European Accessibility Act: UK duties, EU fines and deadlines (with a test of 15 pages)

The European Accessibility Act is Directive (EU) 2019/882: since 28 June 2025 it requires businesses that offer consumers in the EU e-commerce, consumer banking, passenger transport, electronic communications, access to audiovisual media and e-books to make those services usable with a screen reader, a keyboard alone or text magnification. It is not UK law, but it applies to UK businesses selling to EU consumers, and penalties are set by each member state: in Italy, for example, from 5,000 to 40,000 euros under Article 24 of Legislative Decree 82/2022.

Web accessibility, more broadly, is the quality that keeps a website or digital service usable by people who browse with assistive technology or without a mouse and screen: screen readers, keyboard only, text magnification, voice control, braille displays. The EAA turns it into a legal duty for part of the private sector.

The trouble is that hardly anyone can say precisely what is at stake.

We read the pages that currently rank on Google Italy for "european accessibility act" and "accessibilità web". The fines quoted range from 5,000 to 40,000 euros, "up to 40,000", "up to 50,000", "up to 5% of turnover". Not one of them names the article of law the figure comes from.

The three mistakes we see most often:

• mixing up different laws: the Equality Act, the public sector regulations and the EAA cover different organisations;
• believing a widget is enough, installed in five minutes;
• looking only at the website, when the duty also covers the PDF invoice, the order confirmation, the e-ticket.

Two of the projects we work on are online shops. Bosatta sells parts for Vespa and Piaggio vehicles in four countries, Italy, Spain, France and Germany, and generated 240,000 euros of online sales in a year. Scovaventi has a store rebuilt on Shopify that brought in 77,000 euros in a year, with an average order of 190 euros.

What does a directive on accessibility have to do with them?

E-commerce is first on the list. And for a business selling in several countries the duty multiplies: if a service does not comply, the provider must inform the authorities of every member state where it offers the service (Article 12 of the Italian decree, transposing the directive). Four markets, four authorities. A UK shop selling across the EU is in the same position.

In this guide:

• which UK duties apply and where the EAA fits, with the exact microenterprise definition;
• what non-compliance costs, article by article, using Italy as a worked example;
• the deadlines that run to 2030 and beyond;
• a Lighthouse test of 15 pages that explain accessibility, and don't always practise it;
• what to check by hand, because tools only see part of the problem.

Let's start.

Three obligations for a UK business (and only the EAA crosses the Channel)

The first is the Equality Act 2010 (the Disability Discrimination Act 1995 in Northern Ireland). It is not a website law and sets no technical standard, but it applies to every service provider regardless of size: as the government guidance puts it, "all UK service providers have a legal obligation to make reasonable adjustments". For a business that sells or takes bookings online, the website is part of the service.

The second is the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018, in force since 23 September 2018. It covers public sector bodies only: meet WCAG 2.2 at level AA, publish an accessibility statement and review it regularly. Enforcement is by the Equality and Human Rights Commission in Great Britain and the Equality Commission for Northern Ireland.

The third is the European Accessibility Act, Directive (EU) 2019/882. What counts is where the consumer is, not where the company is based: a UK business selling online to consumers in the EU is in scope. The test is the sector, not turnover, and it applies to consumer services placed on the market from 28 June 2025.

Microenterprises providing services are exempt, but the definition has two parts: fewer than 10 people employed and annual turnover or balance sheet total not above 2 million euros. A shop with 6 employees and 3 million euros of turnover is in scope.

Reference	Who it covers	Since	Requirement	Enforcement
Equality Act 2010 (DDA 1995 in Northern Ireland)	All service providers, any size	In force	Reasonable adjustments; no set technical standard	EHRC, ECNI and individual claims
Public Sector Bodies Accessibility Regulations 2018	Public sector websites and apps	23 September 2018	WCAG 2.2 AA and an accessibility statement	EHRC and ECNI
European Accessibility Act (Directive 2019/882)	Consumer e-commerce, banking, passenger transport, electronic communications, access to audiovisual media, e-books, when offered in the EU	28 June 2025	Accessibility requirements plus information on how the service meets them	National authorities in each EU country where the service is offered (AgID in Italy)
Microenterprises	Fewer than 10 people and turnover or balance sheet not above 2 million euros (both conditions)	n/a	Exempt from the EAA service requirements, not from the Equality Act	n/a

What non-compliance costs: Italy as a worked example (from 2,500 to 40,000 euros, 5% of turnover for the largest)

Each member state sets its own penalties, so there is no single EU fine. We checked the Italian rules on the primary text, because that is where we work and where Bosatta and Scovaventi sell. The main penalty is in Article 24, paragraph 1, of Legislative Decree 82/2022: from 5,000 to 40,000 euros for an economic operator breaching the accessibility duties, "taking into account the extent of the non-conformity".

Breach (Italy)	Provision	Penalty
Service not meeting the requirements or the provider's obligations	Art. 24(1), Legislative Decree 82/2022	5,000 to 40,000 euros
Failure to comply with the supervisory authority's orders	Art. 24(2)	2,500 to 30,000 euros
Failure to cooperate with the authority	Art. 24(3)	2,500 to 30,000 euros
Breaches by organisations with average turnover above 500 million euros	Art. 9(1-bis), Law 4/2004, referred to by Art. 24	Up to 5% of turnover

Sources: Legislative Decree 82/2022 and Law 4/2004 on Normattiva, AgID regulation on enforcement, consulted on 28 October 2026. Figures for other member states vary and we haven't verified them on primary sources, so we don't list them.

So a fine just lands?

No. The AgID regulation on enforcement sets out a process: a user complaint on AgID's platform, a check, then a report served on the provider with a "reasonable and proportionate" deadline to fix things. Only then does the procedure start: 30 days to submit a defence, 90 days to close it, then a formal notice with a final deadline.

And the fine is not what hurts most. For service providers AgID can order the service to be taken offline or the app withdrawn from the store. For an online shop that means zero orders while the order stands. With Bosatta's public figures, 240,000 euros a year, each month offline is worth 20,000 euros of sales on average, half the maximum fine.

Deadlines after 2025 (contracts to 2030, terminals up to twenty years)

28 June 2025 is not the only date. The directive's transitional measures, transposed in Italy by Article 25 of the decree, set two.

• Until 28 June 2030 providers may keep delivering services with the products they already used; service contracts agreed before 28 June 2025 can run until they expire, but for no more than five years.
• Self-service terminals already in use before 28 June 2025 can stay in service until the end of their economic life, but for no more than twenty years from when they were put into use.

So an old website can wait until 2030?

No. The transition covers the products used to deliver the service and contracts already signed. Reading it as a general deferral to 2030 means relying on an exception written for something else.

The other way out is disproportionate burden (Article 13 of the Italian decree). A business can skip a requirement if meeting it would impose a disproportionate cost, assessed against criteria set out in an annex. But the assessment must be documented and kept for at least five years, renewed at least every five years or when the service changes, and anyone who is not a microenterprise must notify the supervisory authority.

It is not an exemption you claim out loud. It is a file.

What the technical standard asks (WCAG 2.2 and EN 301 549, updated in September 2026)

The technical standard is the W3C's Web Content Accessibility Guidelines. The current version is WCAG 2.2, a W3C Recommendation since 5 October 2023 and updated on 12 December 2024: 13 guidelines, 9 success criteria new compared with 2.1, and three conformance levels, A, AA and AAA. The level the UK public sector regulations and the European rules use as the working threshold is AA.

The bridge between the law and WCAG is the harmonised standard EN 301 549 from ETSI, which points to WCAG for web content and adds requirements for documents, software and hardware. ETSI published version 4.1.1 on 2 September 2026. If you are scoping a project now, start from that, not from guides written in 2024.

The four WCAG principles translate into things that live in the markup. Perceivable: alternative text on images, captions on videos, sufficient contrast. Operable: everything reachable by keyboard, no focus traps, no imposed time limits. Understandable: declared language, clear labels on forms, predictable behaviour. Robust: semantic HTML and ARIA attributes used correctly, so that assistive technology can interpret the page without guessing.

Three of the four principles run through elements anyone working on the site already knows: alt text, the hierarchy of heading tags, breadcrumbs.

We tested 15 pages that explain accessibility (8 score below 100)

On 28 October 2026 we ran Lighthouse (version 13.4.0, via DataForSEO, desktop profile) on the first-page results on Google Italy, on mobile, for "european accessibility act" and "accessibilità web". We left out a PDF, a Udemy course and one page that did not respond: 15 pages remain. These are Italian results pages, so read the sample as such.

They are pages that tell other people how to make a site accessible. Many belong to companies that sell accessibility services.

Page	Query (Google Italy)	Accessibility score	Agentic Browsing score
eye-able.com (EAA page, URL 1)	european accessibility act	100	67
eye-able.com (EAA page, URL 2)	european accessibility act	100	67
digital-regulation.taylorwessing.com	european accessibility act	100	100
qualibooth.com	european accessibility act	100	100
deque.com	european accessibility act	100	66
inclusyon.it	european accessibility act	95	59
tech4access.com	european accessibility act	88	33
didanet.org	european accessibility act	88	33
accessibit.com	accessibilità web	100	100
accessiway.com	accessibilità web	100	100
m2sistemi.it	accessibilità web	97	67
sitiaccessibili.it	accessibilità web	94	33
one.com	accessibilità web	93	100
bludata.com	accessibilità web	91	63
ecommercelegale.it	accessibilità web	82	50

Visilay test, 28 October 2026: Lighthouse 13.4.0 via DataForSEO, desktop, one run per URL. The score only measures automatically detectable errors.

The numbers, in order:

• 7 pages out of 15 score 100, the other 8 fall short;
• the lowest score is 82, the average is 95;
• one page loads an accessibility overlay (accessiBe, according to Lighthouse's list of resources) and still scores 95: the widget did not remove the errors Lighthouse finds in the code.

The Italian version of this page, run through the same test, scores 100.

So it conforms?

That number can't tell you, and it can't tell anyone. Lighthouse doesn't test the keyboard, doesn't follow focus, doesn't open a screen reader. A 100 only says the automated checks found no errors.

Six errors make up 96% of the problem (WebAIM data on a million home pages)

The largest survey available is The WebAIM Million, which in February 2026 analysed the markup of one million home pages. It is an international sample and should be read as such. 95.9% of home pages had automatically detectable WCAG errors, worse than 94.8% in 2025. The average is 56.1 errors per page, 10.1% more than the year before.

Error detected	Home pages affected
Low contrast text	83.9%
Missing alternative text on images	53.1%
Missing form input labels	51.0%
Empty links	46.3%
Empty buttons	30.6%
Missing document language	13.5%

96% of all errors detected fall into these six categories, the same ones for seven years according to WebAIM. None needs a redesign: they are fixes to the code and the colour palette, and on a medium-sized site they are closed in a few days of work. It is the part to tackle before any discussion of formal conformance.

How to test it (and what Lighthouse doesn't see)

Lighthouse accessibility audits are based on Deque's axe-core. The Chrome documentation explains how the score works: it is a weighted average of pass/fail audits, with no partial scores, and manual audits are not included in the calculation.

What the tools don't see has to be tested by hand, and it takes less time than it seems:

• go through a whole page with the Tab key alone, checking that focus is always visible and the order makes sense;
• zoom to 200% and see whether the content reflows;
• fill in the contact form or the checkout with a screen reader running.

In the WebAIM survey of 1,539 screen reader users (December 2023 to January 2024) the most common primary screen readers were JAWS at 40.5%, NVDA at 37.7% and VoiceOver at 9.7%. Take these proportions as a guide to which software is worth installing for testing, not as a picture of UK users.

Overlay widgets deserve a note, because they are sold as a way to comply. They sit on top of the page and don't touch the markup: the errors in the table above stay where they are, and so does any breach. In our test, the page with an overlay running did not reach 100.

The obligation is on the service, not the site (PDFs and emails included)

The European Accessibility Act does not regulate websites, it regulates services. An accessible checkout that emails a scanned PDF invoice at the end of the order leaves the service non-compliant, because the part the consumer has to read can't be read. The same goes for e-tickets, booking confirmations and bank statements. On handling files, see our guide to PDF SEO.

The Italian decree's Article 12, transposing the directive, adds two duties few people mention:

• information on the service's accessibility must be made available to the public in written and oral form and kept for as long as the service runs;
• if the service does not comply, the provider must immediately inform the authorities of the countries where it offers it, stating which requirements are not met and what it has done.

A conformance claim made once and then left alone, on a site that changes every week, is the most common case. It is also the most exposed.

Where accessibility, SEO and AI answers meet (Lighthouse now scores agents too)

Accessibility is not a ranking factor, and anyone selling it as a shortcut to rankings is selling something else. The overlap is that the work lands on the same things: heading structure, alternative text, semantic markup, navigability. They are the elements technical SEO works on, and markup that a screen reader interprets without guessing is also markup a crawler interprets without guessing: it is worth rereading how search engines work with this in mind. The Core Web Vitals thresholds also reward choices that make a page usable on a slow connection or an old device, and all of it sits within user experience.

Then there is something new. Lighthouse 13 has added a category called Agentic Browsing, which checks whether an AI agent can navigate the page; Lighthouse itself describes it as still under development. In our sample only 5 pages out of 15 score 100, and three stop at 33. Three pages with 100 for accessibility fall below 70 here: the two scores don't move together.

For ChatGPT and Google's AI Overviews the point is simpler. These systems work with passages of text: a page with semantic HTML, headings in order, real HTML tables and text instead of images is easier to read and extract. It doesn't guarantee a citation, but it removes an obstacle. To find out whether your brand actually shows up in the answers you need to measure it, as we explain in our guide to AI visibility and in our GEO service.

What if I'm rebuilding the site?

That is when accessibility costs least, because it goes into the components instead of being bolted on afterwards. Put it in the brief alongside SEO, whoever builds it, web agency or software house; planned from the start, it weighs less on the cost of a website than people expect. The decisions to fix early are the same as for an SEO-friendly website, and if you are changing platform they apply to the migration too. It is how we work in web development.

The recap (and the question few people ask)

In scope: e-commerce, banking, transport, telecoms, audiovisual media and e-books aimed at EU consumers, UK sellers included.

Exempt: microenterprises providing services, if they are under both thresholds.

Penalties: set country by country; in Italy from 5,000 to 40,000 euros, up to 5% of turnover above 500 million, takedown as the extreme measure.

Deadlines: 2030 for existing products and contracts, twenty years at most for terminals.

Testing: Lighthouse for the first pass, keyboard and screen reader for the rest.

The question few people ask is who starts the check. Under the Italian regulation, the complaint comes from a user, on the authority's platform, against a single provider. The first person to test your shop won't be an inspector: it will be a customer who couldn't finish an order. Better to try it yourself first, with the keyboard.

Speak soon!

Frequently asked questions about the European Accessibility Act