services it provides.

Both conditions of the exemption must be met. A company with 12 employees is not exempt, however small its turnover. French law applies the same rule, in Article L. 412-13 of the Consumer Code.

The text allows two other exceptions: making the service accessible would change its basic nature, or would impose a disproportionate burden. The company makes that assessment itself, and must be able to hand it over to the authorities that ask for it.

What you have to publish

The seller explains how its service meets the accessibility requirements, in its terms and conditions or in an equivalent document. In France, the decree of October 9, 2023 repeats what the directive lists: a general description of the service in an accessible format, the explanations needed to understand how it works, and how it meets the requirements.

This is not the same as France's accessibility statement, which follows the RGAA, the French accessibility standard. That statement comes from Article 47 of the law of February 11, 2005, which covers public bodies and companies whose turnover in France reaches 250 million euros. A large company that sells online falls under both texts. The guide on accessibility statements explains who needs one and what goes in it.

What is still open

The directive includes a transition period. A service contract agreed before June 28, 2025 can run unchanged until it ends, for up to five years. Products a provider already used to deliver its service can stay in use until June 28, 2030.

The directive does not list technical criteria. It sets requirements, and a service that meets the harmonized standards is presumed to comply. For a website, the WCAG criteria (the international web accessibility guidelines) and the RGAA, which builds on them, remain the basis of any check.

The RGAA itself is changing: the official site announces version 5 for late 2026.

What we find on the sites we audit

This percentage covers about 30 websites we audited between August 14, 2026 and September 24, 2026, the ones where this point could be checked. Many were audited because a defect showed up quickly, so the figure describes our audits, not websites in general.

A critical barrier stops someone from using an element: a button that a screen reader announces with no name, a form field with no label. When it shows up on almost every page, it usually sits in an element they all share, such as the menu or the header.

What the audit looks at

The audit records the barriers visible on the pages it analyzes, the ones that stop a visitor from moving forward.

• Text contrast, measured on the page as it renders, consent banner included.
• Text alternatives for images, and the names of links and buttons.
• Form field labels, the heading structure and navigation landmarks.
• Keyboard use, tested on menus, buttons and panels, and the visual marker that shows where you are.
• The accessibility statement, on sites that are legally required to publish one.

The report names each barrier and the pages where it appears. A barrier repeated everywhere can often be fixed in one place, in the shared element. A checkout that cannot be completed with a keyboard more often means reworking its components.

What this check doesn't tell you

By Quentin Mathis, Z29K · updated September 28, 2026