Legal obligation since June 2025
Is your website accessible? Legally, the answer matters more than ever.
Since June 2025, digital accessibility is no longer optional for most e-commerce sites and digital services in Europe. Find out whether you are concerned, what it involves, and how to get compliant without spending months on it.
Free self-assessment, about 1 minute, no sign-up required.
The legal context, in plain language
Since 28 June 2025, a European law called the European Accessibility Act (EAA) requires most e-commerce sites, banks and digital services to be usable by people with disabilities. In Luxembourg as in France, that obligation rests on precise technical references: WCAG 2.1 level AA and the European standard EN 301 549.
In practice: if your site sells products or services to consumers online, it must let everyone navigate, understand and buy. That includes people with low vision, deaf people, and people with motor or cognitive impairments.
The three references to know
The EAA, the law
Directive (EU) 2019/882 harmonises accessibility requirements across the 27 member states. It has applied to covered products and services since 28 June 2025.
EN 301 549, the European standard
The technical standard the law points to. For anything digital it relies on the WCAG success criteria, level AA.
RGAA and RAWeb, the national frameworks
France (RGAA) and Luxembourg (RAWeb) turn WCAG into a testable method with a fixed list of criteria and a documented test procedure. Passing them is how you demonstrate conformance.
Who is concerned?
Use the list below as a quick self-diagnosis. If you recognise your organisation in one of these situations, the obligation very probably applies to you.
You are most likely concerned if
- You sell online to European consumers: e-commerce, SaaS, banking, insurance, transport, ticketing.
- You employ more than 10 people or generate more than 2 million euro in annual turnover.
- You are a public body in Luxembourg, whatever your size, or a public body elsewhere in the EU under the earlier Web Accessibility Directive.
- You publish e-books, or provide electronic communication or audiovisual media services.
The one real exception
- Microenterprises providing services, meaning fewer than 10 employees AND less than 2 million euro turnover, may be exempted.
- A requirement that would impose a disproportionate burden or fundamentally change the service can be limited, but the assessment has to be documented and it is reviewed.
These exceptions are narrow and assessed case by case. Being a small company is not, on its own, an exemption. When in doubt, assume the obligation applies.
The concrete risks of doing nothing
Ignoring the obligation creates several kinds of exposure, and not only legal ones.
Financial penalties
Each member state sets its own sanctions regime. Amounts vary by country, but they are designed to be dissuasive and they scale with the size of the organisation.
Direct legal exposure
Complaints from consumers or advocacy groups, formal notices from the national monitoring body, and proceedings that become public. The reputational cost usually lands before the fine does.
An invisible loss of market
According to the WHO, roughly one person in six worldwide lives with a disability. An inaccessible checkout excludes part of your customers silently: they leave, and they never tell you why.
Progressive blocking by new technology
AI agents that browse on a user's behalf rely on the same structures as assistive technology. A poorly structured site becomes hard to read, or simply unusable, for them too.
The real benefits, without the overselling
Being honest matters here. Accessibility is not a magic conversion lever. But it overlaps heavily with UX practices whose impact is well documented, and it removes friction that costs you money today.
SEO
A 2025 Semrush study covering 10,000 websites found that accessible sites get 23% more organic traffic and rank on 27% more keywords. Read it as a correlation, not as a causal ranking factor confirmed by Google: the same work that makes a page accessible also makes it cleaner, faster to parse and better structured.
Source: Semrush, Why Accessibility Matters More Than Ever for SEO Performance (2025)(opens in a new tab)
User experience
Clearer content structure, better designed forms, more logical navigation. All of it benefits every user, not only people with disabilities.
Conversion
No serious study proves that a WCAG badge mechanically increases sales. What is documented is the opposite side: confusing forms, insufficient contrast and unclear error messages are known conversion killers, and accessibility removes exactly those.
Compatibility with AI agents
Shopping assistants and agentic browsers read the DOM and the accessibility tree to understand a page and act on it. Clear ARIA roles, programmatic labels and a clean semantic hierarchy make your site legible to them. That is an emerging competitive advantage, and it costs nothing extra once accessibility is done.
What to do, concretely
Five steps. The first one tells you where you stand, the last one is the only way to stay there.
1. Run a WCAG 2.1 AA conformance audit
On your website, your mobile app and your PDF documents. An audit against RAWeb, RGAA or RAAM gives you a criterion-by-criterion result rather than a vague score.
2. Publish an accessibility statement
Along with a multi-year accessibility plan. Both are expected even while you are still in transition, and publishing them is itself part of the obligation.
3. Prioritise high-impact fixes
Text alternatives, heading hierarchy, colour contrast, forms and keyboard navigation. These few families cover the large majority of the blocking issues found in practice.
4. Re-audit after the fixes
A correction is only real once it has been re-tested. A second pass turns your remediation work into evidence of conformance.
5. Maintain conformance over time
Every release can introduce a regression. Accessibility is a state to hold, not a project to close.
Want these five steps as a working document? The free accessibility checklist expands them into a full action plan, from executive sponsorship through to your declaration to the competent body. Print it, track your progress in it, or hand it to a client.
Get the free accessibility checklistHow CheckFox helps
CheckFox speeds up every step of that process, for accessibility auditors and product teams alike.
The tool lets you audit websites, mobile applications and PDF documents against the official frameworks, cutting the time spent on diagnosis while surfacing the issues worth fixing first. Audits are versioned, so the second pass reuses the first one instead of starting over, and a journey can group several audits to reflect the full experience your customers actually go through.
Audit against the right framework
RAWeb, RGAA, RAAM, RAPDF or WCAG, with the official test procedure attached to each criterion.
Find the blocking issues first
An automatic scanner combining axe-core with CheckFox's own rules flags what it can, and user impact ranks what remains.
Prove progress over time
Versioned audits, shareable reports and a generated accessibility statement, so conformance is documented rather than claimed.
Frequently asked questions
Is my website concerned by the EAA?
What is the difference between RGAA and WCAG?
What happens if I do nothing?
Do I have to be 100% compliant right away?
Are accessibility overlays enough?
How long does an accessibility audit take?
Does accessibility really help SEO?
This page is provided for information purposes and does not constitute legal advice. For a binding assessment of your situation, refer to your national monitoring body or to a qualified legal adviser.
Do not let accessibility become a risk, make it an advantage.
Start with an audit. You will know where you stand, what to fix first, and what to say publicly about it.