European Accessibility Act: What Website Owners Need to Know

The European Accessibility Act (EAA), Directive (EU) 2019/882, does not automatically apply to every website just because it is online. It sets accessibility requirements for specified products and consumer services. For a website owner, the first question is what service the site provides, to whom, and under which national rules—not simply whether the business has a website.

National measures applying the Directive have applied since 28 June 2025. If your service may be in scope, identify the relevant category and Member State rules, then assess the applicable functional requirements and document the work. This guide explains how to do that without treating a widget, automated scan, or broad exemption as a legal determination.

1. What the EAA covers

The EAA harmonises accessibility requirements for selected products placed on the market and selected services provided to consumers. The service categories include electronic communications, access to audiovisual media services, specified passenger-transport elements, consumer banking, e-books and dedicated software, e-commerce, and answering emergency communications to 112. The legal scope depends on the Directive’s definitions and national transposition. Read Directive (EU) 2019/882 on EUR-Lex.

For website owners, e-commerce is expressly listed. Websites and mobile-device-based services can also form part of certain covered passenger-transport services. That does not mean every business website is covered, or that only online shops need to investigate. Consider the service behind the site, whether it is offered to consumers, and whether it fits a defined category.

Quick scope check

Describe the service. Write down what a customer can do through the site or app: buy goods or services, manage a bank account, access transport services, read e-books, or use another service.
Check the statutory category. Compare the actual service with the EAA definitions and your country’s implementing law. A company’s industry label or the mere presence of a checkout is not a substitute for this analysis.
Identify the customer and market. The Directive’s service provisions concern consumer services. Determine where the service is provided and which Member State rules and competent authority are relevant.
Check the operator and any exemption carefully. In particular, verify whether the service-provider microenterprise exemption applies under the statutory definition and national implementation.
Record the conclusion and evidence. Note the service facts, provisions checked, assumptions, responsible person, and date. Revisit the analysis if the service, customers, or markets change.

2. The date: 28 June 2025

Member States were required to apply their transposing measures from 28 June 2025. The date is not a general website grace period. The Directive includes specific transition rules with defined contexts, but they should not be read as a blanket extension for websites.

For example, certain products already lawfully used to provide similar services before the date may continue to be used under specified conditions, generally through 28 June 2030. Certain self-service terminals have a separate possible use period capped at 20 years after entry into use. These provisions concern their stated circumstances; they do not create a general extra five years for a website. Check the Directive and local transposition before relying on a transition.

3. What a covered service provider needs to address

The requirements are functional and apply according to the service and applicable rules. The Directive addresses accessible websites and mobile-device-based services, information about the service and its accessibility features, and support systems that can provide relevant accessibility information. Its annexes set requirements for services and information, while national measures govern implementation and enforcement.

Service providers must provide information necessary to assess conformity in general terms and conditions or an equivalent document. The information should describe the service, how it meets applicable accessibility requirements, and relevant accessibility features. Check the Directive’s annexes and the law of each relevant Member State for the requirements that apply to your specific service.

A practical work plan

Map key user journeys. Include account creation, sign-in, search, purchase or booking, payment, confirmation, customer support, and any service-specific tasks.
Review functional accessibility. Examine whether users can perceive, understand, navigate, and operate the relevant service, including with assistive technologies. Derive the applicable criteria from the law rather than assuming one generic checklist settles every case.
Test with people and assistive technology. Combine manual review and suitable assistive-technology evaluation with automated checks. Automated scans can help find some issues, but the cited legal sources do not establish them as a complete compliance determination.
Fix issues and retest journeys. Prioritise barriers that prevent completing an essential task. Keep a record of findings, fixes, retest results, and remaining work.
Prepare service information. Put the required accessibility information in your general terms and conditions or an equivalent document, as applicable. Make sure support staff can provide relevant information.
Set ownership and review dates. Assign responsibility for monitoring changes to the service, content, third-party components, and national requirements.

A screenshot can help document what a page looked like at a point in time, compare a corrected screen with an earlier one, or review a visual state. It does not establish keyboard access, screen-reader behavior, or legal conformity by itself.

4. Exclusions, exemptions, and exceptions

The Directive contains specific exclusions and an exemption. Each has conditions. Confirm the exact wording and national implementation before relying on one.

Provision	What the Directive says in general	Practical caution
Microenterprise providing services	Microenterprises providing services are exempt from the Directive’s accessibility requirements and related obligations.	This is not a general exemption for every small business or for every product operator. Check the statutory microenterprise definition and how national rules apply.
Specified older media and documents	Exclusions cover specified pre-recorded time-based media and office file formats published before 28 June 2025.	Check the type of material and publication date; do not extend the exclusion to other site content by analogy.
Online maps	Online maps are excluded in the defined circumstance where essential information is provided accessibly.	The condition about essential information matters.
Third-party content	Specified third-party content is excluded where it is not funded, developed by, or under the control of the operator.	Establish who funded, developed, or controls the content. A vendor’s involvement alone does not answer that question.
Archived content	Website or mobile-application archives containing only content not updated or edited after 28 June 2025 are excluded in the defined circumstances.	This is a narrow archive provision, not a way to exempt an active site or its updated content.
Fundamental alteration or disproportionate burden	The Directive provides a conditional exception where a requirement would fundamentally alter the basic nature of a product or service or impose a disproportionate burden.	This calls for an assessment under the Directive’s criteria, relevant documentation, and a check of national implementation—not a casual opt-out.

Where an exception is relevant, document the requirement considered, the facts and analysis, the conclusion, and any information or review steps required by the applicable rules. Do not assume an exception for one part of a service covers the whole site.

5. National enforcement and penalties

The EAA establishes an EU framework, but Member States implement enforcement. The Directive requires effective means of ensuring compliance, including complaint mechanisms and authority follow-up, and requires national penalties to be effective, proportionate, and dissuasive, alongside effective remedial action.

The Directive does not set one EU-wide fine amount for website owners in the cited provisions. Check the current implementing law, competent authority, complaint process, remedies, and penalty rules for each relevant market. Do not rely on a penalty figure from another country as if it applied everywhere.

6. Evidence and ongoing review

Keep practical records that let your team explain what service was assessed, what requirements were considered, and what happened next. Depending on the applicable law and service, useful records may include:

A dated scope assessment tied to service features, customers, and markets.
A list of key journeys and the pages or components involved.
Manual and assistive-technology findings, automated scan results, and their limitations.
Prioritised remediation tickets, owners, completion dates, and retest outcomes.
Accessibility information supplied to customers and the location of that information.
Any formal assessment and supporting evidence used for a claimed exception.

Review after material product changes, new markets, major redesigns, or changes to national requirements. An automated scan or a capture of the rendered page is one input to that process, not proof that every applicable requirement has been met.

7. Capturing page evidence during an accessibility review

For visual review, a browser screenshot can preserve the page state your team needs to discuss. It is useful for visual regressions and documenting appearance; pair it with keyboard, assistive-technology, and task-based checks where relevant.

DIY with Playwright (Node.js)

This example captures a full-page screenshot after the page reaches a usable state. Install Playwright and its browser once, then save the following as capture.mjs:

npm install playwright
npx playwright install chromium

import { chromium } from 'playwright';

const url = process.argv[2] ?? 'https://example.com';
const browser = await chromium.launch({ headless: true });
try {
  const page = await browser.newPage({ viewport: { width: 1440, height: 900 }, deviceScaleFactor: 1 });
  await page.goto(url, { waitUntil: 'networkidle', timeout: 60_000 });
  await page.screenshot({ path: 'accessibility-review.png', fullPage: true });
} finally {
  await browser.close();
}

Run it with node capture.mjs https://your-site.example. Replace the sample URL with a page you are authorised to review. Some sites maintain long-lived network connections, so networkidle may not occur; use domcontentloaded and wait for a specific selector or a short, justified delay for those pages. For authenticated pages, use a controlled test account and protect any saved browser state and screenshots that may contain personal or confidential information.

DIY with cURL, Python, or Node.js using ScreenshotNeo

If you need a screenshot artifact without installing and maintaining a browser locally, ScreenshotNeo provides a website screenshot API and MCP server. Use its API documentation for request parameters and account setup. Keep your access key out of source control and logs.

Or skip the browser setup

One GET request can return a screenshot. The example below saves the response as WebP; adapt the target URL to the page you are reviewing. Use an API key from your account and follow the ScreenshotNeo docs for available output and capture options.

cURL

curl -G "https://api.screenshotneo.com/v1/shot" \
  -d access_key=YOUR_API_KEY \
  --data-urlencode url=https://example.com \
  -o shot.webp

Python

import requests

r = requests.get(
    "https://api.screenshotneo.com/v1/shot",
    params={"access_key": "YOUR_API_KEY", "url": "https://example.com"},
    timeout=90,
)
r.raise_for_status()
with open("shot.webp", "wb") as image_file:
    image_file.write(r.content)

Node.js

const q = new URLSearchParams({
  access_key: 'YOUR_API_KEY',
  url: 'https://example.com'
});
const res = await fetch(`https://api.screenshotneo.com/v1/shot?${q}`);
if (!res.ok) throw new Error(`Screenshot request failed: ${res.status}`);
await import('node:fs/promises').then(fs => fs.writeFile('shot.webp', Buffer.from(await res.arrayBuffer())));

ScreenshotNeo accepts cookie and consent banners as a visitor would and removes more than 60 known consent platforms, newsletter popups, and chat widgets before capture; each step can be turned off. Bot checks and CAPTCHAs, blank pages, timeouts, failed loads, and cache hits are not billed, and response headers report the page verdict and billing status. Its MCP server provides take_screenshot, get_page_info, and capture_pdf for Claude, Cursor, and other MCP clients. The free plan includes 1,000 shots per month with no card; paid plans start at $5 for 3,000 shots. These captures support visual review and evidence collection, not a standalone legal compliance decision.

8. Common mistakes and how to avoid them

Mistake	Why it fails	Better next step
Assuming every website is covered	The Directive lists defined products and services; a website alone does not determine scope.	Assess the service, consumers, definitions, and national rules.
Assuming only online shops are covered	Other defined services may use websites or mobile services as part of delivery.	Check the full service list and the actual service model.
Treating 28 June 2025 as a general grace-period start	The application date has passed, and transitions have defined contexts.	Check whether a particular transition applies to your facts.
Calling any small business exempt	The service-provider exemption is specifically for microenterprises under the relevant definition.	Verify the definition, service status, and national implementation.
Relying on an overlay or one scan as proof	The legal requirements are functional; a single tool is not established as a complete determination.	Use multiple evaluation methods and retain evidence of fixes and retests.
Quoting another country’s fine	Authorities, amounts, complaints, and remedies depend on national law.	Consult the current rules in the Member State relevant to the service.

9. Performance, reliability, and cost of the review process

Scope analysis and accessibility evaluation take time in proportion to the service’s features, journeys, and markets. Start with the journeys that deliver the core consumer service, then expand to supporting flows. Automated checks can be repeated efficiently after releases, while manual and assistive-technology review remains necessary to understand user impact and verify behavior.

For screenshot capture, full-page images are larger and take longer to render and store than a single viewport. Wait for the content relevant to the review rather than an arbitrary long delay; avoid network-idle waits on applications with persistent connections. Store captures securely, use consistent viewport settings for comparisons, and avoid including personal data where possible. Screenshot cost varies by the capture approach and volume; ScreenshotNeo offers 1,000 monthly shots free without a card, then plans from $5 for 3,000, with all features on every plan. Yearly billing gives two months free. A screenshot does not replace accessibility evaluation.

10. FAQ

Does the EAA apply to my website?

It depends on the service the website provides, whether it is provided to consumers, the Directive’s definitions, and applicable national law. Website ownership by itself does not answer the question.

Does the EAA require every site to pass one particular automated test?

The cited sources do not establish one automated test as a complete compliance determination. Identify the requirements that apply to the service and evaluate them with suitable methods.

Can a microenterprise ignore all accessibility obligations?

The Directive exempts microenterprises providing services from its accessibility requirements and related obligations, but the statutory definition and national rules need to be checked. It is not a blanket exemption for every small company or product operator.

Where do I find the applicable fine?

Check the current implementing law and enforcement authority in the relevant Member State. The Directive does not set one EU-wide fine amount in the provisions summarized here.

Sources and next steps

Start with the primary legal text: Directive (EU) 2019/882 on EUR-Lex. Use it alongside the implementing law and competent-authority guidance for each market. The Directive sets the framework; a site-specific scope and compliance conclusion depends on the service and facts.