Website accessibility: the complete guide to WCAG, the EAA and the ADA

Website accessibility means that everyone can perceive, operate and understand your website, including people who are blind or partially sighted, who only use a keyboard or who find reading difficult. The technical benchmark for this is WCAG, the international guideline from the W3C. Since 28 June 2025, accessibility has also been a legal requirement in the EU for many online shops and other consumer services, through the European Accessibility Act.

This complete guide to website accessibility gives you the overview: which rules exist, who they apply to, what you need to do and how to check whether your site complies. Each part has its own in-depth article. We briefly explain technical terms, and you'll also find them in the glossary.

This page explains the rules; it is not legal advice. If you're unsure whether the law applies to your business, talk to a lawyer or check with the regulator.

#What is digital accessibility and who is it for?

Digital accessibility is the extent to which people with a disability can use a website, app or digital document independently. It's about more than blindness. Think of someone with a motor impairment who can't use a mouse, someone who is deaf and can't follow a video without captions, or someone with dyslexia who gets stuck in long, complicated texts.

The group is large. According to the World Health Organization, an estimated 1.3 billion people worldwide live with a significant disability, about 16 percent of the world's population, or one in six people. On top of that come people with a temporary impairment, such as a broken arm, and older people whose sight, hearing or motor skills are declining.

Many people with a disability use assistive technology. A screen reader reads the content of a page aloud or converts it to braille. Others magnify the screen, use voice control or navigate using only the Tab key. All of these tools only work well if the website is built properly from a technical point of view.

Accessibility also helps people without a disability. Captions are handy on the train, good colour contrast helps in bright sunlight and clear error messages in a form help everyone. That's why an accessible site is almost always a more user-friendly site too.

#Which rules and standards apply?

Four frameworks matter for website accessibility: WCAG as the technical guideline, EN 301 549 as the European standard, the EAA as European law and the ADA as US law. They refer to each other, but they are not the same thing. A guideline or standard describes what an accessible website looks like. A law determines who is obliged to follow it.

#WCAG: the technical benchmark

WCAG, short for Web Content Accessibility Guidelines, is the guideline from the World Wide Web Consortium (W3C) that describes when web content is accessible. Each version consists of testable success criteria at three levels: A (minimum), AA (the usual requirement) and AAA (the highest level). WCAG 2.2 is the latest version and became an official W3C Recommendation on 5 October 2023.

According to the W3C overview of what's new in 2.2, nine success criteria were added, six of them at level A or AA. Examples include a minimum size for click targets, a visible focus that doesn't disappear behind a sticky header, and logging in without a puzzle or memory test. The old criterion 4.1.1 (Parsing) has been removed. What this means for your site in concrete terms is covered in WCAG 2.2 explained.

#EN 301 549: the European standard

EN 301 549 is the European standard with accessibility requirements for ICT products and services, from websites to software and hardware. For web content, the standard adopts the WCAG success criteria at levels A and AA. The current harmonised version 3.2.1 refers to WCAG 2.1. According to the European Commission, the standard also contains requirements that are not in WCAG.

On 2 September 2026, ETSI published version 4.1.1, which refers to WCAG 2.2. A standard only gives a presumption of conformity once its reference has been published in the Official Journal of the EU (Article 15 of the EAA). That listing of version 4.1.1 is expected, but had not yet been published at the time of writing. Until then, version 3.2.1, which is harmonised under the European directive for public sector websites, is the usual benchmark. If you build to WCAG 2.2 level AA now, you also meet the WCAG 2.1 criteria, except for the removed criterion 4.1.1.

#The European Accessibility Act: the law in the EU

The European Accessibility Act, Directive (EU) 2019/882, requires businesses to make certain products and services for consumers accessible. Member states had to apply the rules from 28 June 2025 (Article 31). The Netherlands did this with the Implementatiewet toegankelijkheidsvoorschriften producten en diensten (the Dutch implementing act for accessibility requirements for products and services), which has applied since 28 June 2025. Since then, the requirements for e-commerce services have been set out in Title 2ab of Book 6 of the Dutch Civil Code (Articles 6:230fa to 6:230fd). Below you'll read what this means for websites and online shops.

A separate obligation already existed for public sector bodies. Under the Tijdelijk besluit digitale toegankelijkheid overheid (the Dutch temporary decree on digital accessibility for government), Dutch public sector bodies must make their websites and apps comply with EN 301 549. This guide focuses on businesses.

#The ADA: the law in the United States

The ADA, the Americans with Disabilities Act, is a US anti-discrimination law that also applies to what businesses offer online. The US Department of Justice writes in its web guidance that there is no regulation with detailed technical requirements for businesses, but it does name WCAG as helpful guidance. Further down you'll read what this means if you sell to US customers from Europe.

#What are the four principles of accessibility?

All WCAG success criteria fall under four principles: perceivable, operable, understandable and robust, abbreviated as POUR. The same four words appear in Annex I of the EAA, where the directive requires that websites of services covered by the law are made "perceivable, operable, understandable and robust". Once you understand the principles, you understand the logic behind each individual criterion.

1. Perceivable. Information must be perceivable in at least one way. Images get alt text, videos get captions and text has enough contrast with the background.
2. Operable. Everything you can do with a mouse must also be possible with a keyboard. The focus is visible, there are no time limits you can't extend and click targets are large enough.
3. Understandable. Text is clear, the language of the page is set, navigation works the same way everywhere and forms explain what went wrong and how to fix it.
4. Robust. The code is built so that browsers and assistive technology can interpret it reliably. Buttons are real buttons and custom components have the correct name, role and state, using WAI-ARIA where needed.

A handy rule of thumb: perceivable and understandable are mainly about content and design, operable and robust mainly about technology. So you need both your marketing team and your developer.

#What does the EAA mean for your website or online shop?

The EAA applies to services provided to consumers after 28 June 2025, and online shops are directly covered as e-commerce services. Article 2 of the directive lists, among others, electronic communications services, websites and apps for passenger transport, consumer banking services, e-books and e-commerce services. According to Article 3, an e-commerce service is a service provided at a distance, through a website or app, with which a consumer concludes a contract.

In concrete terms, an online shop, a booking site or a site where consumers take out a subscription is usually covered. A B2B online shop that only supplies businesses, or an informational site without online purchases, usually falls outside the e-commerce definition. In the Netherlands, the ACM supervises the accessibility of e-commerce services and electronic communications services. Other services, such as banking services, have other supervisory authorities.

#Exemptions and transition periods

Small businesses are exempt for services. Under Article 4(5), microenterprises that provide services do not have to meet the accessibility requirements. According to Article 3, a microenterprise has fewer than 10 employees and an annual turnover or balance sheet total of no more than 2 million euros. You must meet both conditions: with 8 employees and 3 million in turnover, you are not a microenterprise.

In addition, there are these exemptions and deadlines:

• Certain content (Article 2(4)). Pre-recorded audio and video and office files published before 28 June 2025, third-party content that you don't fund or control, and archives that are no longer updated after that date.
• Disproportionate burden (Article 14). You may choose not to apply a requirement if it would fundamentally alter your product or service or impose a disproportionate burden. You must document that assessment, keep it for five years and, as a service provider, redo it at least every five years.
• Transition period (Article 32). Service providers may continue to use products they were already lawfully using before 28 June 2030, and contracts agreed before 28 June 2025 may run for no more than five years. Note: under Article VIII(4) of the Dutch implementing act, this transitional provision does not apply to e-commerce services.

For an online shop in the Netherlands, the practical conclusion is therefore: if you're not a microenterprise, the requirements already apply now. We discuss the European Accessibility Act situation by situation in a separate article, with the considerations for each type of business.

#What goes into an accessibility statement?

An accessibility statement is a public text in which you explain how accessible your website or service is, which parts don't comply yet and how people can report a problem. For public sector bodies, such a statement has been mandatory for years. For businesses under the EAA, a related obligation applies.

Annex V of the directive states that a service provider must include in its general terms and conditions "or equivalent document" how the service meets the accessibility requirements. That information contains a general description of the service in an accessible format, an explanation of how the service works and a description of how the service meets the requirements of Annex I. Under Article 13, you must keep that information available for as long as the service is in operation.

In practice, many businesses publish a separate page for this and link to it from the footer and the terms and conditions. A good statement is honest about known issues and gives a contact address. How to approach this, with a template, is covered in writing an accessibility statement.

#How do you test whether a website is accessible?

You test accessibility with a combination of automated scans and manual checks, because no single tool can assess every WCAG criterion. A scanner can see whether an image has alt text, but not whether that text is accurate. It can see whether a field has a label, but not whether you can complete the form without a mouse.

Automated tests are fast and repeatable. The best-known testing library is axe-core from Deque, which has rules for WCAG 2.0, 2.1 and 2.2. Deque writes in its documentation that axe-core finds on average 57 percent of WCAG issues automatically. That figure comes from the maker itself. In addition, the tool marks part of its results as incomplete, which require a manual check.

You test manually with, among other things, the keyboard, a screen reader such as NVDA or VoiceOver, and by viewing the page at 200 percent zoom. For a formal audit, you hire a specialist. A workable testing approach for your own team is set out in testing website accessibility.

#Which accessibility errors are most common?

Most accessibility problems are not exotic edge cases, but a handful of basic errors that recur on many pages. Because they often sit in a template, a single change fixes them for the whole site. The WebAIM Million 2026 shows how widespread they are: an automated test found WCAG failures on 95.9 percent of the one million home pages analysed. These are the errors we come across most often:

• Images without alt text, or with meaningless text such as "image1.jpg".
• Too little contrast between text and background, especially with light grey text and text on photos.
• Form fields without an associated label, where only a placeholder explains what to enter.
• Links and buttons without text, such as a shopping cart icon without an accessible name.
• A messy heading structure, where headings are chosen for font size rather than meaning.
• No language set on the page, so a screen reader reads the text with the pronunciation of the wrong language.
• Elements you can't reach with the keyboard, or a focus that is invisible.
• Video or sound that starts playing automatically.

Each error comes with a concrete fix and a success criterion. We work these out in most common accessibility errors.

#Why do forms and the checkout deserve extra attention?

Forms and the checkout are where an accessibility problem costs you revenue directly, because a customer who gets stuck can't complete the order. It is also exactly the part the EAA touches for e-commerce services: concluding a contract.

An accessible form has a visible, associated label for every field. Required fields are recognisable as such, not just by a red colour. Error messages appear next to the field, explain what is wrong and are read out by a screen reader. WCAG 2.2 added two criteria here: you don't ask again for information the customer has already provided, and logging in must not depend on a cognitive test such as a puzzle.

Also watch out for third-party components in your checkout, such as payment windows and address autocomplete. If you choose an external payment module yourself, it is still your service. How to tackle this step by step is covered in accessible forms and checkout.

#Does a European business have to comply with the ADA?

A European business can be affected by the ADA if it actively targets US consumers, but whether the law applies in a specific case is ultimately decided by a US court. Title III of the ADA applies to businesses open to the public, such as shops and service providers. According to the US Department of Justice, the goods and services such a business offers online are also covered by the ADA.

There is no fixed technical standard for businesses. The department names WCAG and the Section 508 standards as helpful guidance. For US state and local governments it's different: the 2024 Title II rule prescribes WCAG 2.1 level AA, with deadlines that were moved in April 2026 to April 2027 and April 2028. That rule does not apply to private businesses.

The good news: if you meet WCAG 2.2 level AA for the EAA, you also cover the guidance used in the US. In ADA compliance for European businesses you'll read when the ADA becomes relevant and what you then need to arrange on top.

#How does accessibility overlap with SEO and GEO?

Accessibility and findability overlap heavily, because search engines and AI systems read a page the same way assistive technology does: through the HTML structure and the text, not through the visual design. A screen reader and a crawler both benefit from a logical heading structure, descriptive link text and a correctly set language.

Three elements count twice:

• Semantic HTML. Real headings, lists, tables, buttons and navigation elements make the structure of a page unambiguous. That helps a screen reader, and it helps an AI system find the right passage.
• Alt text. Good alt text describes what an image shows or means. Search engines use that text to understand images.
• Headings and clear text. Headings that say what a section is about and paragraphs that start with a clear statement make a text understandable for people and easier for AI to quote.

Don't overstate the effect. Accessibility is not a ranking trick, and an accessible site doesn't automatically rank higher in Google or ChatGPT. It does give you a better technical foundation. How that foundation contributes to visibility in AI answers is covered in our complete guide to GEO and in the article on content that AI cites.

#Action plan: how to make your website accessible

You don't build an accessible website in one sprint, but in a fixed order: first determine what applies, then measure, then fix the biggest problems and then keep it that way. This action plan works for most online shops and company websites.

1. Determine which rules apply to you. Check whether you provide a service covered by the EAA, whether you are a microenterprise and whether you target US customers. Record that assessment.
2. Choose your target level. Use WCAG 2.2 level AA as your benchmark. That covers the WCAG criteria that EN 301 549 adopts for web content and the usual guidance under the ADA.
3. List your most important pages. Start with the home page, a category page, a product page, the shopping cart, the checkout, the contact form and the login. That's where the revenue is, and that's where the templates are.
4. Run an automated scan. Use a tool based on axe-core for a first list of errors per page, sorted by severity.
5. Test manually. Go through each key page using only the keyboard and with a screen reader, check the contrast and view the page at 200 percent zoom.
6. Fix it in the templates. Solve errors where they originate: in the theme, the components and the forms. One fix in a template improves hundreds of pages.
7. Improve the content. Write alt text, put headings in a logical order, make link text descriptive and provide captions for video.
8. Publish your accessibility statement. Describe how your service meets the requirements, what doesn't work well yet and how people can get in touch. Link to it in the footer and the terms and conditions.
9. Embed the process. Add accessibility to the checklist for every new page, campaign and plugin. Scan again periodically, because every update can introduce new errors.
10. Document exemptions. If you rely on disproportionate burden, record that assessment in writing and review it at least every five years, as Article 14 of the EAA requires.

#How to check this on your own site

You can get a first picture of your website's accessibility yourself in half an hour. Take one product page and your checkout and go through these steps:

1. Press Tab from the top of the page. Can you always see where the focus is? Does a "Skip to content" link (a skip link) appear first? Can you add a product to the cart and check out without a mouse?
2. Look at the source code. Is there lang="en" on the html element? Does every image have an alt attribute? Is there exactly one H1, and do the headings follow a logical order?
3. Check your forms. Click the text next to a field: does the cursor move into the field? Then the label is associated. Submit the form empty and see whether the error messages clearly explain what's wrong.
4. Measure the colour contrast. Use a contrast checker or your browser's developer tools. According to WCAG level AA, normal text needs a contrast ratio of at least 4.5 to 1.
5. Find your accessibility statement. Is there a link to a statement in the footer, and does what it says still match the current site?
6. Watch out for autoplaying sound. Does audio or video with sound start anywhere without the visitor asking for it? Then it must be possible to pause or stop it.
7. Run an automated scan on your most important pages and deal with the highest-severity errors first.

Flowproof's accessibility check is included in the paid Pro and Business plans. It tests your pages with axe-core against WCAG 2.0, 2.1 and 2.2 levels A and AA, showing the success criterion, level and severity for each error. It also checks whether there is a link to an accessibility statement, a skip link and autoplaying sound. The scan honestly reports colour contrast as something to check manually, because that requires an actual rendering of the page. If your page only builds its content with JavaScript, you'll get a warning about that. You can start for free or compare plans.