European Accessibility Act: official texts and scope
Sources checked on 11 October 2026. Informative summary only: the linked official texts prevail. Not legal advice.
Directive (EU) 2019/882 (European Accessibility Act)
- The Directive applies from 28 June 2025 (Art. 31). Service contracts agreed before that date may continue unchanged until they expire, but no longer than five years (Art. 32).
- E-commerce services are “services 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” (Art. 3(30)). Business-to-business-only sales are not covered.
- The information duty (Art. 13(2) and Annex V) requires the provider to explain how the service meets the accessibility requirements, in the general terms and conditions or an equivalent document, made available in written and oral format, including in an accessible way, and kept as long as the service is operated. Annex V lists: (a) a general description of the service in accessible formats; (b) descriptions and explanations needed to understand the operation of the service; (c) how the Annex I requirements are met. Point 3 also asks for information showing that the service delivery process and its monitoring ensure compliance.
- E-commerce requirements (Annex I, Section IV(g)) cover accessibility information on products and services sold when provided by the responsible economic operator; identification, security and payment functions that are perceivable, operable, understandable and robust.
- A provider claiming a disproportionate burden (Art. 14, Annex VI) needs a documented assessment, kept five years, renewed at least every five years; notifying the authority does not apply to microenterprises.
- As of the date above, no harmonised standard under Directive 2019/882 has been published in the Official Journal (Commission list), so there is no presumption of conformity yet. EN 301 549 V3.2.1 (which includes WCAG 2.1 level AA) is the usual reference.
Text: Directive (EU) 2019/882 on EUR-Lex.
Microenterprise exemption (services)
A microenterprise employs fewer than 10 persons and has an annual turnover or an annual balance sheet total not exceeding €2 million (Art. 3(23)). “Microenterprises providing services shall be exempt from complying with the accessibility requirements […] and any obligations relating to the compliance with those requirements” (Art. 4(5)). Member States must provide guidelines and tools for microenterprises (Art. 4(6)). The exemption covers services only, not products.
- France: Code de la consommation, art. L. 412-13, I.
- Germany: BFSG § 2 No. 17 and § 3(3).
National transpositions
- France transposed it through law 2023-171, art. 16 and decree 2023-931 (Code de la consommation art. D. 412-57 and its annex); enforcement is by the DGCCRF, with fines of the 5th class of contraventions (art. R. 451-4). Large companies (average French turnover above €250 million) must also follow article 47 of law 2005-102: RGAA-format statement, multi-year plan, homepage mention.
- In Germany, BFSG § 14 and Annex 3 also require naming the competent market surveillance authority (MLBF); fines reach €100,000 (§ 37).
- Public sector bodies follow Directive (EU) 2016/2102 and the model statement of Implementing Decision (EU) 2018/1523.
Limits of automated testing
Automated tools such as axe-core only check part of the criteria. Neither the mini-test nor the partial automated audit can show that a site conforms. No tool or overlay makes a website accessible by itself.