WCAG and the European Accessibility Act: who must comply in the EU?

There is a lot of confusion around WCAG and the European Accessibility Act. One of the most common claims is that every website or online store in the EU became legally required to comply with WCAG on June 28, 2025. That is not an accurate description of the law. WCAG is a technical accessibility standard, not legislation in its own right. Legal obligations depend on the applicable law, the type of organization, the service being provided, and the users it serves.

Public-sector websites have been subject to digital accessibility requirements for years. The major change for private businesses came with the European Accessibility Act, or EAA, and the national legislation implementing it across EU Member States. Since June 28, 2025, accessibility requirements have applied to a range of covered products and consumer services, including e-commerce.

Is WCAG legally required?

WCAG stands for Web Content Accessibility Guidelines. Developed by the World Wide Web Consortium, or W3C, it is an international technical standard explaining how to make websites, applications, and other digital content more accessible to people with disabilities.

WCAG does not, by itself, create a legal obligation for every website. Instead, legislation, procurement rules, contracts, and technical standards may refer directly or indirectly to WCAG when defining accessibility requirements.

For a detailed explanation of the four WCAG principles, conformance levels A, AA and AAA, and the differences between WCAG 2.0, 2.1 and 2.2, see our WCAG glossary entry. This article focuses on the legal and business question: who actually needs to address digital accessibility?

WCAG and the European Accessibility Act – what is the difference?

WCAG and the EAA are closely related, but they are not the same thing.

• WCAG is a technical web accessibility standard developed by W3C.
• The European Accessibility Act is Directive (EU) 2019/882, which sets accessibility requirements for certain products and services across the European Union.
• National legislation implements and enforces the EAA in individual EU Member States.

In Poland, the EAA was implemented through the Act of April 26, 2024 on ensuring compliance with accessibility requirements for certain products and services, commonly referred to as the Polish Accessibility Act. It entered into force on June 28, 2025.

This distinction matters. A company should not begin by asking whether “WCAG applies to us.” The better first question is whether its products or services fall within the scope of the applicable accessibility legislation. The relevant technical requirements can then be identified.

Accessibility requirements for public bodies

Public-sector websites and mobile applications are subject to a separate European framework based on Directive (EU) 2016/2102 and the national laws implementing it.

In Poland, public-sector digital accessibility is governed by the Act of April 4, 2019 on the digital accessibility of websites and mobile applications of public entities. It covers, among others, public finance bodies, state organizational units, certain publicly controlled or financed legal entities, associations of those organizations, and some NGOs working in health, disability, or services for older people.

Covered public websites have been required to meet digital accessibility requirements since September 23, 2020, and mobile applications since June 23, 2021. Public bodies also have specific obligations concerning an accessibility statement.

Does the European Accessibility Act apply to e-commerce?

Yes, e-commerce is one of the services covered by the European Accessibility Act. This is particularly important for online retailers selling to consumers in the EU, except where a specific exemption applies.

Under the Polish implementation, an e-commerce service is a service offered or provided remotely through websites or mobile devices, by electronic means and at the individual request of a consumer, with the purpose of concluding a contract.

This means the rules are relevant to far more than a conventional online store selling physical goods. Depending on the business model, they can also apply to businesses selling services, subscriptions, insurance, bookings, healthcare services, digital products, and other consumer offerings online.

Accessibility must also be considered across the complete customer journey. Making the home page accessible while leaving the cart, checkout, account registration, delivery selection, or payment flow inaccessible does not solve the problem.

What about B2B websites?

The EAA’s e-commerce provisions concern services provided to consumers. A website operating exclusively in a business-to-business model should therefore not automatically be treated in the same way as a consumer e-commerce service.

Mixed B2B/B2C platforms and companies providing several different digital services require a more careful scope assessment. The fact that a company has a website does not, on its own, determine whether that website falls within the EAA.

Which private businesses are covered by the EAA?

E-commerce is only one part of the European Accessibility Act. The legislation covers a defined range of products and consumer services.

Covered services include areas such as:

• electronic communications,
• access to audiovisual media services,
• certain digital elements of passenger transport services,
• consumer banking services,
• e-books and related services,
• e-commerce services.

As a result, accessibility is relevant not only to online retailers but also to banks, transport and booking platforms, telecommunications providers, publishers, and other organizations providing covered services to consumers.

A corporate brochure website that does not provide a covered service should not automatically be assumed to fall within the same legal scope. The service, audience, contractual process, and applicable national legislation all need to be considered.

Exemptions and microenterprises

The microenterprise exemption

One of the most important EAA exemptions concerns microenterprises providing services. This is why statements claiming that every online store in Europe must comply are too broad.

Under the EAA framework, microenterprises providing covered services are exempt. In the Polish business framework, microenterprise status generally means employing fewer than 10 people and remaining within the applicable EUR 2 million turnover or balance-sheet threshold.

The distinction between products and services is important. A microenterprise that manufactures, imports, or distributes a product covered by accessibility legislation should not assume that the service exemption automatically removes all of its obligations.

Fundamental alteration and disproportionate burden

The EAA framework also recognizes situations in which meeting a particular accessibility requirement would fundamentally alter the basic nature of a product or service or impose a disproportionate burden.

This is not a blanket exemption that can simply be claimed because remediation is expensive. The relevant assessment must follow the applicable legal criteria and, where required, be documented and kept up to date.

WCAG 2.1 vs. WCAG 2.2 – which version should you use?

WCAG 2.2 is the latest version of the WCAG 2 standard. It adds requirements addressing areas such as focus visibility, accessible authentication, dragging alternatives, target size, and repeated information in forms. W3C recommends using the latest version of WCAG where possible.

However, the latest WCAG release should not automatically be presented as the legally mandated version in every jurisdiction and every use case.

As of August 2026, the European standard EN 301 549 V3.2.1:2021 remains the version listed by the Polish government for e-commerce accessibility requirements, and that version references WCAG 2.1. Work on an updated European standard is ongoing.

For new websites and major remediation projects, targeting WCAG 2.2 Level AA can therefore be a sensible forward-looking technical objective where appropriate, while the formal compliance assessment should still be based on the exact legislation, standard, and specification applicable to the organization.

What needs to be made accessible on a website or online store?

Digital accessibility is much broader than color contrast or a toolbar that allows users to enlarge text. A meaningful accessibility review looks at design, content, semantic HTML, JavaScript behavior, forms, and complete user journeys.

Typical areas to review include:

• full keyboard operation of interactive features,
• visible and logical keyboard focus,
• accessible names and roles for buttons, links, and controls,
• properly labeled form fields and understandable error messages,
• sufficient color contrast,
• information that does not rely on color alone,
• appropriate text alternatives for meaningful images,
• semantic headings, lists, tables, and page regions,
• content that remains usable when zoomed or reflowed,
• accessible menus, dialogs, tabs, accordions, and other interactive components,
• captions and other required alternatives for multimedia,
• accessible login, authentication, cart, checkout, and payment processes.

Automated testing is useful, but an automated scan cannot establish full WCAG conformance. A tool cannot reliably determine whether alternative text communicates the right information, whether focus order is logical, whether an error message makes sense to a user, or whether an entire checkout process works with a screen reader.

Accessibility statements and accessibility information

The terminology here can be confusing because public bodies and private businesses do not necessarily have the same documentation obligations.

Public-sector organizations covered by public-sector accessibility legislation are generally subject to specific accessibility statement requirements under their national framework.

Private service providers covered by EAA implementing legislation may have separate information obligations. In Poland, for example, an e-commerce service provider must make information available about the service, what is necessary to use it, and how the service meets the applicable accessibility requirements.

A private-sector accessibility information requirement should therefore not automatically be treated as identical to the formal accessibility declaration required from a Polish public entity.

Penalties and enforcement

The EAA is a directive, so enforcement mechanisms and penalties are established through national legislation. Businesses operating across several EU markets should therefore consider the rules that apply in each relevant Member State rather than assuming there is one EU-wide fixed fine.

In Poland, the Accessibility Act provides for financial penalties for certain violations, including failure by a covered service provider to meet applicable accessibility requirements. A penalty may reach up to ten times the average monthly salary in the national economy for the preceding year, subject to a cap of 10% of the business’s turnover in the previous financial year.

For public-sector organizations in Poland, a different enforcement regime applies. Persistent and unjustified failure to provide digital accessibility can result in fines of up to PLN 10,000 for a website or mobile application, while accessibility declaration violations can result in fines of up to PLN 5,000.

Regulatory risk is only one reason to address accessibility. An inaccessible form, authentication step, or checkout can also prevent a potential customer from using the service at all.

How to implement WCAG on an existing website

The most effective approach is to determine the legal and technical scope first and remediate the product second. Installing an accessibility overlay or a generic plugin does not replace accessible design, code, content, and testing.

A professional remediation process typically includes:

1. Scope assessment – determine the applicable legislation, technical standard, pages, components, and user journeys.
2. Accessibility audit – review representative pages, templates, components, and critical processes.
3. Issue prioritization – distinguish critical blockers from lower-impact improvements.
4. Design and development remediation – correct problems in UI, HTML, CSS, JavaScript, forms, and interactive components.
5. Content remediation – address alternative text, headings, links, multimedia, documents, and instructions.
6. Manual testing – test keyboard navigation, screen readers, zoom, reflow, and complete user journeys.
7. Retesting – verify that fixes work and have not introduced new barriers.
8. Ongoing accessibility – include accessibility in future design, development, and content workflows.

At Travi, we audit and remediate existing websites and online stores and can also build new digital products with accessibility incorporated from the design stage. Learn more about our WCAG audits and accessibility remediation services.

Does WCAG compliance help SEO and UX?

WCAG compliance is not a known standalone Google ranking factor. Accessibility should therefore not be marketed as a shortcut to higher search rankings.

There is, however, meaningful overlap between accessible implementation and high-quality web development. Semantic HTML, descriptive links, logical heading structures, accessible forms, responsive layouts, understandable content, and predictable navigation can improve the experience for users and make digital content easier for different technologies to interpret.

For businesses, the more immediate benefit is straightforward: an accessible digital service reduces the number of situations in which a customer cannot understand the content, operate a form, create an account, or complete a purchase. For large organizations and e-commerce businesses, accessibility belongs alongside compliance, UX, product quality, and long-term maintainability.

Is there an EAA transition period until 2030?

June 28, 2030 is sometimes presented as a general deadline allowing existing websites and online stores to remain inaccessible until that date. That is not what the European Accessibility Act provides.

The transitional rules apply to specific situations. Service contracts agreed before June 28, 2025 may continue without alteration until they expire, but for no longer than five years. Service providers may also continue, until June 28, 2030, to provide certain services using products they lawfully used for similar services before the EAA became applicable.

It is therefore misleading to say that every existing website automatically has until 2030 to become accessible. The transitional provisions need to be assessed in the context of the specific service, contract, and technology involved.

Official sources

• W3C – Web Content Accessibility Guidelines (WCAG)
• European Commission – European Accessibility Act
• EUR-Lex – Directive (EU) 2019/882
• Polish government – Accessibility Act and e-commerce services
• Polish Accessibility Act of April 26, 2024

This article is provided for general informational purposes and does not constitute legal advice. Organizations with complex business models or operations across several jurisdictions should assess the applicable requirements individually.

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