European Accessibility Act for US Sellers

The European Accessibility Act doesn't care where your company is incorporated. It cares whether you offer covered products or services to consumers in the EU, so if your store ships to Lyon or your app takes payments in euros, the Act's first anniversary is a good moment to check where you stand.

EU member states have had to apply the Act, Directive (EU) 2019/882, since June 28, 2025. This is a practical guide for US companies: what it covers, who enforces it, how it relates to WCAG, and what to do this quarter. It is not legal advice. Whether the Act applies to your business, and how, is a question for counsel who knows EU law.

Which US businesses the Act reaches

The Act covers a defined list of products and services. On the service side, the obligations attach to services provided to consumers, and the list is what matters most for American companies:

Covered service	What it looks like for a US business	The journey to test first
E-commerce services	An online store that sells and ships to EU consumers, or sells them digital goods	Search, product page, cart, checkout, payment
Consumer banking services	A card issuer, lender, or fintech app serving EU consumers	Sign-up, identity checks, payments, statements
E-books and dedicated software	A publisher selling e-books to EU readers, and the reading app	Purchase, download, reading with a screen reader
Electronic communications services	Calling or messaging services offered to EU consumers	Account setup, contacting someone, support
Access to audiovisual media services	A streaming service's website and apps	Browsing, playback, caption and audio description settings
Passenger transport services	Air, bus, rail, or ferry booking sites, apps, e-tickets, and travel updates	Search, booking, ticket delivery, changes

On the product side, the Act covers items such as consumer computers and their operating systems, smartphones, e-readers, and self-service terminals like ATMs, ticket machines, and check-in kiosks. US manufacturers selling those in the EU face product obligations, including technical documentation and CE marking.

The practical test for most US sellers is simple: do you sell to people in the EU who are buying for themselves? Signals that you're targeting them include EU shipping, euro pricing, EU-language storefronts, and EU country domains. A purely business-to-business platform is in a different position from a consumer store, and where your line falls is something to settle with counsel.

The microenterprise exemption

The Directive exempts microenterprises that provide services from the service accessibility requirements. It defines a microenterprise as one that employs fewer than 10 people and has an annual turnover, or an annual balance sheet total, of no more than EUR 2 million. The exemption covers services only, not products. If your company belongs to a larger group, how headcount and turnover are counted can change the answer, so check before relying on it.

Who enforces it, and how

A directive isn't a single law that applies directly. Each member state writes the Act into its own national law, designates authorities to check that services comply, and sets its own penalties. The Directive requires those penalties to be effective, proportionate, and dissuasive, and it requires member states to make sure consumers and qualifying organizations have ways to take action under national law.

The result is one enforcement regime per country, with different authorities, procedures, and penalty scales. We aren't going to list enforcement actions or fines here, because the picture differs by country and changes quickly. If you sell into a particular market, find out which authority covers your sector there.

Two provisions are often misread. The Directive allows a provider to claim that a requirement would impose a disproportionate burden, but only after a documented assessment, and the claim has to be renewed and supplied to authorities on request. It isn't a blanket opt-out. And the Directive includes transitional arrangements for certain existing service contracts and products already in use, which are worth confirming with counsel but won't cover a storefront you keep changing.

Where WCAG fits: EN 301 549

The Act doesn't cite WCAG directly. Its Annex I sets functional requirements instead, such as providing information through more than one sensory channel and making websites and mobile apps perceivable and operable for people with disabilities. Products and services that conform to harmonised standards published in the EU's Official Journal are presumed to meet the matching requirements.

The standard everyone points to is EN 301 549, the European standard for accessibility of ICT products and services. Its web and software clauses incorporate the WCAG 2.1 Level A and AA success criteria, and it adds requirements beyond WCAG for things like two-way voice communication, video players, documentation, and support services. EN 301 549 is already the harmonised standard for public sector websites under the Web Accessibility Directive, and an updated version is being prepared with the EAA in mind. Before you write a version number into a contract, check which version, if any, is cited in the Official Journal for the EAA.

In practice: if your EU-facing web journeys conform to WCAG 2.1 AA, you've covered most of what EN 301 549 asks of web content. Conforming to WCAG 2.2 AA covers that and the newer criteria too. The remaining work is in the parts WCAG doesn't address, such as support channels and documentation.

For e-commerce, Annex I adds specifics worth reading closely. Identification, security, and payment functions must be accessible, and when a manufacturer provides accessibility information about a product, the store should pass it on.

What to do this quarter

Map your exposure with counsel. List every storefront, app, and market where you sell to EU consumers, and which legal entity does the selling. Settle the microenterprise question early if it might apply.

Audit the EU journey in the languages you sell in. Start where an EU visitor starts: the cookie consent banner, which is often the first keyboard trap on the page. Then test product search, international address forms, checkout, the payment step (including third-party payment frames and card authentication challenges), account creation, returns, and support chat. Use a keyboard and a screen reader, not just a scanner.

Get the language attributes right. Screen readers choose pronunciation from the lang attribute, so a German page marked as English is read with English pronunciation. The 2026 WebAIM Million found that 13.5% of home pages were missing a document language entirely. Multilingual stores need it on every page, and on language switcher links too:

<html lang="de">
…
<nav aria-label="Language">
  <a href="/fr/" hreflang="fr" lang="fr">Français</a>
  <a href="/en/" hreflang="en" lang="en">English</a>
</nav>

This covers WCAG SC 3.1.1 Language of Page and SC 3.1.2 Language of Parts.

Publish how your service meets the requirements. Annex V asks service providers to make available information about the service, how it works, and how it meets the accessibility requirements, in accessible formats. Most companies do this as an accessibility statement: the standard you test against, known limitations and workarounds, how to report a barrier, and when the statement was last reviewed. Publish it in each language you sell in, and make sure the statement itself is accessible.

Ask your vendors. Payment, consent, search, chat, and review widgets all sit inside your journey. Ask each one for an Accessibility Conformance Report in the EU edition of the VPAT® (currently 2.5Rev), which reports against EN 301 549.

Fix in source code. A script or widget that patches the page after it loads doesn't change the markup your EU visitors' assistive technology reads, and it adds another third-party script to a consent banner that already has to account for every one. Fix the components themselves, then retest with the same keyboard and screen reader steps.

Build it into releases. EU storefronts change constantly: new payment methods, seasonal campaigns, localized promotions. Add automated accessibility checks for the EU checkout to your deployment pipeline, and repeat the manual keyboard and screen reader pass whenever the payment step or the consent banner changes, since those two components change often and are easy to break.

Keep records. Authorities may ask what you tested, what you fixed, and when. A dated findings register answers that.

If you sell into Europe, start with the checkout

The checkout is where EU consumers spend money and where barriers cost you sales, so it's the right first test. Our WCAG 2.2 accessibility audit can cover your EU-facing journeys in each language, and if business customers in Europe are asking for documentation, we write Accessibility Conformance Reports in the EU edition.

One year in, the European Accessibility Act reaches US checkouts