You run a store, a software product or a booking service from India, and some of your customers are in Germany, France, the Netherlands or elsewhere in the EU. Then a distributor, a payment partner or a customer mentions the European Accessibility Act, and you are left wondering whether a European law can apply to a company in Kolkata, Pune or Bengaluru.
It can, depending on what you sell and who you sell it to. This post explains what the Act is, what it covers, where the exemptions are, and what an Indian business selling to European consumers should check on its website. It is general information, not legal advice. If the Act may apply to you, confirm the details with a lawyer familiar with the EU country you sell into.
What the European Accessibility Act is
The European Accessibility Act is an EU directive. Its aim is to make a set of everyday products and services usable by people with disabilities, and to replace a patchwork of national rules with common requirements across the EU market.
Because it is a directive rather than a regulation, each EU member state had to write it into its own national law. The core requirements are the same, but enforcement, penalties and some procedural details are set country by country, and are handled by national authorities. That is one reason the answer to “what happens if we do not comply” depends on where your customers are.
The Act has applied since mid-2025. There are transitional arrangements for some existing services and products, but new sites and services should be planned on the basis that it is already in force.
What it covers
The Act lists specific products and services rather than covering everything. On the product side it includes things such as computers and their operating systems, smartphones, self-service terminals like ATMs and ticket machines, payment terminals and e-readers.
On the services side it includes, among others:
- E-commerce services, meaning selling to consumers online through a website or app.
- Consumer banking services.
- E-books and the software used to read them.
- Electronic communications services, such as phone and messaging services offered to the public.
- Parts of passenger transport services, such as websites, apps and electronic tickets.
- Services giving access to audiovisual media, such as streaming.
For most Indian businesses reading this, e-commerce is the category that matters. If EU consumers can browse, choose and pay for something on your website or app, that buying journey is likely to be in scope. That applies whether you sell clothing, handicrafts, courses, or consumer subscriptions to a software product.
The Act is focused on consumers. A service sold only to other businesses is generally outside the e-commerce category, though the line can be less clear than it looks, for example when a sole trader buys the same plan as a consumer. This is one of the points worth checking with an adviser.
Being outside the EU does not take you out of scope
The Act is about the EU market, not about where a company is registered. If you offer a covered product or service to consumers in the EU, the requirements are aimed at you in the same way as at a European competitor. Selling through your own site, with prices in euros, shipping to EU addresses or marketing to EU customers are the kinds of signs that you are offering services there.
Your own website and app are where your responsibility is clearest, so that is where to start.
The microenterprise exemption
The Act includes an exemption for microenterprises that provide services. A microenterprise is defined as a business with fewer than 10 people and an annual turnover or balance sheet total of no more than 2 million euros. If you meet that definition, the service requirements do not apply to you.
Three cautions. The exemption is for services; the rules for microenterprises dealing in products are different and lighter, not absent. The way staff and turnover are counted follows an EU definition, which can include linked or partner companies, so a small Indian subsidiary of a larger group may not qualify. And growing past the threshold changes your position, so it is worth reviewing each year.
There is also a separate provision for cases where meeting a requirement would be a disproportionate burden or would fundamentally change the service. This is not a general opt-out. It needs an assessment, documented properly, and it is the kind of claim to make only with advice.
How it connects to EN 301 549 and WCAG
The Act itself describes accessibility requirements in functional terms, for example that information must be perceivable, operable and understandable, using the same four principles that WCAG is organised around. It does not spell out exactly how a web page must be coded.
The practical detail comes from standards. EN 301 549 is the European standard for the accessibility of ICT products and services, and it is already used under the EU’s separate directive for public-sector websites. Its requirements for web content are built on WCAG at Level AA. Work on standards tied specifically to the Act has been ongoing, but in practice WCAG AA is what businesses, auditors and authorities work to.
If WCAG is new to you, our post WCAG explained covers the principles, levels and versions in plain terms.
What to check on your website
If you sell online to EU consumers, these are the questions to work through.
- Are you in scope? Do you sell to consumers in the EU, and does what you sell fall into a covered category? Write down the answer and the reasoning.
- Does the microenterprise exemption apply? Check your headcount and turnover against the EU definition, including any linked companies.
- Can the whole buying journey be completed accessibly? Not just the home page. Search, product pages, filters, cart, account creation, checkout, payment and order confirmation should all work with a keyboard and a screen reader.
- What about third-party parts? Payment gateways, chat widgets, cookie banners, review plugins and booking tools sit inside your journey. If one of them cannot be used with a keyboard, the journey fails at that point. Ask the vendors what accessibility standard they work to.
- Do you publish accessibility information? Service providers are expected to explain how their service meets the accessibility requirements. Many businesses do this with an accessibility statement page, linked from the footer.
- Is there a way to report problems? A contact route that works for people who could not complete a purchase is sensible regardless of the law.
- Who keeps it accessible? New products, new plugins and theme updates can break things that passed last month. Someone needs to recheck.
Our website accessibility checklist covers the page-level checks, such as alt text, headings, contrast and form labels, that you can run yourself.
For WordPress and WooCommerce stores
Most of the effort on a WooCommerce or WordPress site goes into the theme and plugins, not the content. Product galleries, quick-view pop-ups, mega menus, variation selectors and one-page checkouts are common trouble spots. Sometimes a setting fixes it; sometimes the honest answer is to replace a component with one that was built accessibly. Be wary of overlay widgets that promise compliance by adding a script. They do not change the underlying markup that the requirements are about.
Accessibility is one part of a wider set of changes we cover in what a business website needs now.
If you are not sure where you stand
We do not offer a packaged EAA compliance service, and we cannot give legal advice. What we can do is look at your WordPress or WooCommerce site against WCAG AA and tell you plainly what is likely to need work. If that would help, tell us what you need.
Next in this series: Sending Website Leads Straight Into Zoho CRM
