Accessible websites and the European Accessibility Act (EAA 2025): obligations and opportunity

An accessible website is one that anyone can use, including people with visual, hearing, motor or cognitive disabilities, and people who browse with screen readers, with the keyboard only or with enlarged text. Since 28 June 2025, it has also been a legal obligation for many businesses: the European Accessibility Act (EAA, Directive (EU) 2019/882), applied in Spain through Law 11/2023, requires certain digital products and services — including e-commerce — to be accessible. Let's look at who it applies to, what you need to comply with, what the risks are and why, on reflection, it's an opportunity.

What is the European Accessibility Act (EAA)?

Directive (EU) 2019/882, known as the European Accessibility Act or EAA, is the EU law that sets common accessibility requirements for a range of everyday products and services. It has a dual aim: to ensure people with disabilities can access them on equal terms, and to avoid each EU country having different rules. Its requirements have applied since 28 June 2025.

In Spain, the directive was transposed by Law 11/2023 of 8 May, which sets out the obligations for economic operators and service providers. In February 2026, Royal Decree 143/2026 also created the technical support and coordination unit for accessibility market surveillance authorities — a clear sign that enforcement is under way.

Which businesses does it apply to?

The EAA doesn't apply to every website, only to the products and services it lists. On the services side, the most relevant for a business are:

• E-commerce: any website or app that lets a consumer buy or sign up for something remotely. This is the case that affects most SMEs.
• Consumer banking services.
• Passenger transport (air, bus, rail and waterborne): websites, apps, e-tickets and real-time information.
• Electronic communications and access to audiovisual media services.
• E-books and the software used to read them.

It also covers products such as computers, smartphones, e-readers and self-service terminals (ATMs, ticketing or check-in machines).

There's one important exception: micro-enterprises providing services — fewer than 10 employees and annual turnover or a balance sheet not exceeding €2 million — are exempt from the service obligations. Even so, if you're a micro-business with an online store, making your website accessible is still highly advisable: your customers don't care about your company size when they can't complete a purchase.

A useful nuance: the EAA is about consumers. A purely corporate or B2B website that doesn't allow online contracting is not, in principle, within the scope of this law — but the same good practices apply, and large clients and public bodies often require accessibility in their tenders.

What does the law require in practice?

The law sets functional requirements: the service must be perceivable, operable, understandable and robust. In practice, the technical reference is the European standard EN 301 549, which for websites points to the WCAG 2.1 level AA guidelines. One caveat: today it is the harmonised standard for Directive (EU) 2016/2102, which covers public-sector websites; no harmonised standard has yet been published in the Official Journal of the EU for the EAA (an adapted version is in preparation), but it is the most widely used technical reference for assessing compliance. The latest version, WCAG 2.2, adds criteria on focus visibility, touch target size and authentication, and it's the one we recommend as the target for new projects. Some concrete examples of what must be met:

• All informative images have alternative text describing them.
• Contrast between text and background is sufficient to read it without effort.
• The whole website can be used with the keyboard only, and focus is always visible.
• Forms have clear labels and understandable error messages.
• Videos have captions, and content doesn't rely on colour alone.
• Heading structure is logical and the site works well with text enlarged to 200%.

In addition, the service provider must explain how the service meets the accessibility requirements, for example in its general terms or in an accessibility statement.

Are there transition periods?

Yes, but they're limited. Services may keep using, until 28 June 2030, products they were already lawfully using before 28 June 2025, and contracts signed before that date may continue until they expire, for a maximum of five years. Self-service terminals already installed have a longer deadline. None of these periods applies to new or redesigned websites: if you build an e-commerce website today, it must be accessible from day one.

What are the penalties for non-compliance?

Law 11/2023 refers to the infringement and penalty regime of the relevant sector legislation and, on a supplementary basis, to that of Spain's General Law on the rights of persons with disabilities (Royal Legislative Decree 1/2013), which classifies infringements as minor, serious or very serious, with fines ranging from €301 up to €1,000,000 in the most serious cases. Enforcement falls to the authorities designated by each autonomous community (Article 27 of the law); where none has been designated yet, the national technical unit created by Royal Decree 143/2026, attached to the Directorate-General for the Rights of Persons with Disabilities, steps in. Beyond fines, the most immediate risk is often something else: customer complaints, lost sales and reputational damage that is hard to undo.

Why is accessibility an opportunity and not just an obligation?

Because an accessible website is simply a better website for everyone:

• A bigger market: according to the European Commission, around 87 million people in the EU have some form of disability, and a growing share of the population is older. If they can't buy on your website, they'll buy on someone else's.
• Better SEO: well-structured headings, alternative text, semantic HTML and speed are exactly what Google values.
• Better GEO: well-structured, well-described content is much easier for AI assistants to interpret and cite.
• More conversions: clear forms, large buttons and good contrast reduce errors and drop-offs for all users, including those browsing on a phone in bright sunlight.

How do we audit and fix a website's accessibility?

1. Automated analysis: we run specialised tools to catch obvious issues (contrast, alternative text, labels). They only detect part of the problems, which is why they're not enough.
2. Manual review: we navigate the website with the keyboard only, with screen readers and with enlarged text, and test the key journeys: finding a product, adding it to the basket, paying or filling in a form.
3. Prioritised report: we rank issues by impact and effort, referencing each affected WCAG criterion.
4. Fixes: we correct code, design and content, starting with purchase and contact journeys.
5. Statement and monitoring: we write the service's accessibility information and periodically check that new content doesn't introduce errors.

The problems we find most often are always the same: cookie banners that can't be closed with the keyboard, carousels that can't be paused, forms without labels, inaccessible PDFs and icon-only buttons with no text.

Where should you start if you run an online store?

If you sell to consumers through your website and don't know where you stand, here's a first check you can do yourself in half an hour:

1. Try to complete a full purchase using only the keyboard (Tab, Enter and the arrow keys). If you get stuck at any point, there's a serious problem.
2. Zoom the browser text to 200% and check that nothing overlaps or disappears.
3. Check whether product photos have a description and whether buttons say what they do.
4. Test the cookie banner and the chat widget: they're often the first obstacle.
5. Look for a page or section with accessibility information about the service.

If any of these checks fails, it's worth running a full audit before a customer finds the problem for you.

Want to know whether your website complies?

At Somia Digital we design accessible websites from the start and adapt existing ones, following WCAG criteria and thinking about real people. You can see how we work on our web design service page. If you run an online store or aren't sure whether the law applies to you, send us your website address or message us on WhatsApp and we'll do a first no-obligation review.

This article is for information purposes only and does not constitute legal advice. Information reviewed as of October 2026.