Website accessibility: EAA, WCAG 2.1 and what the law requires (2026)
Does your webshop or website need to be legally accessible? This article explains who the EAA applies to, what WCAG 2.1 AA entails and which five changes make the most difference.
- The European Accessibility Act (EAA, EU Directive 2019/882) applies from 28 June 2025 to new B2C services — including webshops, banking apps and travel booking. Existing services have until 28 June 2030. The required standard is WCAG 2.1 level AA. Enforcement in the Netherlands is by the Authority for Consumers and Markets (ACM).
- Micro-enterprises are fully exempt: fewer than 10 employees and less than €2 million annual turnover (art. 4(5) EAA). If your business has 10 or more employees or higher turnover, the EAA does apply to your B2C webshop or app.
- WCAG 2.1 level AA contains 50 success criteria across four principles: Perceivable, Operable, Understandable and Robust (POUR). The five most impactful quick wins are: alt text for images, colour contrast 4.5:1, keyboard navigation, form labels and a logical heading structure.
Does the European Accessibility Act (EAA) apply to my SME website?
The European Accessibility Act (EAA, EU Directive 2019/882) has been in force since 28 June 2025 for new digital services to consumers in the EU. Webshops, banking apps, travel booking services, e-book platforms and audiovisual media services are in scope if they are B2C. Government websites were already covered by the Dutch Government Digital Access Act (WTOA) and WCAG 2.1. For SMEs the crucial question is whether the micro-enterprise exemption applies: businesses with fewer than 10 employees and less than €2 million turnover are fully exempt from the EAA. Other SMEs with a B2C webshop or app must comply with WCAG 2.1 level AA. Existing services available before 28 June 2025 have until 28 June 2030 to conform.
Who must comply with the EAA? Scope and micro-enterprise exemption
The EAA (Directive 2019/882) targets providers of digital products and services to consumers (B2C). B2B services fall outside the scope. The micro-enterprise exemption fully exempts small businesses.
Which services are in scope of the EAA?
The EAA applies to: e-commerce services to consumers (B2C webshops, online marketplaces), consumer electronic banking services, passenger travel booking services, providers of e-books and e-reader software, audiovisual media services (streaming, VOD) and consumer telephone services. B2B services, government websites (already covered by the WTOA), intranets and pure content websites without transaction functionality fall outside the EAA scope. If your SME website also has a webshop, that webshop functionality is in scope even if the rest of the site is B2B.
Micro-enterprise exemption (art. 4(5) EAA): who is exempt?
Micro-enterprises are fully exempt from the EAA: businesses with fewer than 10 full-time equivalents (FTE) and an annual turnover or balance sheet total below €2 million (art. 4(5) Directive 2019/882, as defined in Recommendation 2003/361/EC). Both conditions must apply simultaneously. If your business has 10 or more employees or turnover above €2 million, your B2C webshop is covered by the EAA. The exemption applies only to EAA obligations; other consumer law (GDPR, Unfair Commercial Practices Directive) continues to apply.
Timeline: when must my webshop comply?
New B2C services launched after 28 June 2025 must comply with WCAG 2.1 level AA immediately. Existing services already available before 28 June 2025 have a transitional period until 28 June 2030 to conform. Self-service terminals (ATMs, kiosks) that were already in use before 28 June 2025 may continue in use until the end of their economic life or up to 20 years from the date of entry into service (art. 32(5) Directive 2019/882). Enforcement in the Netherlands is handled by the Authority for Consumers and Markets (ACM); fines depend on the severity and duration of the violation. Consult acm.nl for current enforcement guidelines.
The four WCAG principles: what the standard requires in practice
WCAG 2.1 (Web Content Accessibility Guidelines, version 2.1) is the international technical standard for digital accessibility, published by W3C. Level AA is the legally required standard under the EAA and contains 50 success criteria.
Perceivable: content visible and audible for everyone
Perceivable means all information and interface elements are presented in ways users can perceive — including blind users, those with low vision and deaf users. Level AA success criteria: text alternatives for all non-text content (alt text for images, transcripts for audio), captions for video audio, colour contrast minimum 4.5:1 for regular text and 3:1 for large text and UI components, information not conveyed by colour alone, text resizable to 200% without loss of function, and no horizontal scrolling at 320 CSS pixels wide (mobile).
Operable: full keyboard navigation and sufficient time
Operable means all functionality is available via keyboard — without requiring a mouse or touchscreen. Essential for users with motor impairments. Level AA criteria: all functions reachable via Tab/Enter/arrow keys, skip-to-content links present for quick navigation, focus indicators always visible (never remove outline from focusable elements via CSS), and sufficient time limits when completing forms. Quick test: load your website, put away the mouse and navigate using only Tab and Enter — can you reach all features?
Understandable: readable and predictable behaviour
Understandable sets requirements for text readability, predictable behaviour of page elements and assistance with input errors. Level AA: page language correctly set via the lang attribute (e.g. lang="en"), pages consistent in navigation and naming, forms identify input errors and provide correction suggestions, and every form field has a visible label linked via the for attribute — not just placeholder text. In WordPress: check Settings > General for the lang setting and use a forms plugin with correct label linking (Gravity Forms, WPForms).
Robust: works with screen readers and other assistive technology
Robust means content is interpretable by screen readers (NVDA, JAWS, VoiceOver) and other assistive technologies, now and in the future. Level AA: valid HTML without duplicate id attributes or incorrectly closed tags, ARIA landmarks correctly applied (role="navigation", role="main", role="complementary"), and status messages communicated to screen readers via aria-live regions without a focus change. Use the WAVE browser extension (wave.webaim.org, free) or Axe DevTools (Chrome extension, free basic version) to detect ARIA errors and HTML validation issues.
Five changes that address the most common accessibility problems for SMEs
For SME websites, five changes address the most common WCAG violations. Start here for the greatest impact.
1. Alt text for images: required and straightforward to add
Alt text is the text screen readers read aloud instead of an image, and displayed when the image fails to load. WCAG 2.1 success criterion 1.1.1 requires all informative images to have descriptive alt text. Decorative images get alt="" (empty attribute). In WordPress: add alt text via Media > Library or directly when inserting an image in the block editor. Do not forget WooCommerce product images — these are also used by Google for Google Lens and Image Search.
2. Colour contrast 4.5:1: good for everyone, required for many
WCAG 2.1 level AA requires a contrast ratio of at least 4.5:1 between text and background (success criterion 1.4.3). Large text (18pt or 14pt bold) may use 3:1. Test for free via the WebAIM Contrast Checker (webaim.org/resources/contrastchecker). Grey text on white (#999999 on #ffffff) has ratio 2.85:1 — too low. Switch to #767676 on #ffffff (ratio 4.54:1). Check buttons, form labels, footer text and links separately — these are regularly overlooked.
3. Form labels: every input field visibly and programmatically labelled
Every form field (text, email, phone, dropdown, checkbox) must have a visible label that is programmatically linked to the field via <label for="..."> or aria-label. Placeholder text alone is not sufficient: it disappears when the user starts typing and is not read by all screen readers. In WordPress: check whether your forms plugin (Gravity Forms, WPForms, Contact Form 7) generates correct label links by inspecting the HTML — the for attribute of the label must match the id attribute of the input field.
4. Keyboard navigation: Tab, Enter and arrow keys as a full alternative
All interactive elements — links, buttons, form fields, dropdown menus, modals — must be reachable and operable via keyboard without a mouse. Test manually: load your website, put down your mouse and navigate via Tab and Shift+Tab. Every focused element must be visible — never remove outline from focusable elements via outline:none in CSS. Add a visible focus style: :focus-visible { outline: 2px solid #005fcc; outline-offset: 2px; }. Missing focus indicators are the most common WCAG violation on SME websites.
5. Logical heading structure: one H1, then H2 and H3 in order
A logical heading hierarchy helps screen reader users understand the page and navigate between sections. WCAG 2.1 success criteria 1.3.1 and 2.4.6 require descriptive, sequentially numbered headings. Every page has exactly one <h1> describing the page title. Subsections use <h2>, sub-subsections <h3> — do not skip levels (e.g. never go directly from h1 to h3). In WordPress: check via the block editor > Structure whether headings are correctly nested. Do not use bold paragraphs as visual headings — make them actual heading elements.
Website accessibility: frequently asked questions
Does the EAA apply to my WordPress webshop?
What is the difference between WCAG 2.1 and WCAG 2.2?
How do I test my website's accessibility for free?
What is the fine for not complying with the EAA?
Do I need to publish an accessibility statement as an SME?
Does the EAA also apply to my B2B website or intranet?
Building WCAG-compliant from the start? That is how we work.
A new website built on Next.js is inherently more accessible than an optimised WordPress theme — semantic HTML, keyboard navigation and focus management are built into the architecture.
Book my free call →Free consultation · response within 1 business day · no cure, no pay