Accessibility from June 28: a website checklist

On June 28, 2025, the European Accessibility Act, Directive (EU) 2019/882, starts to apply. For websites and apps that sell online to consumers, the technical benchmark is WCAG 2.1 at level AA. That leaves almost four months. Below is a list you can work through yourself in an afternoon to see how far you have to go.

First: does it apply to you?

The directive covers, among other things, e-commerce, consumer banking, e-books and passenger transport. Microenterprises providing services are exempt. A purely informational website with no sales isn't on the list. We explained who's covered, who's exempt and how the directive was written into Romanian law in our September post.

If you run an online store, paid bookings or an app where people buy something, and you're above the microenterprise threshold, the list below is for you. If not, it's still worth going through: the same rules make a site easier to use on a phone, in bright sunlight or for an older visitor.

Why WCAG 2.1 AA

The harmonized European standard EN 301 549 (version 3.2.1, March 2021) states that web content conforming to WCAG 2.1 Level AA meets its web requirements. That's where the benchmark comes from.

W3C has since published WCAG 2.2, with a few new criteria, such as a minimum size for tap targets and logins that don't rely on memory tests. If you're rebuilding your site now, it's worth covering those too. For compliance, the benchmark is still 2.1 AA.

The checklist

Each line has its WCAG 2.1 criterion number, so you can look it up.

Page structure

• Every page has a title that says what's on it (2.4.2).
• The page language is declared in the code (3.1.1). For an English site, lang="en".
• Headings and lists are marked up in the code as headings and lists. Big bold text isn't enough (1.3.1).

Images and video

• Images that carry information have alt text (1.1.1). For a product: what's in the photo, not "image1."
• Purely decorative images have empty alt text, so screen readers skip them.
• Videos with speech have captions (1.2.2).

Color and reading

• Regular text has a contrast ratio of at least 4.5:1 against its background (1.4.3).
• Buttons, field borders and important icons have a contrast ratio of at least 3:1 (1.4.11).
• Text can be enlarged to 200% without losing content (1.4.4).
• The page reads at 320 px wide without horizontal scrolling (1.4.10). In practice, on a small phone.

Keyboard

• Everything you can do with a mouse can be done with the keyboard alone: the menu, filters, cart, checkout (2.1.1).
• You can always see where you are when you press Tab (2.4.7). If the design hid the focus outline, that's the first fix.

Forms

• Every field has a clear label or instruction (3.3.2).
• When something is wrong, the error is described in text next to the field. A red border alone doesn't say what's wrong (3.3.1).

The one-afternoon test

1. Put the mouse away. Starting from the homepage, use only Tab, Enter and the arrow keys to get all the way to a submitted order.
2. Zoom the browser to 200% and do it again.
3. Open the site on the smallest phone you can find.
4. Check the contrast of your main colors with a contrast checker.
5. Go through your product photos and look at their alt text.

W3C has a set of quick checks, "Easy Checks," on the same topics: page title, alt text, headings, contrast, resizing, keyboard, forms. W3C is clear that they catch only some issues and that a page can pass them and still have serious barriers. They're a starting point, not an audit.

The accessibility page

The law asks for more than correct code. A service provider has to explain publicly how the service meets the accessibility requirements, in an accessible form, for as long as the service runs. The directive says this information goes in the general terms and conditions or an equivalent document, and includes a description of the service and how the requirements are met. In practice: a clear page, linked from the footer and from your terms.

If you'd like a full audit with a report per criterion, see what we do on our web services page.