European Accessibility Act: UK Business Guide

Quick Answer

The European Accessibility Act, in force since 28 June 2025, applies to any business selling covered digital products or services to EU consumers, regardless of where that business is based. UK companies with EU-facing websites, apps, or e-commerce checkouts fall within scope. Microenterprises with fewer than 10 employees and under €2 million annual turnover are exempt from some requirements if they have no EU customers, but the exemption narrows quickly once EU trade is involved.

Why a UK Business Would Be Covered by EU Law

The EAA is extraterritorial by design. It does not test where a business is registered or based. It tests whether the business’s digital products or services are accessible to EU consumers. A UK company with a checkout page that EU residents can complete is within scope, regardless of physical location.

What Counts as a Covered Product or Service

E-commerce websites and apps selling to EU consumers
Banking and financial services offered to EU customers
Transport ticketing and booking services
Telecoms and electronic communications services
E-books and certain digital publishing formats
Consumer electronics with digital interfaces sold into the EU

The Microenterprise Exemption

If your business has fewer than 10 employees and under €2 million in annual turnover, and you have no EU customers, EAA legal pressure is significantly lower. Once you actively sell to EU consumers, this exemption narrows, so it is worth checking your actual customer base rather than assuming the exemption automatically applies.

Enforcement Is Already Happening

The EAA is not a theoretical risk. Through 2026, enforcement has moved from warnings to real penalties:

The first EAA lawsuits were filed in France in November 2025
The Dutch Authority for Consumers and Markets has actively enforced against e-commerce and electronic communications providers
Germany fined a retailer €150,000 over checkout alt-text failures
Penalties vary substantially by member state, ranging from around €60,000 in Ireland to roughly €900,000 in Sweden

What UK Businesses Should Check Now

Do you sell products or services that EU consumers can complete a transaction for online?
Does your checkout, booking, or account creation flow work for keyboard-only and screen reader users?
Are you relying on pre-June-2025 contracts or products, and if so, have you identified your transitional deadline of 28 June 2027?
Have you documented your current conformance status, even informally, in case a customer or regulator asks?

How the EAA Relates to UK Domestic Law

The EAA sits alongside, not instead of, your existing UK duties under the Equality Act 2010. See our guide on whether website accessibility is a legal requirement in the UK for how the two frameworks work together. A UK business with EU customers effectively has two separate legal bases requiring accessible digital services, not one combined requirement.

What Enterprise Buyers Are Now Asking For

Beyond direct enforcement risk, EAA compliance has become a commercial factor. Enterprise and public sector buyers increasingly request accessibility documentation, including WCAG conformance claims, audit summaries, and remediation roadmaps, as a standard part of vendor selection and contract renewal, even outside formal enforcement action.

Frequently Asked Questions

Does the European Accessibility Act apply to UK businesses?
Yes, if the business sells covered digital products or services to EU consumers, regardless of where the business is based.

Is there a small business exemption from the EAA?
Microenterprises under 10 employees and €2 million turnover are exempt from some requirements, but only if they have no EU customers.

When did the EAA come into force?
28 June 2025, with active enforcement now underway across several EU member states.

What are the penalties for EAA non-compliance?
Penalties vary by member state, ranging from around €60,000 in Ireland to roughly €900,000 in Sweden, based on cases so far.

Does the EAA replace UK accessibility law?
No. It applies alongside the Equality Act 2010 for any UK business with EU customers, not instead of it.

European Accessibility Act: What UK Businesses Need to Know