Can everyone use your website? Accessibility, the law and a five-minute test
Since June 2025 many websites in the EU have to be usable by people with disabilities. Who that covers, what the rules ask for in plain words, and how to check your own site before anyone else does.
Adí Aviram
Law and money · · 8 min read

Imagine three visitors. One reads your opening hours on her phone at a bus stop in bright sun, and your pale grey text disappears. One cannot use a mouse and moves through pages with the Tab key, and your contact form never lets him reach the send button. One is blind and listens to your page through a screen reader, which announces "image, image, link, image" and nothing else. All three leave. In the EU, for a lot of businesses, that is now also a legal problem.
This is the second post in our law and money series, after the one on cookie banners. Same rules as last time: plain language, sources at the bottom, and no legal advice.
Who this is about
More people than most site owners assume. According to Eurostat, 23.9% of people aged 16 and over in the EU reported a disability in 2024. Add everyone who is older and finds small text hard, everyone with a broken wrist or a sleeping baby on one arm, everyone on a cheap phone in direct sunlight, and accessibility stops looking like a niche. It is the difference between a site that works for most people on a good day and one that works for everybody.

What the law says
The European Accessibility Act, Directive (EU) 2019/882, has applied since 28 June 2025. For websites, the part that matters is e-commerce: services provided at a distance, through websites and apps, where consumers conclude a contract online. In practice that means online shops, booking and ticketing, banking, e-books, and similar services sold to consumers. Each EU country has written the directive into its own law. In Germany it is the Barrierefreiheitsstärkungsgesetz, which allows fines of up to €100,000; competitors and associations can also send warning letters, the same mechanism behind the Google Fonts ruling.
There is an exemption. Micro-enterprises that provide services, meaning fewer than ten employees and no more than €2 million in annual turnover or balance sheet total, do not have to comply. The exemption is narrower than it sounds: it covers services, not products, and a business that grows past either line is in. Public sector websites have had their own rules for years, under a directive from 2016.
The technical yardstick is the European standard EN 301 549, which for websites incorporates the Web Content Accessibility Guidelines, WCAG 2.1 at level AA. The current version of the guidelines is WCAG 2.2, published in 2023, and a new edition of the standard based on it was published in September 2026. Building to 2.2 AA today covers both.
What WCAG asks for, in plain words
The guidelines are long, but most of what goes wrong on small sites comes down to a short list.
- Text you can read. Normal text needs a contrast ratio of at least 4.5 to 1 against its background, large text at least 3 to 1. Pale grey on white is the classic failure, and so is white text on a busy photo.
- Images that say what they show. Every image that carries information needs a short text alternative. A photo of your shop front is "Our shop on Main Street, blue door". A decorative swirl gets an empty one, so it is skipped.
- Everything works with a keyboard. Menus, forms, sliders and pop-ups must be reachable with Tab and usable with Enter, and you must be able to see where you are.
- Forms that explain themselves. Every field has a visible label, and an error message says what is wrong ("Please enter a date after today"), not just that something is.
- Structure the machine can read. Real headings in a logical order, the page language set, links that say where they go instead of "click here".
- Nothing by colour alone. "Required fields are in red" fails for anyone who cannot see red. Add a word or a symbol.
- Room to grow. Text can be zoomed to 200% without the layout breaking, and videos have captions.
Contrast is the easiest one to check yourself, so here is a checker. Pick your text and background colours, or try the examples. The last one is our own sunshine yellow, which is exactly why we never set text in it on a light background.
Calculated with the WCAG formula. Level AA needs 4.5 : 1 for normal text and 3 : 1 for large text (about 24px, or 19px bold). AAA needs 7 : 1.
How most websites do
Badly, and getting worse. Every year WebAIM, a non-profit at Utah State University, runs an automated test on the home pages of the top one million websites. In the 2026 edition, 95.9% of home pages had detectable WCAG failures, with an average of 56.1 errors per page, up from 51 the year before. Low-contrast text was the most common problem, on 83.9% of pages. And six error types, all of them on the list above, made up 96% of everything found.
That last number is the encouraging part. Most accessibility problems are not exotic. They are the same handful of mistakes, repeated, and each of them is cheap to fix when a site is built and expensive to fix after a warning letter.
A five-minute test you can do today
You do not need special software to find the worst problems on your own site.
- Put the mouse away. Press Tab, again and again, from the top of your home page. Can you always see where you are? Can you open the menu, fill in the form and press send?
- Zoom to 200%. Press Ctrl and + (Cmd and + on a Mac) until the browser says 200%. Does the text still fit, or do things overlap and disappear?
- Listen to it. Turn on VoiceOver on an iPhone or TalkBack on Android and let your phone read your home page out loud. Do the images and buttons make sense when you cannot see them?
- Take it outside. Open your site on your phone in daylight. Whatever is hard to read there fails the contrast check too.

What a widget will not fix
You will see services that promise accessibility with one line of code: a small icon that opens a toolbar with bigger text and higher contrast. They change how the page looks on top. They do not change the code underneath, and the code is what a screen reader reads and what a keyboard moves through. A missing form label stays missing. The same goes for sites generated by AI tools or templates. They can look tidy and still fail half of the list above, because a model fills every gap with the most common choice, and the most common choice on the web is, as WebAIM shows, inaccessible. If you built your site with one, the five-minute test is worth more than any toolbar.
What to ask whoever builds your site
Four questions. Which WCAG level do you build to? Do you test with a keyboard and a screen reader, or only with automatic tools? Who writes the alternative texts for the images? And if the European Accessibility Act applies to my business, who writes the accessibility statement that explains how the site meets the requirements? If the answers come quickly and specifically, you are in good hands. If you are preparing for a new site anyway, add accessibility to the list you bring to the first call.
Sources
- Taylor Wessing: European Accessibility Act, requirements for e-commerce services (2025)
- Köksal: EU Accessibility Act and Germany's BFSG
- European Platform for Rehabilitation: Eurostat disability data 2024
- Nexer Digital: The WebAIM Million report 2026, and the report itself at webaim.org
- W3C: Web Content Accessibility Guidelines 2.2
General information, not legal advice. Whether the Act applies to your business depends on what you sell and to whom; for your own situation, ask a lawyer.

Adí Aviram
Design, illustration and SEO at Frisun. Adí is a creative developer, designer and illustrator. She builds websites that tell a story: scrollytelling, data visualization, interactive maps and illustration. She has worked on projects with +972 Magazine, Göttingen University and the Goethe Institute. Adí brings the colour, the motion and the character to every site you get from Frisun. About the studio


