European Accessibility Act checklist for websites

The Act covers a list of products and services. For websites, the part that matters most is e-commerce: selling goods or services to consumers online. Banking services, e-books, passenger transport services and electronic communications are covered as well.

Service providers that are microenterprises are exempt: fewer than 10 staff and an annual turnover or balance sheet total of no more than 2 million euros. Selling only to other businesses also changes the picture, because the Act is about services for consumers.

Each member state applies the Act through its own law, for example the BFSG in Germany and the BaFG in Austria, with its own market surveillance and penalties. Whether your offer is in scope, and from when, is a question for your legal adviser; the rest of this guide is the technical side.

The Act describes the requirements in general terms. In practice a website is measured against the European standard EN 301 549, and for web content that standard points to WCAG 2.1 at level AA: content people can perceive, operate and understand, built so that assistive technology such as screen readers can read it.

Service providers also have to say how their service meets the requirements. Most do that with an accessibility statement on the website, linked from every page, together with a way to report barriers.

Put the mouse away and try your most important path, such as product page, cart and checkout, or the contact form:

• Every link, button, menu and form field can be reached with the Tab key and used with Enter or Space
• You can always see where the keyboard focus is
• You can leave every menu, pop-up and cookie banner with the keyboard, without getting stuck
• The order in which the focus moves follows the order of the page

Check what a person who cannot see the screen, or cannot hear the sound, gets from the page:

• Every image that carries information has a text alternative that says what it shows or does; purely decorative images are hidden from screen readers
• Videos with speech have captions, and audio has a transcript
• Nothing flashes more than three times per second, and moving content can be paused

Check that the text can be read by people with low vision or colour blindness:

• Body text has a contrast ratio of at least 4.5 to 1 against its background, and large text at least 3 to 1
• Information is never given by colour alone, for example a required field marked only in red
• The page still works with the browser zoomed to 200 percent, and on a narrow phone screen nothing needs scrolling sideways

Screen reader users move through a page by its structure, so the structure has to carry the meaning:

• Each page has a title that says what it is, and one main heading
• Headings follow a logical order, so a screen reader user can jump through the page by them
• The language of the page is set in the code, so text is read out with the right pronunciation
• Link and button texts make sense on their own: not five links that each say "click here"

This is where inaccessible sites lose orders from people who wanted to complete them:

• Every field has a visible label that stays visible while you type
• Errors are described in text, next to the field, with what to do instead
• Time limits can be turned off or extended
• The whole checkout, including the payment step and any confirmation code, works with the keyboard and a screen reader

The last two checks are documents, not code:

• An accessibility statement is published and linked from every page
• The statement names a way to report barriers, and someone answers those reports

Start with the keyboard pass above on your three most important pages. Then zoom to 200 percent and open the site on a phone. Finally, listen to one page with the screen reader built into your computer or phone: VoiceOver on Apple devices, Narrator on Windows, TalkBack on Android.

Automated checkers, such as the accessibility audit built into Chrome's developer tools, are a useful first pass: they find missing text alternatives, low contrast and missing labels quickly. They cannot tell whether a text alternative is meaningful or whether a checkout makes sense when read out, so a clean automated score is not conformance.

Fix the paths that earn money and answer customers first: checkout, booking and contact forms. Within them, keyboard access, form labels and error messages, and contrast usually make the largest difference.

An overlay script that adds a toolbar to the page does not change what the standard tests, and it does not change the experience of the people the law was written for. Findings are fixed in the code, or they are not fixed.

If you want the full measurement against EN 301 549 and WCAG 2.1 AA, with a prioritised report and fixed-price remediation, see our accessibility audits under the European Accessibility Act. Every new site we build carries the baseline: what every build includes.