Short answer: if you sell products or services online to consumers in the EU, the European Accessibility Act (EAA) already applies to you, and enforcement has started. It has applied since 28 June 2025, every member state enforces it through its own authority, and the practical target today is WCAG 2.1 Level AA. Year one has produced court orders, inspections and complaint queues rather than headline fines, which makes now the cheapest moment to fix your site: audit your key journeys, fix the blockers in your components rather than page by page, publish an accessibility statement, and build accessibility checks into every release.
This guide is written for founders, store owners and agencies in the US, UK and Pakistan who serve EU customers and want to know what the law actually asks of a website or app, what enforcement looks like so far, and how to plan the work without paying for it twice.
Why this is in the news now
Three developments pushed accessibility back onto roadmaps this autumn.
- The first court order against a big retailer. On 4 June 2026, a court in Caen ordered Carrefour France to make its website and app fully accessible within six months, with a penalty of €500 per day of delay after that. Carrefour had argued its site was 71% compliant; the court said an e-commerce site cannot be only a little accessible (Accessisight). That six-month window runs out in early December 2026.
- Regulators are opening cases. Sweden's regulator PTS has opened 28 supervision cases against e-commerce services, including IKEA and H&M. Germany's joint market surveillance body had received nearly 700 reports by June 2026, and German law allows fines of up to €100,000 for providing a non-conforming service (ComplyLoft enforcement tracker).
- The standard moved. EN 301 549 v4.1.1, published in September 2026, adopts WCAG 2.2 as the benchmark. It is not yet the legal reference: until the Commission cites it, v3.2.1 and WCAG 2.1 AA still apply (AccessibleEU). In practice, building to WCAG 2.2 now means you will not have to redo the work later.
As of October 2026, no national regulator had published an EAA fine. That is not a reason to wait. Enforcement starts with questions and notices to correct, and the businesses that answer them quickly with an audit, a statement and a plan are in a very different position from those that have nothing to show.
Does the EAA apply to your business?
The Act covers a defined list of products and services. For most of our clients, the relevant ones are e-commerce services, consumer banking, e-books, electronic communications and parts of passenger transport such as booking sites and apps (European Commission). A few points people often get wrong:
- Location of your company does not matter much. A US or Pakistani business selling to EU consumers is in scope for those sales, just as it is for GDPR.
- Very small service providers are exempt. Microenterprises (fewer than 10 staff and annual turnover or balance sheet of no more than €2 million) are exempt for services. If you grow past that line, the exemption ends, so check it yearly.
- B2B-only software is mostly out of scope, but your customers may be in scope and will start asking you for accessibility evidence in procurement. That is often the bigger commercial pressure for SaaS companies.
- Documents count. Regulators and complainants are already flagging inaccessible PDFs, contracts and statements, not just web pages.
This article is practical guidance, not legal advice. If you are unsure whether a product is in scope, a short review with a lawyer in your main EU market is money well spent.
What “accessible” means for a website in practice
WCAG is long, but the failures we see on real client sites cluster into a handful of patterns. Fix these first and most journeys become usable for keyboard and screen-reader users.
1. Keyboard access and visible focus
Every menu, modal, carousel, date picker and checkout step must work with the keyboard alone, in a logical order, with a visible focus outline. Custom dropdowns built from plain divs are the most common blocker, followed by modals that do not trap or return focus.
2. Labels, names and errors on forms
Every input needs a programmatic label, not just placeholder text. Error messages must say what went wrong and how to fix it, and must be announced to screen readers. Checkout, sign-up and contact forms are where accessibility failures turn directly into lost revenue.
3. Colour contrast and text that resizes
Light grey text on white, low-contrast buttons and text baked into images all fail. Pages should still work when zoomed to 200% and on narrow screens without horizontal scrolling.
4. Images, icons and media
Meaningful images need useful alt text; decorative ones should be hidden from assistive technology. Icon-only buttons such as cart, search and close need accessible names. Video needs captions.
5. Structure and semantics
One clear H1, a sensible heading order, landmarks such as header, nav and main, real buttons and links instead of clickable divs, and a correct page language. This is also exactly the structure search engines and AI assistants rely on, which is why accessibility work tends to improve SEO too. We covered the machine-readability side in our guide to making your website ready for AI agents.
A five-step plan that does not waste budget
- Pick the journeys that matter. Home, search or category pages, product or service pages, cart, checkout, sign-up, login, account and contact. Ten to fifteen templates usually cover most of a site.
- Audit with tools and with people. Automated scanners such as axe or Lighthouse catch a useful share of issues quickly, but they cannot judge whether alt text makes sense or whether a checkout is usable with a screen reader. Combine an automated scan with a manual keyboard and screen-reader pass on each journey.
- Fix at the component level. If your site uses a design system or shared components, fixing the button, modal, form field and menu once fixes them everywhere. This is where a rebuild or refactor on a modern stack such as Next.js often pays for itself.
- Publish an accessibility statement. Say what standard you target, what is known not to work yet, how users can report problems and how quickly you respond. Regulators ask for this and it shows good faith.
- Stop regressions. Add automated accessibility tests to your CI pipeline and a short manual checklist to your release process, so new features do not quietly undo the work.
Avoid the “one-line fix” overlay trap
Accessibility overlay widgets promise compliance with a single script tag. They can add useful preferences such as larger text, but they do not fix broken markup, unlabeled forms or keyboard traps in your actual code, and disability advocates widely criticise them. The Carrefour case is a reminder that “mostly accessible” is not a defence. Treat an overlay as optional extra, never as the plan.
What it costs and how long it takes
Cost depends on how the site was built far more than on its size. A site on clean, shared components can often be brought up to WCAG 2.1 AA in a few focused weeks. A site assembled from page builders, plugins and third-party widgets usually needs some components replaced, and sometimes a partial rebuild is cheaper than patching. Most of our accessibility and front-end remediation projects fall inside our usual USD 3k–15k+ range, with larger commerce platforms at the upper end. We scope after a short audit so you pay for real issues, not guesses.
Where Localhost Labs fits
We build and refactor websites, stores and SaaS products with accessibility built into the components from day one. For existing sites we run an audit of your key journeys, fix issues in code, add automated checks to your pipeline and help you write an honest accessibility statement. Agencies can use us as a white-label development partner to deliver accessibility remediation for their own clients, and founders planning a new product can see how we approach SaaS development and budgeting.
If you sell into the EU and are not sure where your site stands, get in touch with our team for a short accessibility review of your most important journeys. You will get a prioritised list of what blocks users today and a realistic estimate to fix it.