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EAAaccessibility-statementEN 301 549

Is my website compliant with the European Accessibility Act?

A plain-language guide to checking whether your site meets the EAA: who is in scope, what the law actually requires, and how to verify it.

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Pavel Charkasau

Short answer: your website is likely covered by the European Accessibility Act (EAA) if you sell products or services to consumers in the EU and you are not a microenterprise providing a service. To meet the law, your site needs to satisfy the accessibility requirements set out in the EAA and the technical standard it points to, EN 301 549, which currently incorporates WCAG 2.1 Level AA. You also need to tell users how your service meets those requirements. So the honest version of "is my website EAA compliant" is two questions: does the law apply to you, and does your site actually meet WCAG 2.1 AA in practice for real people using assistive technology? An automated scan answers part of the second question fast. The rest needs human judgement. No tool can confirm conformance on its own, and any vendor that promises otherwise is making a claim regulators have already pushed back on.

Below is how to work through both questions without guesswork.

Does the European Accessibility Act apply to my website?

The EAA is Directive (EU) 2019/882. Member states have applied it since 28 June 2025, so it is a live law, not a future one (European Commission).

It covers a defined list of consumer-facing products and services. On the web, the services most often in scope are:

  • E-commerce (selling products or services online to consumers)
  • Consumer banking and many financial services
  • E-books and dedicated reading software
  • Electronic communications services
  • Passenger transport websites and apps (tickets, timetables, real-time information)
  • Access to audiovisual media services

Two points catch people out. First, the EAA reaches non-EU companies too: if you sell into the EU market, location does not exempt you. Second, there is a microenterprise carve-out, but only for services. A business that provides a service and has fewer than 10 people and an annual turnover or balance sheet total of €2 million or less is outside the service obligations of the directive (Directive (EU) 2019/882, Article 4 and Recital 70). Both conditions have to be true. Miss either threshold and the exemption does not apply.

If you run a shop, a bank, a booking site, or an e-book store aimed at EU consumers and you are above that microenterprise line, assume you are in scope and read on. Our EAA overview breaks the scope down by sector if you need detail for your specific case.

What does "EAA compliant" actually mean for a website?

The EAA states the goal: the service has to be perceivable, operable, understandable, and robust for people with disabilities. It does not list the technical checks itself. For that, it relies on the harmonised standard EN 301 549. Meeting the relevant parts of EN 301 549 gives you a "presumption of conformity" with the EAA's requirements (European Commission, standardisation request M/587).

Here is the part that matters for a practical answer. The current legal version, EN 301 549 v3.2.1, incorporates WCAG 2.1 Level AA for web content (Chapter 9). So in practice, "is my website EAA compliant" comes down to: does it meet WCAG 2.1 AA, plus the extra EN 301 549 clauses that apply to your service?

A newer version, v4.1.1, updates the reference to WCAG 2.2 and is expected in 2026. Until it is formally cited in the Official Journal, WCAG 2.1 AA stays the legal bar. The sensible move is to target 2.1 AA now and keep an eye on the 2.2 criteria (such as focus appearance and target size) so the eventual switch is small. Our EN 301 549 page tracks how the standard maps to WCAG version by version.

How do I check if my website meets the requirements?

Work in two layers, because no single layer covers everything.

Layer one, automated testing. Run your pages through a scanner built on a real rules engine. This catches the high-frequency, machine-detectable problems quickly: missing alt text, low colour contrast, form fields without labels, missing page language, duplicate IDs, and basic ARIA mistakes. These also happen to be among the most common defects on the web, so automation clears a lot of ground in minutes.

Layer two, manual review. A person checks the things a machine cannot judge: can you complete a checkout using only the keyboard, does the focus order make sense, is the alt text meaningful rather than image123, does a screen reader announce the page in a usable way, do error messages help. None of that has a reliable automated test.

How much does each layer cover? Deque's analysis of more than 2,000 audits across roughly 300,000 issues found its automated testing identified about 57% of issues by volume; more conservative estimates that count the share of WCAG success criteria put automation closer to 30% (Deque, 2021). Either way, a large share of conformance only shows up under human review. That is not a knock on automation. It is the reason to use both layers and to be honest about the gap.

A reasonable order of operations: scan first to find and fix the obvious defects, then run a structured manual pass against the WCAG criteria you could not test automatically. Our WCAG checklist tool gives you that manual list so nothing falls through.

Do I need an accessibility statement under the EAA?

Yes, if your service is in scope. The EAA requires service providers to explain, in the information accompanying the service, how the service meets the accessibility requirements (set out in the directive's Annex V). EN 301 549 Annex C provides a structured way to document conformance clause by clause, recording each applicable requirement as met, partially met, or not met.

This is where EAA conformance differs from a plain WCAG audit. WCAG is a technical standard and does not, by itself, require any document. The EAA does. A good statement is honest: it records your conformance level, lists known limitations, gives a plan and a timeline for fixing them, and offers a contact for feedback. Stating documented effort is what the law asks for, not a perfect score. You can draft one with our accessibility statement generator, and the accessibility statement guide explains what each section should contain.

Can a scanner or an overlay make my site compliant?

No, and it is worth being blunt about why, because the market is full of the opposite claim.

Accessibility lives in your source code: the HTML elements, attributes, and structure that assistive technology reads. An overlay is a script you paste in that tries to patch the page in the browser after the fact. It cannot fix the underlying code, and it struggles with the things that matter most: menus, headings, tables, forms, embedded media, and documents.

The claim that a tool can do this on its own has a clear cost. In April 2025 the US Federal Trade Commission approved a final order requiring the overlay vendor accessiBe to pay $1 million over claims that its AI product could make any website WCAG compliant; the order bars the company from saying its automated product can make a site WCAG compliant unless it has evidence to back it up (FTC, April 2025).

The takeaway is not "avoid tools." It is "use tools for what they are good at." A scanner finds issues and points you at the code to fix. It documents your progress over time. It does not, and should not claim to, deliver conformance by itself. Full conformance needs human review and real fixes in the code.

A practical way to check your site against the EAA

  1. Confirm scope. Are you selling to EU consumers, and are you above the microenterprise threshold? If yes, you are in.
  2. Set the target. WCAG 2.1 AA, plus any EN 301 549 clauses specific to your service.
  3. Scan. Run your key pages and templates to clear the machine-detectable defects.
  4. Review by hand. Test keyboard flows, focus order, alt-text quality, and screen-reader output against a WCAG checklist.
  5. Fix in the code, then re-scan to confirm the change held.
  6. Document. Publish an accessibility statement that records your level, your known gaps, and your plan.
  7. Keep going. Re-test on a schedule. Conformance is a state your site drifts out of every time you ship new code, so treat it as ongoing rather than a one-time project.

Frequently asked questions

Is my website automatically EAA compliant if it passes an automated scan?

No. A clean automated scan is a good sign, but automation detects only part of what the standard requires. The rest, such as keyboard operability and meaningful alt text, needs manual review before you can claim conformance.

Does the EAA apply to websites outside the EU?

Yes. If you offer covered products or services to consumers in the EU, the directive applies regardless of where your company is based.

Which WCAG version does the EAA require?

The current standard, EN 301 549 v3.2.1, incorporates WCAG 2.1 Level AA. A v4.1.1 update referencing WCAG 2.2 is expected in 2026, but until it is formally cited, 2.1 AA is the legal bar.

Do small businesses have to comply with the EAA?

Microenterprises that provide a service and have fewer than 10 employees and turnover or a balance sheet of €2 million or less are exempt from the service requirements. Both conditions must be met. Larger businesses, and microenterprises that make products, are not exempt.

Is an accessibility statement mandatory under the EAA?

For in-scope services, yes. Providers must explain how the service meets the accessibility requirements. EN 301 549 Annex C gives a clause-by-clause format for documenting it.

Check where your site stands

The fastest way to turn "is my website EAA compliant?" from a worry into a plan is to see your actual issues. Run a free scan to find the machine-detectable problems on your pages, then work through the manual checklist for the rest. You will know what to fix, in what order, and what to put in your statement.

Pavel Charkasau, founder, wcagc.com. Last updated 19 June 2026.

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