Since June 28, 2025 the European Accessibility Act (EAA) has been fully in force for private-sector websites and apps across Europe. It applies to all companies offering services to consumers — with an exemption only for microenterprises (fewer than 10 employees AND less than €2M revenue).
In 2026 most SMBs with an e-commerce site or booking app have binding accessibility obligations. In this guide we cover what WCAG 2.2 requires, what changed from 2.1, and the concrete risks of non-compliance.
WCAG 2.2 accessibility: what's new vs the previous version
WCAG 2.2 (October 2023) adds 9 new success criteria. The most relevant for business sites:
- 2.4.11 Focus Appearance: keyboard focus must be visible with minimum 3:1 contrast. Eliminates the invisible focus problem common in sites with aggressive CSS resets.
- 3.2.6 Consistent Help: if a support mechanism exists (chat, phone, FAQ), it must appear in the same position on every page.
- 3.3.7 Redundant Entry: in multi-step flows (e.g. checkout), users must not re-enter data already provided.
- 3.3.8 Accessible Authentication: cognitive puzzle CAPTCHAs are prohibited without an accessible alternative. Magic links, passkeys and audio CAPTCHAs are allowed.
Who the EAA applies to in 2026
Any private company offering products or services to EU consumers via website or app, except microenterprises. In practice: B2C e-commerce with >€2M revenue or >10 employees, booking platforms, online banking, transport apps. B2B brochure sites are a grey area, but the reputational risk is real. Enforcement authority varies by country; fines can reach hundreds of thousands of euros for serious violations.
The 5 most common accessibility failures on business sites
- Insufficient colour contrast: light grey text on white background fails the required 4.5:1 ratio for WCAG AA.
- Images without alt text: decorative images need an empty alt attribute, informational ones need a descriptive alt.
- Forms without visible labels: fields with only placeholder text are not accessible to screen readers.
- Broken keyboard navigation: interactive elements unreachable by Tab or with invisible focus.
- Videos without captions: video content requires synchronised captions (AA) or a transcript (A).
How to do a quick audit
Free tools: WAVE (wave.webaim.org) for visual analysis, Axe DevTools Chrome extension, and Lighthouse built into Chrome DevTools. No automated tool covers 100% of WCAG criteria — only a manual audit with a screen reader (NVDA on Windows, VoiceOver on Mac/iOS) guarantees full coverage.
Conclusion
Web accessibility in 2026 is no longer an optional ethical choice: it's a legal obligation and a concrete sanction risk for most European companies.
Every site we build includes WCAG 2.2 AA accessibility as standard in our web services. If you want an audit of your current site, contact us via the quote form: the initial analysis is free. See accessible site examples in our portfolio.