The accessibility law most UK businesses think does not apply to them

An EU law that reaches UK businesses

If you sell online and some of your customers are in the European Union, there is a rulebook that applies to you which most UK business owners have never been told about.

The reasoning is straightforward once you see it. The European Accessibility Act attaches to the market being served, not to where the seller is registered. Leaving the EU changed who writes the rules for British companies, not whether British companies have to follow the rules of markets they sell into.

It came into force on 28 June 2025. Which makes 2026 the first full year in which national authorities are supervising against a deadline that has already passed.

Who this actually catches

The Act covers a defined list of digital services rather than everything online. In practice the ones that matter to a smaller business are ecommerce, online banking, ticketing, transport and travel booking, and the websites and mobile apps used to deliver them.

If you take orders or bookings from consumers in the EU through your own site or app, assume you are in scope until you have checked otherwise.

Selling only to other businesses changes the picture, since the obligations are framed around consumers. So does selling exclusively through a marketplace that owns the checkout, although that shifts the obligation rather than removing your commercial exposure to it.

The exemption most people get wrong

There is a genuine exemption for micro enterprises, and it is narrower than the version circulating in blog posts.

You qualify if you have fewer than 10 employees and an annual turnover or balance sheet total at or under 2 million euros. Both conditions, not either.

The exemption covers services. It does not cover products, so a business that manufactures or distributes physical products with a digital component can be exempt as a service provider and still carry obligations elsewhere in the chain.

Two more details worth knowing. The exemption falls away the moment you outgrow it, with no grace period to adjust. And it does not apply if you have taken funding specifically for accessibility improvements.

The dates

New services launched on or after 28 June 2025 were expected to comply from the day they launched.

Services already running before that date get a transition period that runs to 28 June 2030. That sounds generous, and it is, but it is worth reading carefully: it applies to services already in existence, not to the redesign you launch next spring.

The practical implication is that a rebuild is the moment this becomes unavoidable. Anything new starts life in scope.

What compliance actually means

The technical reference is the harmonised European standard EN 301 549, which is built on the Web Content Accessibility Guidelines at level AA. Advisers differ on which version of the guidelines to work to, and the safe move is to build to the most recent one rather than the minimum.

Stripped of the standards language, most of it is a short list of ordinary things.

• Every image that carries meaning has a text description, and decorative ones are marked so screen readers skip them.
• Every form field has a label that stays visible, not just placeholder text that vanishes when you type.
• Text has enough contrast against its background to be read in daylight.
• The whole site works with a keyboard alone, and you can see which element is focused as you tab through it.
• Error messages say what went wrong and how to fix it, and do not rely on colour alone to communicate.
• Video has captions.

That list will get you most of the way. The remainder is usually custom components, a date picker, a modal, a bespoke dropdown, that were built without keyboard support.

What happens if you ignore it

Enforcement sits with national authorities in each member state rather than with a single European regulator, and the penalties vary accordingly.

The tools available to them include administrative fines, mandatory corrective measures, and requiring a non compliant service to be withdrawn from the market . There is also a procurement consequence, since non compliant suppliers can be excluded from EU public sector contracts.

For a small UK business the realistic risk is not a dramatic fine arriving unannounced. It is a complaint, followed by correspondence with a regulator in a language you do not speak, at a cost in time that dwarfs what the fixes would have cost.

The part nobody mentions

Accessibility work is not only a compliance exercise, and treating it purely as one leads to the worst version of it, which is an overlay widget bolted on to a site that remains unusable underneath.

Almost every fix on that list helps people well beyond the group it was written for. Captions get used on silent commutes and in noisy cafes. Contrast helps everyone reading outdoors. Clear labels and useful error messages reduce failed checkouts for people with no impairment at all.

There is also a straightforward commercial reading. A checkout that cannot be completed with a keyboard is a checkout that some proportion of your visitors abandon, and you will never see those people in your analytics as anything other than a drop off you assumed was disinterest.

What this costs in practice

The number people fear is the number for a full audit and remediation of a large, old, complicated site. That is not most small businesses.

For a site built in the last few years on a mainstream platform, the mechanical failures tend to be concentrated and repetitive. The same missing label appears on every form because every form came from the same template, so fixing it once fixes it everywhere.

The expensive version is the one where accessibility is treated as a bolt on at the end of a redesign, because by then the decisions that caused the problems, a colour palette with poor contrast, a custom component nobody can tab through, are baked into everything.

Which is the real argument for raising it early. As a design constraint it costs close to nothing. As a repair job it costs whatever the repair costs.

A sensible first pass

Start with an automated scan to find the mechanical failures, missing alt text, low contrast, unlabelled fields. Free tools catch a meaningful share of the total and cost you nothing but an hour.

Then do the keyboard test yourself. Put the mouse away and try to complete your own most important journey, whether that is buying, booking or signing up. Most sites fail this within about ninety seconds, and the failure is usually one component rather than the whole design.

Then fix in order of how many people hit the problem, which almost always means checkout and forms before marketing pages.

The UK has its own duties around reasonable adjustments under the Equality Act 2010, so this work is rarely wasted even for a business with no EU customers at all.

If you would rather not guess

We build web apps and websites, and accessibility is cheaper to design in than to retrofit, which is the main reason it is worth raising before a rebuild rather than after one.

If you want an honest read on whether this applies to you and what a first pass would involve, book a free 15 minute consultation or email info@kerenlabs.com .