EN 301 549 and European Accessibility Act audits
Since 28 June 2025, online stores and other consumer services selling in the EU have to meet European accessibility requirements, wherever the business is based. I test your site by hand against EN 301 549 and WCAG 2.2 AA, and give your developers a report they can fix from.
What the European Accessibility Act requires
The European Accessibility Act (EAA, Directive (EU) 2019/882) has applied since 28 June 2025. It sets accessibility requirements for products and services that consumers use every day. For websites and apps, the services in scope include:
- Online stores and other e-commerce services
- Consumer banking services
- E-books and the software used to read them
- Electronic communications services
- Websites, apps and e-tickets for booking passenger transport
- Access to audiovisual media services
Each EU country has turned the directive into its own law, for example Germany's Barrierefreiheitsstärkungsgesetz (BFSG), and national authorities enforce it.
Does it apply to your business?
| Your situation | Does the EAA likely apply? |
|---|---|
| You are based in the EU and sell to consumers online | Yes, unless you are a microenterprise (see below). |
| You are based outside the EU, for example in the US, UK or India, and sell to consumers in the EU | Yes. The EAA follows the customer, not the address of the business. |
| You provide services, have fewer than 10 employees, and have an annual turnover or balance sheet of €2 million or less | You are a microenterprise, which is exempt for services (not for products). |
| You sell only to other businesses | The EAA focuses on consumers, but public bodies and large buyers often ask for EN 301 549 conformance when they buy. |
| You run the website or app of a public sector body | The Web Accessibility Directive applies, and it uses the same technical standard. |
This is a general guide, not legal advice. Whether the rules apply to you depends on your products, your customers and your country, so confirm with a lawyer who knows EU law.
EN 301 549: the standard behind the law
EN 301 549 is the European standard for ICT accessibility. Meeting it gives a presumption of conformity with the EAA and the Web Accessibility Directive. For web content, it builds directly on WCAG.
| Version | Web content is based on | Status (October 2026) |
|---|---|---|
| V3.2.1 (2021) | WCAG 2.1 AA | The version that currently gives a presumption of conformity. |
| V4.1.1 (September 2026) | WCAG 2.2 AA | Published. The presumption of conformity starts once the European Commission cites it in the Official Journal of the EU. |
V4.1.1 adds six WCAG 2.2 criteria for web content: Focus Not Obscured (Minimum), Dragging Movements, Target Size (Minimum), Consistent Help, Redundant Entry and Accessible Authentication (Minimum). It also drops the obsolete Parsing criterion and extends the user preferences requirements to web pages.
What this means for you
My audits test against WCAG 2.2 AA, so one audit prepares you for both versions. For engagements under V3.2.1, I also check the Parsing criterion that version still lists. You don't need to wait for the new version to be cited before you start fixing.
What is at stake
- Penalties are set country by country. Germany's law allows fines of up to €100,000 per violation, and other countries set their own ceilings.
- Enforcement has started. In November 2025, French disability rights organizations filed the first lawsuits under the EAA, against four large retailers.
- Selling in several countries multiplies the exposure, because each national authority can act on its own.
Penalties and enforcement practice change quickly. Check the current rules in each country where you sell.
What you get from an EU audit
- A manual audit of your key pages and user journeys against WCAG 2.2 AA, with keyboard, NVDA, JAWS and VoiceOver
- Every finding mapped to its EN 301 549 clause (web content is clause 9) as well as its WCAG criterion
- Severity ratings, steps to reproduce, actual and expected behavior, and code-level fixes your developers can use
- A conformance summary you can use as input for your accessibility information. Your lawyer should review the final wording.
- An accessibility conformance report (ACR) in the EN 301 549 edition, as a $300 to $500 add-on
- A walkthrough call and a free retest after your fixes
The audits and prices are the same as for US clients. See pricing or see a sample report.
Working across time zones
I'm based in India, and Europe's working day overlaps with mine, so calls and questions are easy to schedule. Reports are delivered in English.
Common questions
Do you give legal advice?
No. I test and report on accessibility. For questions about what the law requires of your business, talk to a lawyer who knows EU and national law.
Will an accessibility overlay make my store compliant?
No. Overlays don't fix the underlying code, and they are not a substitute for testing. Read why widgets don't protect you.
Do I need an accessibility statement?
The EAA expects service providers to give consumers information about the accessibility of their service, and several countries expect a published statement. Your lawyer can tell you what your country requires. My report gives you the technical facts that statement depends on.
I sell in both the US and the EU. Do I need two audits?
No. One manual audit covers both, and the report shows how each finding relates to the ADA, Section 508, EN 301 549 and the EAA. Compare the US and EU rules.
See what an EU audit would find on your site.
I'll test your homepage by hand and send you a free one-page report on the top 3 barriers I find. Tell me you sell in Europe, and I'll note the EN 301 549 clause for each.
Sources and notes
- Directive (EU) 2019/882, the European Accessibility Act (EUR-Lex)
- European Commission, AccessibleEU: EN 301 549 has been updated (7 September 2026)
- ETSI EN 301 549 V4.1.1 (2026-09)
Information as of October 2026. Enforcement examples come from published legal analyses and press reports. This page is general information, not legal advice.