European Accessibility Act (EAA): What online marketplace founders should know

Certain websites with customers in the European Union or European Economic Area will soon have to meet the accessibility requirements defined in the European Accessibility Act (EAA) (formally known as Directive 2019/882). 

Newly-launched websites need to comply with the directive starting from 28 June 2025, and existing websites from 28 June 2030.

In this article, we’ve compiled the key information you need to know as the owner of a marketplace website, including:

• The purpose of the new directive
• Types of websites and businesses the EAA applies to
• The deadline for the changes to meet the accessibility requirements
• Consequences of non-compliance
• Why consider complying voluntarily (even if you’re a microenterprise and thereby exempt)
• Summary of key accessibility guidelines to help you become EAA-compliant
• Practical tips for auditing and improving your site to meet the EAA guidelines, along with a comparison of the auditing tools we've tested
  

The stated purpose of the European Accessibility Act is to “increase the availability of accessible products and services in the internal market and improve the accessibility of relevant information.”

In practical terms, this means ensuring that the elderly and people with disabilities have equal access to products and digital services at competitive prices. According to an estimate by the European Commission, this could impact 87 million people across the EU and EEA.

At the same time, the purpose is to remove barriers created by divergent rules between the EU Member States and thereby reduce costs and open more market opportunities for accessible products.

When it comes to websites, the European Accessibility Act applies to 

• Private-sector businesses that provide digital services 
• To customers in the European Union (EU) or the European Economic Area (EEA)
• If the business is not a microenterprise

Digital services mean products like:

• E-commerce websites and apps (including online marketplaces)
• Online banking and financial services
• Transport booking and ticketing platforms
• Streaming and audiovisual media services
• E-books 

Serving customers means that the location of your marketplace doesn’t matter: a US-based business, for example, also needs to comply with the European Accessibility Act if it targets customers located in the EU or EEA.

However, there’s a notable exception for microenterprises: businesses selling digital services are exempt from the EAA's requirements if they have 

• Fewer than 10 employees and 
• An annual turnover or balance sheet total not exceeding €2 million. 

(The exemption does not apply to businesses selling products.) 

In summary: the EAA applies to your marketplace if you serve customers in the EU or EEA and are not a microenterprise.

The deadline for meeting the accessibility requirements specified in the European Accessibility Act is:

• 28 June 2025 for newly launched websites
• 28 June 2030 for existing websites

However, the exemption for microenterprises applies. Even if you launch your marketplace after 28 June this year, you’re exempt from the requirements if your business starts off as a microenterprise (i.e., fewer than 10 employees and not exceeding €2 million in turnover or balance sheet total).  

Once your business expands beyond the microenterprise thresholds, you will become subject to the EAA's requirements. 

If your marketplace isn’t a microenterprise, failure to comply with the European Accessibility Act by the deadline may risk significant consequences.

Within the EU, each member state will be responsible for enforcing the EAA through market surveillance, and the specific penalties for non-compliance may vary from country to country. According to the accessibility consultancy Inclusive Web, fines for non-compliant businesses may reach €500,000.

Even if your marketplace is exempt from complying with the European Accessibility Act, you might consider taking this opportunity to comply voluntarily.

For example, at Sharetribe, we’ve decided to start working towards making all areas of our product and marketing site compliant with the EAA well before the 2030 deadline, even though the directive doesn’t apply to the type of product we offer (and most of our customers start off as microentrepreneurs).

Eventually, this will mean Sharetribe-powered marketplaces will be default compliant with the EAA out of the box. 

Here are a few reasons why it can be a good idea to strive towards meeting the EAA requirements, even if the new directive doesn’t apply to your business currently.

Accessibility features like clearer navigation, better contrast, and captions make the user experience better for all users, not just those with disabilities.

For example, as we audited our product at Sharetribe, one of the recommended improvements was to create descriptive titles for the different pages in Sharetribe’s Console (the admin panel where you build and manage your marketplace).

Before, if you had several Console tabs open on your browser, your workspace looked like this. Each browser tab just said “Sharetribe Console”.

After the improvement, the same view looks like this. Navigating between tabs is much easier for everyone when each page has a descriptive title.

The same applies to the vast majority of accessibility considerations. Think of accessibility as a subset of good UX: an accessible product is often easier, faster, and more intuitive to use for everyone.

According to the European Commission, nearly 1 in 5 people in the EU and EEA live with a disability—around 87 million people. 

Disability can affect anyone, at any time, whether temporarily or permanently. Making your marketplace or service accessible opens the door to a larger and often underserved audience and helps you design your website for real-life situations for all your users.

In a competitive market, meeting accessibility requirements can also make you eligible for partnerships, collaborations, and visibility, for example, related to public or third-sector partnerships.

Accessibility shows social responsibility, inclusiveness, and empathy. These are values that resonate increasingly with a lot of users. A small business that invests in doing the right thing can stand out in a crowded market.

If your business grows beyond microenterprise status, you’ll need to comply with the EAA. At that point in your growth, there are probably big, impactful projects in your backlog that need to take the backseat. 

Building accessibility from the start avoids a costly, time-consuming retrofitting at a point when you’d rather be doing something else. 

Even if you’re exempt from complying with the European Accessibility Act and decide not to invest in becoming compliant yet, it can be a really good idea to take the time to audit your site anyway. (You’ll find some helpful tips and tools for that later in this article.)

This way, you’ll know where you stand and what the scope of a project to become EAA-compliant would be, should you decide to prioritize it.

More importantly, auditing your site and listing the required improvements helps you improve your offering incrementally. Improvements towards accessibility can become a natural part of projects as you develop your marketplace, branding, and marketing. And you and your team build the habit of considering accessibility alongside other criteria when planning and executing work.

Currently, most experts recommend that websites follow the Web Content Accessibility Guidelines (WCAG) 2.2 Level AA to comply with the European Accessibility Act.  

The EAA is a legal document that describes what needs to be accessible and who has to comply, but it doesn’t directly specify how to reach compliance. 

However, experts expect that the WCAG 2.2 Level AA guidelines will be formalized in the EU standards in the future. These guidelines are the current internationally recognized baseline for accessible websites and mobile apps.

WCAG stands for Web Content Accessibility Guidelines. It’s an international standard developed by the World Wide Web Consortium (W3C) to help make web content more accessible to people with disabilities.

It has several versions: The WCAG 2.0 was created in 2008 and has been widely adopted, and the updated WCAG 2.2 from 2023 adds more guidance for users with low vision and cognitive disabilities. WCAG 3.0 is currently under development.

There are three levels of accessibility compliance in the WCAG. 

• Level A: Essential
• Level AA: Ideal support 
• Level AAA: Specialized support (reserved for websites and apps that serve a specialized audience)

It’s considered likely that AA-level compliance with the WCAG 2.2 will become the formal standard of the European Accessibility Act.

The WCAG defines four principles for accessibility, and the same four accessibility principles are mentioned in the legal text of the European Accessibility Act (Directive 2019/882). According to the principles, accessible products and services need to be perceivable, operable, understandable, and robust.

Here’s a summary of the recommendations to meet the four principles, according to the WCAG 2 at a glance document.

Perceivability: Present information in ways that people can perceive. In practice, that means:

• Provide text alternatives for non-text content (e.g. alt texts for images).
• Provide captions and other alternatives for multimedia.
• Create content that can be presented in different ways, including by assistive technologies, without losing meaning.
• Make it easier for users to see and hear content.

Operability: Make interfaces usable via multiple input methods and allow for adjusting or pausing time-limited actions. In practice, that means:

• Make all functionality available from a keyboard.
• Give users enough time to read and use content.
• Do not use content that causes seizures or physical reactions.
• Help users navigate and find content.
• Make it easier to use inputs other than keyboard.

Understandability: Avoid confusion by making content clear and simple and ensuring interfaces behave in expected ways,

• Make text readable and understandable.
• Make content appear and operate in predictable ways.
• Help users avoid and correct mistakes.

Robustness: Ensure your website works with a variety of assistive technologies both now and in the future.

• Maximize compatibility with current and future user tools.

The WCAG 2.2. breaks all of these requirements down into concrete recommendations with practical information on how to implement them. To read more, go to:

• WCAG 2 at a glance: a summary of the WCAG 2.1 and 2.2 guidelines
• How to meet WCAG (quick reference): a customizable reference where you can see the exact requirements for each Level (A–AAA) and techniques for meeting them.
• The entire WCAG 2.0 guideline with links to supporting documents.
• Google also has a good resource to learn more about web accessibility.

When you start thinking about compliance with the European Accessibility Act, the first question is: how accessible is your marketplace currently? What needs to be improved?

So, the first step towards EEA-compliance is to audit your marketplace for accessibility.

Once you’ve audited your site, you can list and prioritize the improvements according to your timeline and how they fit into your other projects. 

There are lots of tools online that can be used to audit how well your marketplace currently meets the accessibility criteria specified in the WCAG 2.2 guideline.

Here’s our recommended process for auditing your marketplace for accessibility: 

1. Use a tool (the table below lists several options) to run an automated audit of your entire marketplace website. This helps you get a general sense of the situation and find issues that impact all pages.
2. At the same time, run a dedicated audit on the most important pages. Audit at least the “happy path” (the ideal user journey on your website from the landing page to making a purchase) and the most-visited pages. 
3. Complement the automatic audit with manual checks. Some tools, e.g. the Firefox extension AInspector for WCAG Accessibility Evaluation, gives you a list of “manual checks” when you run the audit.
4. If you’re not technical, ask someone with technical expertise to browse the key pages. Sometimes, the results from the auditing tool can be difficult to understand without a technical background.
5. Gather all your findings into a single document to refer to and use as material for the estimation and prioritization of improvements. List concrete findings and your estimate in terms of their complexity, and also include your general “gut feeling” on other changes and improvements that could be needed.

Item number 3 is worth highlighting: regardless of the auditing tool you choose, you’ll always need to complement it with a manual audit.

Many accessibility requirements involve clarity of language, logical structure, and meaningful interaction. Not a single tool we tested was able to capture these (yes, we did try ChatGPT, too.)

Here are a few examples of such considerations:

• Is this text meaningful?
• Does this image alt text convey the same information as the image?
• Is color the only way to notice that this button is a call to action?
• Is the font size consistent with the rest of the page?
• Does the layout break when zooming in or out using the browser’s zoom-in feature?

In fact, accessibility expert Karl Groves notes that only 25 to 33% of WCAG guidelines can be reliably tested with automation.

So, book enough time to both run an automated accessibility audit and complement it with a manual audit. 

As a part of the project to improve Sharetribe’s accessibility, our COO Thomas listed and tested several tools that offer an audit according to the WCAG 2.2 AA Level guideline.

Thomas’ general experience was that none of the tools is perfect. Many seemed to miss things, and those that offered the most comprehensive audit often lacked data exporting capabilities. At the same time, there were noticeable differences in quality and a clear winner (AInspector for WCAG Accessibility Evaluation) that we selected for auditing all of Sharetribe’s properties.

We’ve also decided to use the same tool in the future as a part of our acceptance testing. Whenever we release a new feature to Sharetribe, one stage in its testing process will be to run it through AInspector to check for accessibility issues. Picking and sticking with one tool helps unify the process and ensures all teams use the same criteria when designing, developing, and testing for accessibility.

Here’s a list of tools, along with Thomas’ experience trying them:

As mentioned earlier, you won’t catch all or even most of your accessibility issues even with the best auditing tool.

However, the best tools, such as the AInspector for WCAG Accessibility Evaluation, give you a helpful list of the things that you should check manually for each page. 

Here’s our recommended process for how to complement your automated accessibility audit with a manual audit:

1. Run your auditing tool, such as the AInspector for WCAG Accessibility Evaluation, on your most important and most-visited pages. (Unless you’re aiming at 100% compliance, this can already get you far.)
2. Go through the list of suggested manual checks for each page.
3. Test how a user can navigate through your marketplace website with keyboard navigation only.
4. Try navigating through your site with a screen reader, e.g. VoiceOver for Mac and NVDA for Windows. This usually reveals the most important paintpoints rather quickly.
5. Read through your content and pay close attention to understandability, for example how well your headings make sense, accurately describe the content that follows, and are constructed logically using the H1–H6 hierarchy. (It might help to get input from complete outsiders, here.)

While auditing Sharetribe’s accessibility, Thomas noted that things to fix or improve generally fall under one of three categories:

1. Simple element/information missing (e.g a technical label missing). These are easy to audit automatically and usually quick to fix.
2. More complex technical fix needed (e.g. embed something into a container that is made properly accessible). The best auditing tools spot these well and fixing them only requires development work.
3. Anything that needs design and/or content (e.g. font size, colors, understandable language). These require a human reviewer for the most part. In addition to accessibility, the questions relate to design, taste, and branding and tend to take some discussion from several people on the team.

Items in categories 1 and 2 are straightforward and a question of when you have the time and resources to prioritize them. More often than not, they’re also things you only need to fix once: for example, once you’ve made sure your marketplace CTA button colors on Sharetribe have enough contrast, the adjustment applies to all of your marketplace pages.

Items in category 3 are the most challenging and time-consuming. At the same time, they represent an opportunity to develop your marketplace brand into a direction that is accessible by default. Once you’ve taken the time to have the discussions, it’s much easier to incorporate accessibility as one additional consideration when you make decisions about your marketplace.

If your marketplace serves customers in the EU or EEA and is not a microenterprise, the European Accessibility Act applies to you. That means your site must meet accessibility requirements—likely based on WCAG 2.2 Level AA—by:

• 28 June 2025 for newly launched websites
• 28 June 2030 for existing websites

But whether or not you’re required to comply, accessibility is worth your time. Here’s why:

• Better user experience—Improvements like clearer structure, alt texts, and contrast help everyone
• Larger audience—87 million people in the EU live with a disability
• Stronger brand—Inclusive design shows integrity and care
• Scalability—Fixing issues early is easier than retrofitting later

Start by auditing your current site, using both automated tools and manual checks. Then, build accessibility into your product roadmap. This is how we’re approaching it at Sharetribe, and we’ve found that once the initial effort of auditing and discussion is done, accessibility quickly becomes a more and more natural part of our design and development process.

We hope soon to bring these benefits to our customers by giving them a no-code marketplace builder and web template that are accessible and EAA-compliant out of the box.

To read more, we recommend these resources:

• WCAG 2 at a glance: a summary of the WCAG 2.1 and 2.2 guidelines
• How to meet WCAG (quick reference): a customizable reference where you can see the exact requirements for each Level (A–AAA) and techniques for meeting them.
• The entire WCAG 2.0 guideline with links to supporting documents.
• Google also has a good resource to learn more about web accessibility.
  

The EAA is an EU directive (Directive 2019/882) that sets accessibility requirements for certain digital products and services in the EU and EEA. Its purpose is to ensure people with disabilities—including many elderly users—can access services like e-commerce, banking, transport, and audiovisual media on equal terms.

If your marketplace:

• Offers services like buying/selling, bookings, digital content, or media,
• Has customers in the EU or EEA,
• And your business has 10 or more employees or annual turnover/balance sheet total over €2 million,

then yes, your marketplace will likely fall under the EAA's scope.

If you're a microenterprise (fewer than 10 employees and under €2M turnover or balance sheet total), you're exempt, though voluntary compliance is encouraged.

A “new” website refers to a site or service launched on or after 28 June 2025. These must meet accessibility requirements from the day they go live.

Existing websites (those launched before that date) have until 28 June 2030 to meet the same requirements.

It might. The EAA applies based on where your customers are, not where your business is located. If your marketplace serves users in the EU or EEA, the law applies, even if your company is based elsewhere.

Each EU Member State will enforce the EAA and can set its own penalties. Fines may range from a few thousand euros to over €500,000, depending on the country. Your marketplace might also face legal action, reputational damage, or market restrictions if found non-compliant.

While the EAA doesn’t name a specific technical standard, the safest route is to make your site meet the WCAG 2.2 Level AA accessibility guidelines. Broadly, this includes:

• Using text alternatives for images
• Ensuring color contrast
• Making your site navigable by keyboard
• Writing clear, predictable content
• Ensuring compatibility with assistive technologies

You can find more details in this How to meet WCAG quick reference guide.

You can start with automated audits, but they only cover about 30% of accessibility issues. Many important requirements (like clarity, logical structure, or meaningful alternative text) must be checked manually.

Yes. Voluntary compliance can improve:

• Usability for all users, not just those with disabilities
• Market reach (nearly 90 million people in the EU and EEA have a disability)
• Brand reputation for inclusiveness and responsibility
• Scalability — you’ll avoid costly retrofits when you grow beyond microenterprise status

Even small steps now—like clearer navigation or better contrast—make a difference and are easier to build into your site.