The European Accessibility Act Is No Longer Optional

I’ll start with the first thing I do on every new website: I try to get through it without a mouse, and I look at the cookie banner. If the “Reject all” button is buried three clicks deep, I know enough — that product wasn’t built for people, it was built against them. That’s my professional tic, I admit it. But since June 28, 2025, this is no longer a question decided by my taste. It’s decided by law.

Because that’s the date the European Accessibility Act became applicable. It isn’t an industry buzzword or a blog trend — it’s Directive (EU) 2019/882 of April 17, 2019 on the accessibility requirements for products and services. It applies to products placed on the market after June 28, 2025, and to services provided to consumers after that date. And in case you’re tempted to file this under non-binding ambitions: Article 31 required member states to adopt their national rules by June 28, 2022 and to apply them from June 28, 2025. That’s the mechanics of a deadline, and it has already arrived.

What falls under it — and why that affects most marketing teams

The most common reflex I hear is: “Surely that only applies to a few specialty devices.” It doesn’t. The scope covers computers and operating systems, smartphones, ATMs, ticketing and check-in machines, TVs, e-readers, telephony services, consumer banking, e-books — and, the decisive point for you as a marketer, e-commerce. If you sell to consumers, chances are high that your store, your booking flow, or your banking front end falls within scope.

That’s exactly why the old argument annoys me so much. “Much of B2C” is not rhetorical exaggeration on my part — it simply describes the list written into the law. There are exceptions — microenterprises in the services sector, for one, and the usual proportionality clauses — and I don’t want to dramatize anything here that isn’t in the text. But if you run a normal consumer online store, don’t bet on being an exception.

For readers in the DACH region, here’s what that means concretely: Austria transposed the directive with its Accessibility Act (Barrierefreiheitsgesetz, BGBl. I Nr. 76/2023), in force since June 28, 2025 — the same date the EU set for all member states. Germany transposed it through a law of its own; I’m deliberately not quoting its sections from memory.

Accessibility is the opposite of dark patterns

This is where it gets personal for me, and it should. What makes me passionate about manipulative UX — the hidden unsubscribe button, the “Reject all” that only shows up after several clicks, the 3 extra fields in the checkout that nobody needs — is, at its core, the same thinking as an inaccessible interface. Both build friction against people who simply want to get something done. A dark pattern does it on purpose; a barrier often does it out of negligence. For the person in front of the screen, the difference doesn’t matter: they don’t get through.

That’s why I find something liberating in this regulation. Well-built accessibility is not a moral add-on draped over the UX. It is good UX. Clear structure, readable contrast, full keyboard operability, images that carry meaning instead of decoration — that helps everyone, not just people with a disability. Take it seriously, and along the way you build the kind of product I’d recognize as “built for people” in the first place.

Why this is not just compliance, but reach

Now for the part where I have to stay sober, even though I don’t want to. Ignoring accessibility means shutting people out — and not a fringe group. According to Eurostat, in 2024 nearly a quarter of people aged 16 or over in the EU — 23.9% — had a disability in the sense of an activity limitation. That is not a niche at the edge of your target audience. Those are potential customers who fail at a badly built interface before they ever get to your offer.

And the interfaces are bad. The 2026 WebAIM Million report ran automated checks on the home pages of the one million most-visited websites. The result: 95.9% showed detectable WCAG 2 failures. By far the most common single error was low text contrast, found on 83.9% of home pages. 16.2% of all images were missing alternative text — 10.8 such images per page on average. Across all pages, that added up to an average of 56.1 detected errors per home page, 56,114,377 in total.

Knowing these tests as I do, I have to add an honest caveat, or I’d be part of the problem: those are automatically detectable errors, and home pages only, not complete sites. So the real picture is likely worse, not better — automated testing is a floor, not a ceiling. But even the floor says it plainly: the obligation is here, and almost nobody meets it today.

The standard you will be measured against

If you want to know what “accessible enough” means technically, the answer is less mystical than many fear. The harmonized European standard is called EN 301 549, and its currently harmonized version (v3.2.1) adopts the Web Content Accessibility Guidelines 2.1 at levels A and AA for web content. In practice, WCAG 2.1 Level AA is the web benchmark you should build for.

Here’s a detail where I want to spare you unnecessary panic: WCAG 2.2 circulates in plenty of pitches as the supposedly new mandatory standard. As of the compliance date, that isn’t true. WCAG 2.2 has been published, but it has not yet been harmonized through a version of EN 301 549 referenced in the Official Journal of the EU. What’s binding today is 2.1 AA. Doing more hurts no one — but nobody should sell you WCAG 2.2 as a current legal obligation, because it isn’t one.

My blind spot — and what you gain from it

I wouldn’t be an honest voice if I hid my own slant. I see everything through an expert lens, and that is a strength and a weakness at once. My functionalist reflex likes to tell me beauty is secondary — as if aesthetics were mere garnish. That’s not the whole truth. Some products have to work emotionally before anyone uses them at all, and my yardstick would miss them. So treat my rigor as a useful tool, not as gospel.

What remains stands regardless, because it doesn’t depend on my taste — it’s written in the directive, in the Austrian law, in the standard, and in the numbers. Since June 28, 2025, accessibility has been mandatory for much of B2C. Build cleanly now and you lose nothing — you just get the interface that doesn’t lock out me, the 23.9%, or anyone else. Show me I can get through without a mouse. Then we’ll talk about the rest.