European Accessibility Act: what changes for your clients

Since 28 June 2025, the European Accessibility Act (Directive (EU) 2019/882) applies across the European Union. For the first time, digital accessibility is no longer an obligation for the public sector only: an online shop, a bank or a transport service must also make its website and app usable by people with disabilities.

If you build or maintain websites for clients, the question will come sooner or later: "are we concerned, and are we compliant?". Here is what you need to answer it.

Who is concerned

The directive covers specific products and services sold to consumers. On the web, the most common cases are:

• e-commerce: any website or app that sells products or services online to consumers;
• banking services for consumers;
• passenger transport: websites, apps, e-tickets and travel information;
• e-books and the software used to read them;
• electronic communications and access to audiovisual media services.

Microenterprises that provide services (fewer than 10 people and an annual turnover or balance sheet of 2 million euros at most) are exempt. A small craft shop may therefore not be concerned, while an online shop with 15 employees is.

Each member state has transposed the directive into its own law. In France, the RGAA, the framework well known to those who work for the public sector, remains the most detailed practical reference.

What "accessible" means in practice

The directive sets general requirements. To apply them, the European standard EN 301 549 is the reference, and for web content it takes up the criteria of WCAG at level AA. On a website, this means for example:

• text alternatives on images that carry information;
• enough contrast between text and background;
• a site usable with the keyboard, with a visible focus;
• forms where every field has a label, and errors are explained;
• a clear structure: ordered headings, the page language declared, links that say where they lead.

The service must also publish information about its accessibility: how it meets the requirements, and what does not yet.

What an automated audit sees, and what it does not

An automated tool quickly finds a good share of the issues: an image without a text alternative, contrast too low, a field without a label, a button without a name. They are often the most frequent, and the easiest to fix.

It does not replace a human audit, though. It cannot tell whether a text alternative describes the image well, whether the reading order makes sense or whether a checkout can be completed with the keyboard from start to finish. An automated audit without errors does not mean "compliant", but a page that shows fifty certainly is not.

What Kolteo does

On each analysis, Kolteo loads the page in a real browser, as a mobile visitor sees it, and runs a WCAG 2.2 AA audit with axe-core, the open source audit engine by Deque. For each issue found, you see:

• the elements concerned and how to fix them;
• the matching criteria of WCAG 2.2, EN 301 549 and the French RGAA 4.1;
• its severity, from blocking issues to minor remarks.

As the analysis comes back every week by default, you also see when a new issue appears after an update, and the PDF report you send to your client keeps track of it.

Where to start with a client

1. Check whether they are concerned: do they sell online to consumers? Are they above the microenterprise thresholds?
2. Analyse the key pages: home, product page, cart, checkout, account creation.
3. Fix the blocking issues first, those that prevent a purchase: buttons without a name, fields without a label, unreadable contrast.
4. Test the checkout with the keyboard, without a mouse, from start to finish.
5. Write the accessibility information of the service, and plan a human audit if the stakes are high.

Accessibility is not only a legal constraint: a site that is easier to read and to use is easier for everyone, not only for people with disabilities.

This article gives guidance, not legal advice. For a specific case, ask a lawyer or a specialised auditor.