Does the European Accessibility Act apply to UK businesses? A practical 2026 guide for websites, e-commerce, and social content

What the European Accessibility Act is (and why UK teams should care)

The European Accessibility Act (EAA) is Directive (EU) 2019/882, designed to harmonise accessibility requirements across the EU for a defined set of consumer-facing products and services, many of them digital.

The key date: EU Member States’ national laws started applying from 28 June 2025. From that point, in-scope products and services placed on the market / provided to consumers must meet accessibility requirements.

If you are UK-based, the crucial point is this:

The EAA is not UK law, but it can still apply to you if you sell in-scope products or services to EU consumers.

The short answer: When does it apply to UK businesses?

It applies to you (even if you’re UK-based) if:

You offer in-scope products or services to consumers in the EU, including via a website or app. This is routinely described as the EAA’s “extra-territorial” practical effect, location is less important than where your customers are and where the service is offered.

It may not apply to you if:

You are UK-only (no EU consumers, no EU targeting, no EU distribution) and you do not place in-scope products/services on the EU market. Even then, accessibility may still be commercially required (procurement, platforms, reputational risk), but you’re not usually in the EAA’s direct firing line.

A simple decision tree you can use today

Ask these in order:

1. Do you sell to EU consumers?

• EU shipping, EU currencies, EU-language pages, EU-focused ads, EU customer support, EU app store listing, EU distribution partners = you’re likely “offering” into the EU.

2. Are your products/services in scope? (Next section.)

3. Are you a microenterprise providing services?

• If you have fewer than 10 employees and turnover or balance sheet ≤ €2m, you may be exempt for service obligations (note: exemptions are not a universal “do nothing” card, and product-side obligations can differ).

If you answered Yes to (1) and (2), you should assume you need an EAA compliance approach (even if you later confirm an exemption).

What is “in scope” under the EAA? (The parts most UK businesses trip over)

The EAA scope is specific, it does not make every website on earth subject to it. It targets categories of products and services that are common in everyday life and commerce.

In-scope services (digital-heavy examples)

The directive covers accessibility requirements for several service categories commonly delivered through websites/apps, including:

• E-commerce services (think: online shops and apps where consumers browse, select, and purchase)

• Consumer banking services

• Electronic communications services

• Access to audio-visual media services (e.g., certain on-demand services)

• Certain passenger transport services where digital interfaces are used (ticketing, information, etc.)

In-scope products (relevant if you manufacture, import, distribute, or white-label)

The EAA also covers accessibility requirements for categories such as certain consumer devices and self-service terminals (e.g., payment terminals, ATMs, ticketing machines, some ICT equipment).

“We just run socials”, how the EAA still becomes your problem

From a compliance standpoint, the highest-risk pattern I see is this:

The social content is accessible, but the journey it drives to is not.

If your Instagram ad, TikTok, LinkedIn post, or influencer campaign links to an inaccessible product page or checkout, the service (e-commerce) may fail accessibility requirements even if the post itself looks “inclusive”.

As a social media manager, treat accessibility as funnel-wide:

• Social post accessibility (captions, alt text, sensory load)

• Landing page accessibility (contrast, structure, keyboard access)

• Product pages (images + alt text, variants, error handling)

• Checkout and payments (forms, labels, timeouts, confirmation)

• Customer support (chat, contact forms, confirmations, PDFs)

If any of those stages are broken, you risk both conversion loss and compliance exposure.

What standard should you aim for? (WCAG vs EN 301 549)

The EAA is a legal framework; the technical “how” is commonly demonstrated using recognised standards.

In practice, organisations often align to EN 301 549 (the European accessibility standard for ICT).
EN 301 549 incorporates WCAG requirements for web content (and also includes requirements beyond WCAG, e.g., for documents and software).

Two practical takeaways:

• If you build to WCAG 2.2 AA, you are usually moving in the right direction (and WCAG 2.2 content also meets WCAG 2.1/2.0).

• Don’t ignore documents: EN 301 549 updates have explicitly highlighted that WCAG applies to documents downloaded from the web, a frequent blind spot for marketing teams sharing PDFs.

Exemptions and “we’re small” realities

Microenterprise exemption (services)

The EAA includes an exemption for microenterprises providing services (fewer than 10 employees and ≤ €2m turnover/balance sheet).

However, in practical governance terms, small organisations should be careful:

• You may still face contractual accessibility requirements from EU partners, marketplaces, or procurement.

• You may still face complaints and reputational fallout (and disabled customers do not become “less real” because your headcount is small).

• You may outgrow microenterprise thresholds, and retrofitting is always more expensive than building access in.

Disproportionate burden / fundamental alteration

The directive allows for limited exceptions where compliance would impose a disproportionate burden or require a fundamental alteration, but the expectation is that you can evidence the assessment rather than simply assert it.

What happens if you ignore it? (Realistic risk framing)

Enforcement and penalties are set by each EU Member State’s implementing law, so consequences vary by country.
But the direction of travel is consistent: regulators can require remediation and can impose fines or restrictions depending on national regimes.

For most UK SMEs, the most immediate risk isn’t “a headline fine tomorrow” it’s:

• Losing EU market access (delays, takedowns, procurement disqualification)

• Customer churn and higher support burden

• Legal escalation after complaints

• Damage to brand trust (especially if you market yourself as inclusive)

The quickest compliance wins (based on what actually fails on websites)

If you need a prioritised list, focus on the issues that repeatedly cause accessibility failures at scale, such as:

• Low colour contrast

• Missing alt text

• Form inputs without labels

• Empty links / buttons

• Missing document language / structure issues

These are also the same issues that hurt conversion and SEO—so the fixes tend to pay twice.

A practical 30-day EAA readiness plan (for UK e-commerce + marketing teams)

Week 1: Scope and ownership

• Confirm whether you serve EU consumers and which journeys are in-scope (site, app, checkout, PDFs, support).

• Assign an internal owner (compliance/product) and a delivery lead (web/dev or agency) Week 2: Audit what matters (not everything)

Week 2: Audit what matters (not everything)

• Run a baseline audit against WCAG 2.2 AA and map to EN 301 549 where relevant.

• Audit your top 10 landing pages, your checkout, and your top 5 PDFs first

Week 3: Fix high-impact issues

• Contrast, headings/structure, alt text, form labels, keyboard navigation, error messages.

Week 4: Social media compliance alignment

• Make sure campaign links go to accessible landing pages.

• Create a lightweight “Accessible Campaign QA” checklist:

  • Captions on all video

  • Alt text where supported

  • No essential info only in imagery

  • Avoid sensory overload (audio spikes, aggressive motion)

  • Clear CTA language + descriptive links (not “click here”)

The bottom line for UK businesses

If you sell into the EU, you should treat the EAA as a commercial reality, not an abstract EU policy. The question is not “is our Instagram accessible?” but “is the entire customer journey accessible where the EU consumer experiences it?”