Does the European Accessibility Act apply to my UK business?

Short answer: if someone in the EU can buy from your website, probably yes. Being based in the UK does not take you out of scope. The test is not where your company is registered. It is which market you sell into.

This guide walks through how to work out whether you are in scope, what the law actually asks for, and what enforcement has looked like so far.

The one thing most UK businesses get wrong

A lot of UK business owners heard about the European Accessibility Act, checked that their company is registered in England, and moved on.

That is the wrong test.

The EAA is extraterritorial. It applies based on whether you are offering products or services to consumers in the EU, not on where you are established. If an EU resident can land on your site and complete a purchase, you are offering into the EU market.

The date has already passed, too. The EAA became applicable on 28 June 2025. This is not a deadline coming up. It is a law that is already in force, and 2026 is the year enforcement started to bite.

Three checks to work out if you are in scope

None of these need a lawyer. Give it an afternoon.

1. Can an EU customer actually complete a purchase?

Not "do we have EU customers" as a vague feeling. Check properly:

• Does your checkout accept EU delivery addresses?
• Does it accept EU billing addresses and cards?
• Do you list prices in euros, or ship to EU countries?

If you have an app, open your App Store and Google Play listings and check country availability. If EU storefronts are switched on, you are offering into the EU market, whether or not anyone has downloaded it yet.

If EU residents can transact with you, location is not your defence.

2. Are you above the microenterprise threshold?

The EAA exempts microenterprises from the service provisions. A microenterprise means fewer than 10 people and annual turnover or balance sheet total not exceeding €2 million.

Read that carefully, because it trips people up: you need to be under both to be exempt. Nine staff and €4m turnover is not a microenterprise. Twelve staff and €500k turnover is not a microenterprise either.

If you are over on either count, the exemption does not apply to you.

3. Do you sell a covered service?

The EAA covers specific categories, and ecommerce is squarely one of them. The most commonly relevant:

• Ecommerce websites and mobile shopping
• Consumer banking services
• E-books and dedicated reading software
• Transport services (passenger information, ticketing)
• Electronic communications services
• Access to audiovisual media services

If you run an online shop selling to consumers, you are in a covered category.

What the law actually requires

The EAA does not spell out design rules itself. It points to a harmonised standard, EN 301 549, which for web content aligns with WCAG 2.2 Level AA.

In practice that means your site needs to work for people who:

• Cannot see it, and use a screen reader instead
• Cannot use a mouse, and navigate by keyboard alone
• Cannot easily distinguish low-contrast text
• Need to zoom in significantly, or increase text spacing
• Cannot hear audio content without captions

Enforcement so far has concentrated on transaction paths: checkout, login, account management. That is also where the serious failures tend to live, and where an inaccessible site stops being a usability complaint and starts being a customer who cannot buy from you.

What enforcement has actually looked like

This is the part worth paying attention to, because it moved fast in 2026.

• November 2025: the first EAA lawsuits were filed in France, brought by disability rights organisations.
• 4 June 2026: the Tribunal judiciaire de Caen ordered Carrefour France to bring its website and mobile app to full accessibility within six months, with a €500 per day penalty if it misses the deadline.
• Germany: a retailer was fined €150,000 over checkout alt-text failures.
• May 2026: a near-identical case against Auchan was dismissed in Lille on a domestic threshold reading, and is now on appeal.
• 22 September 2026: an E.Leclerc hearing is listed in Créteil.
• The Dutch ACM has been actively enforcing against ecommerce and electronic communications businesses.

Maximum penalties vary a lot by member state, from around €60,000 in Ireland to roughly €900,000 in Sweden. These are statutory ceilings, not automatic fines.

Two honest observations about this, rather than scare tactics:

First, fines are rarely the opening move. Authorities typically start with a complaint, a notification, an investigation, and a corrective-action deadline. The pattern emerging from the French cases is court orders to fix by a deadline, not surprise penalties.

Second, enforcement against smaller businesses is still light. Legal commentators have noted that early EAA activity has focused on large platforms and major retailers, and that a lack of enforcement against smaller businesses is a real frustration for consumers and campaigners. If someone tells you an SME crackdown is imminent, treat that as a sales pitch rather than a fact.

What that means practically: the risk to a mid-sized UK ecommerce business today is less "we will be fined next month" and more "we have no evidence of compliance if a complaint, a court order, or an enterprise customer's procurement team asks."

Your UK obligations did not go anywhere either

Worth remembering that the EAA is not the only thing in play. The Equality Act 2010 already applies to private sector service providers in the UK, and has done for years. It requires reasonable adjustments so disabled people are not put at a substantial disadvantage.

So a UK business with no EU customers at all is still not exempt from accessibility obligations. It is just exempt from this particular one.

Why "we installed an accessibility widget" is not an answer

If you have added an overlay or accessibility widget to your site, that is worth knowing about.

In April 2025 the US Federal Trade Commission issued a final order requiring accessiBe to pay $1 million, and barred the company from claiming its automated product can make any website WCAG-compliant.

Separately, analysis by UsableNet found that of US digital accessibility lawsuits filed in 2024, roughly a quarter, 1,023 cases, specifically named overlay widgets as barriers rather than solutions.

The reason is structural, not a matter of one bad vendor. Overlays sit on top of your site and try to patch it in the browser. They do not fix the underlying code, and they cannot make judgements about whether a screen reader announcement actually makes sense to a human being.

Why an automated scan is a starting point, not a compliance result

You can scan your own site for free in about twenty seconds, and you should. It will find real problems worth fixing.

But be clear about what it can and cannot tell you. Testing by the UK Government Digital Service put 13 automated accessibility checkers against a single page containing 142 known barriers. The best tool caught 40%. WAVE caught 30%. axe caught 29%.

So even the best automated tooling detects roughly a third of known issues. The rest, whether your checkout can actually be completed with a screen reader, whether keyboard focus gets trapped in your cookie banner, whether your error messages are announced at all, requires a person testing manually.

That gap is not a marketing angle. It is why an automated pass does not equal compliance, and why an accessibility statement claiming conformance on the basis of a scan is a risk in itself.

What to do this quarter

1. Answer the scope question properly. Check whether EU residents can complete a transaction with you. A surprising number of UK businesses have never actually asked.
2. Run an automated scan to find the obvious problems. Free, fast, and it gives you a baseline.
3. Manually test your transaction paths with a keyboard and a screen reader. Checkout, login, account management. This is where enforcement concentrates.
4. Fix the design system, not individual pages. One accessible component library resolves issues at scale and stops them coming back every time someone publishes a new product page.
5. Keep evidence. The businesses coming through these cases best are the ones who could show work already done when the question arrived. Sites change weekly. "We ran an audit last year" is a weak position if updates have introduced new barriers since.

Check your site now

You can run a free automated accessibility scan of your site in about twenty seconds. It will not tell you whether you are compliant, and we will say so plainly in the results, but it will show you what is already visible to a machine, and it is the sensible first step.

Run a free scan

If you would rather skip straight to a human review of your checkout and login flows, get in touch.