A client rang me in March, panicked. She runs a mid-size e-commerce operation selling kitchenware, ships across Germany and the Netherlands, and her developer (not us, for the record) had just told her the site "probably needs some accessibility work." That was it. No specifics, no timeline, no mention that the European Accessibility Act had a hard enforcement deadline of 28 June 2025. She found out from a trade newsletter.
That kind of vague handoff is, I'd argue, a professional failure. And right now, across the UK and EU, agencies are doing it constantly.
So let me be direct about what the EAA actually requires, what it means for the sites you've built, and what you genuinely owe the clients paying you.
What the EAA Actually Is (and Isn't)
The European Accessibility Act is an EU directive that member states were required to transpose into national law by June 2022. Enforcement kicked in June 28, 2025. It applies to a wide range of products and services, but for our purposes: websites and mobile apps offering e-commerce, banking, transport, and media services to EU consumers are in scope.
Here's where people get confused. The EAA is not the same as the Public Sector Bodies Accessibility Regulations, which covered government sites from 2018. This is private sector. If you built a webshop for a small Brussels-based furniture brand, or a booking platform for a Berlin yoga studio, that client is now subject to enforcement.
The technical standard the EAA points to is WCAG 2.1 Level AA. Four principles: perceivable, operable, understandable, robust. The specific success criteria (there are 50 at AA level) are what courts and regulators will point to when something goes wrong.
Seahawk has built sites in 40+ countries. I've had this conversation with clients on three continents. The EAA is not uniquely terrifying, but the enforcement mechanism across EU member states is real, and the fines vary by country. Germany in particular has a litigious accessibility culture going back years before the EAA existed.
Who Actually Falls Under This
Not every site you've ever shipped is suddenly a legal liability. But the scope is broader than most agencies are telling clients.
In scope: e-commerce (any site taking orders from EU consumers), banking and financial services, audiovisual media services, e-books and e-book readers, electronic communications, transport passenger services.
Out of scope (mostly): micro-enterprises with fewer than 10 employees and under €2 million annual turnover. Note: that's an AND, not an OR.
So if you built a WooCommerce store for a 15-person UK brand that ships to France, they're in scope. If you built a site for a 3-person bakery in Manchester that only ships locally, probably not. But I'd still have the conversation. Clients ask. Better they hear it from you.
The UK situation is slightly different post-Brexit. The EAA as an EU directive doesn't directly apply in Great Britain. But if your client has EU customers, it applies to them. And there's every reason to expect the UK will tighten its own private sector accessibility rules in the next few years. I'm building to WCAG 2.1 AA regardless, because retrofitting later is always more expensive.
The Four Things You're Probably Getting Wrong Right Now
I'm going to be honest here. After auditing dozens of sites in the past 18 months, these are the failures I see on almost everything.
- Missing or inadequate accessibility statements. The EAA requires a written accessibility statement on every in-scope site. Not a checkbox in a footer. An actual statement describing conformance level, known issues, and contact details for users to report problems. Most sites I audit have nothing, or have a five-line legal boilerplate that was copied from somewhere else.
- Colour contrast failures. WCAG 2.1 AA requires a 4.5:1 contrast ratio for normal text. I ran axe DevTools on a fintech client's site last autumn and found 34 separate contrast failures, mostly in grey-on-white form labels. The designer had picked them in Figma on a calibrated monitor in a dark room. Looked beautiful. Completely failed the standard.
- Keyboard navigation that breaks on modals and dropdowns. Focus trapping in modal dialogs is one of the most commonly failed success criteria. Users navigating by keyboard (including people using switch controls, not just tab-key power users) get lost. I've seen agency-built nav menus where pressing Escape does absolutely nothing.
- Images with missing or meaningless alt text. Not just blank alt attributes. Equally bad: alt text that says "image1.jpg" or "photo of product" with no useful description. I had a client whose entire product catalogue had been bulk-imported from a supplier feed with file names as alt text. Thousands of images. That's a significant audit failure.
What a Proper Accessibility Audit Actually Involves
Automated tools catch roughly 30-40% of WCAG issues. That's a well-documented figure. The rest requires human judgement.
Here's the process I'd recommend for any in-scope site:
- Run axe DevTools or Lighthouse in Chrome DevTools across key templates (homepage, product page, checkout flow, contact form).
- Check keyboard-only navigation through the full purchase journey. No mouse. Just Tab, Shift+Tab, Enter, Escape, arrow keys. See what breaks.
- Test with a screen reader. NVDA is free on Windows. VoiceOver is built into macOS. Spend an hour with your eyes closed on the checkout page.
- Check colour contrast using the Colour Contrast Analyser from TPGi. Do this on every text element, not just body copy.
- Read through every form's error messages. Do they identify the field? Do they describe the problem? Or do they just say "please correct the errors above"?
This is not a one-afternoon job. For a complex e-commerce site I'd budget 2-3 days for a thorough audit, plus another 3-5 days for remediation. Quote accordingly.
The Accessibility Statement Specifically
The W3C has a good generator for accessibility statements. I've used it as a starting point on a dozen projects. It won't write the statement for you, but it gives you the structure. The statement needs to live at a consistent URL, be linked from the footer, and be updated when you fix issues or find new ones.
The Contractual Question Nobody Wants to Answer
Here's the thing: if you built a site that's now in scope for the EAA, and you didn't build it to WCAG 2.1 AA, are you liable?
Probably not legally. Unless your contract explicitly promised accessibility compliance (most don't), the legal liability falls on your client as the service operator. But that's a cold comfort argument. The client will feel, rightly, that you should have flagged it. Especially if they come back to you after a regulator contacts them.
My position: if you built the site, you have a professional obligation to inform the client. Send a plain email. "Your site may be in scope for the European Accessibility Act. Here's what that means. Here's what we'd need to do. Here's a rough cost estimate." That's it. You've done your job.
Back in 2021, Seahawk had a US-based travel booking client operating in the EU. We flagged the incoming directive proactively, before they'd heard of it. They came back eight months later and gave us a full remediation project. Probably £18,000 worth of work we'd never have gotten if we'd stayed quiet.
Don't be passive about this. It's not nagging clients. It's being a professional.
Pricing Accessibility Work Honestly
Accessibility retrofitting is priced all over the place. I've seen agencies quote £500 for an "accessibility review" that's just an automated Lighthouse scan. That's not an audit. That's a parlour trick.
Real numbers, from our own projects:
- Basic automated audit report with prioritised issues: £800-1,500 depending on site complexity.
- Full manual audit (automated plus keyboard, screen reader, contrast, form testing): £2,500-5,000.
- Remediation on a mid-size WooCommerce site with 50-100 page templates: £4,000-9,000.
- Full remediation plus accessibility statement plus documentation for a complex web app: £12,000+.
These aren't padded numbers. Accessibility work is slow, careful, detail-oriented work. The keyboard navigation piece alone takes time because you're testing real user journeys, not just clicking around.
And yes, you should charge for ongoing monitoring. Accessibility isn't a one-time fix. Every time you add a new feature, change a colour palette, or update a theme, you can introduce new failures. Quarterly audits with a retainer are a legitimate service line.
What to Tell Clients Who Ask "Are We Compliant?"
Don't say yes unless you've done the work. Don't say "probably" either.
The honest answer is almost always: "Not fully, and here's why." Full WCAG 2.1 AA conformance on a non-trivial site that wasn't built with accessibility in mind from the start is genuinely rare. There's almost always something.
What I tell clients: "We can get you to a defensible position. That means no critical failures, an up-to-date accessibility statement, a process for handling user complaints, and a documented remediation roadmap for lower-priority issues." That's achievable. That's also what a regulator would look for when deciding whether to pursue enforcement.
Nobody expects perfection on day one. They expect good faith effort and a process. Build them both.
FAQ
Does the EAA apply to UK agencies building sites for EU clients?
It applies to your client, not to you directly. If your client is operating an e-commerce service targeting EU consumers, they are the "economic operator" under the directive and they carry the compliance obligation. But you built the site. If it doesn't meet the standard, that's a conversation you need to have.
What happens if a site isn't compliant after June 2025?
Enforcement varies by member state. In practice, the most likely first contact is a complaint from a user or a disability advocacy organisation, followed by a request from a national market surveillance authority for remediation. Fines differ significantly by country. Germany and France have historically been more active on these matters than some smaller member states.
Is WCAG 2.2 required, or is 2.1 enough?
The EAA references the EN 301 549 standard, which currently aligns with WCAG 2.1 AA. WCAG 2.2 adds nine new success criteria. You're not legally required to meet 2.2 for EAA purposes yet, but building to 2.2 where it's feasible is sensible future-proofing.
Can a micro-enterprise really be exempt?
Yes, if they meet both thresholds: fewer than 10 employees AND under €2 million in annual turnover. But individual member states can choose to apply the directive more broadly. Don't rely on the exemption without checking your specific client's situation against the law in the countries where they operate.
We built the site two years ago. Are we on the hook?
The site is in scope based on what it does now, not when it was built. Age of the site is irrelevant to compliance. What matters is whether it currently meets WCAG 2.1 AA. If it doesn't, the operator needs to fix it. Whether they can recover costs from you as the original developer depends entirely on your contract.
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Accessibility isn't a niche concern or a nice-to-have anymore. For a significant chunk of the sites our industry builds, it's now a legal requirement with real enforcement behind it. The agencies that get ahead of this will find it's actually a decent revenue stream. The ones that stay quiet until clients start getting letters will find those conversations a lot harder to have.
Do the audit. Write the statement. Tell the client.