Accessibility Law: EU and UK

About Octopus Scanner

What the European Accessibility Act and UK accessibility law ask of websites and apps, who they apply to, the standard to aim for and where an automated scan fits in.

This isn't legal advice. It's a plain-English summary of the main rules, with links to the official texts. Whether a law applies to you, and what it asks of you, depends on your circumstances and on how each country has put the rules into its own law. If you're unsure, speak to a legal adviser or the regulator in the country concerned.

1. At a glance

  • European Union: The European Accessibility Act applies to many consumer products and services sold in the EU, including e-commerce, consumer banking, e-books and parts of passenger transport, from 28 June 2025.
  • United Kingdom: The Equality Act 2010 requires service providers to make reasonable adjustments for disabled people. Public sector websites and apps must also meet WCAG 2.2 Level AA and publish an accessibility statement.
  • A sensible target: WCAG 2.2 Level AA covers what both regimes point to for websites and apps.
  • Automated testing helps, but isn't enough on its own: A scan finds many technical problems quickly. Meeting the law also needs testing by hand and, in the EU, published information about how your service meets the requirements.

2. The European Accessibility Act

The European Accessibility Act is Directive (EU) 2019/882. Each EU country had to turn it into national law by 28 June 2022 and apply it from 28 June 2025. The rules, penalties and enforcement bodies are set by each country, so the details differ from one country to the next.

What it covers

Services provided to consumers after 28 June 2025, including:

  • E-commerce: Websites and mobile apps used to sell to consumers at a distance.
  • Consumer banking services
  • E-books and the software used to read them
  • Electronic communications services, such as telephony
  • Services giving access to audiovisual media, such as television
  • Air, bus, rail and waterborne passenger transport: Websites, mobile apps, electronic tickets, travel information and interactive self-service terminals. For urban, suburban and regional transport, only the self-service terminals are covered.

Products placed on the market after 28 June 2025, including consumer computers and their operating systems, smartphones and similar devices, e-readers, payment terminals and self-service terminals such as cash machines, ticket machines and check-in machines.

Who it applies to

  • Businesses selling to consumers in the EU: The Act defines a service provider as anyone who provides a service on the EU market or offers it to consumers in the EU. A business based outside the EU, including in the UK, can be covered if it offers an in-scope service to consumers in the EU.
  • Microenterprises providing services are exempt: A microenterprise employs fewer than 10 people and has an annual turnover, or an annual balance sheet total, of no more than 2 million euros. The exemption covers services only, not products.
  • Disproportionate burden: The requirements apply only to the extent that they don't fundamentally change a product or service or place a disproportionate burden on the business. A business relying on this must assess and document it.

Website content that isn't covered

The Act doesn't apply to some website and app content, including pre-recorded audio and video and office documents published before 28 June 2025, third-party content the business doesn't fund, develop or control, and archived content that isn't updated or edited after 28 June 2025.

Transition periods

  • Until 28 June 2030: Service providers may keep providing their services using products they were lawfully using before then.
  • Existing contracts: Service contracts agreed before 28 June 2025 may continue unchanged until they expire, but no later than 28 June 2030.
  • Self-service terminals: Countries may allow terminals in use before 28 June 2025 to stay in use until the end of their economically useful life, up to 20 years after they entered use.

Information you must publish

Service providers must explain how their service meets the accessibility requirements, usually in their general terms and conditions or an equivalent document. The information must be available in accessible formats and kept for as long as the service runs.

3. EN 301 549, the European standard

EN 301 549 is the European standard for the accessibility of information and communication technology. Meeting a harmonised standard cited in the EU's Official Journal is the usual way to show that a product or service meets the requirements.

  • The version currently cited: Version 3.2.1, which is based on WCAG 2.1 Level AA for websites, software and documents.
  • The newest version: Version 4.1.1, published in September 2026, adopts WCAG 2.2 Level AA. According to AccessibleEU, it isn't yet the legal reference for the European Accessibility Act. That changes when the European Commission cites it in the Official Journal.
  • More than web content: EN 301 549 also covers hardware, software with closed functionality, two-way communication and documentation, which WCAG doesn't.

4. The United Kingdom

The UK left the EU before the European Accessibility Act had to be in national law, so it isn't UK law. UK businesses that sell in-scope services to consumers in the EU still need to consider it.

The Equality Act 2010

Under section 29 of the Equality Act 2010, a service provider must not discriminate against disabled people and has a duty to make reasonable adjustments. This applies in England, Scotland and Wales. The Act doesn't name a technical standard, but WCAG is widely used to show what an accessible website looks like. In Northern Ireland, the Disability Discrimination Act 1995 applies instead.

Public sector websites and apps

The Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 apply to public sector bodies and to some charities and other organisations, for example those mostly funded by the public sector. According to GOV.UK's guidance, they must:

The Government Digital Service monitors a sample of sites each year. The Equality and Human Rights Commission enforces the rules in England, Scotland and Wales, and the Equality Commission for Northern Ireland in Northern Ireland.

5. Which standard to aim for

For websites and apps, WCAG 2.2 Level AA is a sensible target in both the EU and the UK. It includes everything in WCAG 2.1 Level AA, which the currently cited version of EN 301 549 is based on, plus the newer criteria that the latest version of EN 301 549 and the UK public sector rules now expect. Meeting WCAG 2.2 Level AA on its own may not cover everything EN 301 549 asks for outside web content.

6. Where an automated scanner helps

Octopus Scanner checks whole websites against WCAG 2.2 using the axe-core engine, on your own computer. It also offers an EN 301 549 rule set under Axe Tags. It's a quick way to find and track the problems code can detect, such as missing text alternatives, unlabelled form fields and low contrast.

  • What it can do: Find many technical failures across a whole site, show where they are and give developers ready-made tickets.
  • What it can't do: Confirm that a site meets WCAG, EN 301 549 or any law. Many success criteria need human judgement, such as whether alt text is meaningful or whether a page can be used by keyboard alone. Scope of Automated Testing explains the limits.

No automated tool, including Octopus Scanner, can make a website compliant or certify that it is.

7. Practical steps

  1. Find out what applies to you: Check whether you provide an in-scope service to consumers in the EU, whether you're a public sector body in the UK and whether you qualify for any exemption.
  2. Scan your website: Run a scan against WCAG 2.2 Level AA to find the technical problems. See Your First Scan.
  3. Fix what the scan finds: Start with the most serious issues and shared components that repeat across pages. See After Your Scan.
  4. Test by hand: Check keyboard use, screen reader output, meaningful text alternatives and the other things no tool can confirm.
  5. Publish your accessibility information: An accessibility statement for UK public sector bodies, or information on how your service meets the requirements for the European Accessibility Act.
  6. Keep records: Save your reports, what you fixed and when, and any disproportionate burden assessment. Re-scan after changes to catch new problems.

8. Official sources

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