Your website may be in scope of an EU law you have never read.

Two questions decide whether this touches you, and neither is about your registered office.

Do you provide one of the listed services? The list is specific rather than general: e-commerce, banking services, e-books, telephony, audio-visual media, transport, and a set of physical products including ATMs and ticketing machines. A brochure website for a professional firm is not obviously an e-commerce service. A page where a consumer buys something is.

And do EU consumers use it? The scope follows the customer. A law firm's guide to the Act puts it plainly: it applies to any provider offering e-commerce services to consumers in the EU, whether that provider is in the EU or not.

What "accessible" means in practice

The requirements align with EN 301 549, the EU's harmonised digital accessibility standard, which in turn leans on the Web Content Accessibility Guidelines. In practice that means the things an accessibility audit has always looked for: text alternatives, keyboard operability, sufficient contrast, labels on form fields, content that survives being resized or read aloud.

Bird & Bird's guide makes one point worth repeating: e-commerce here means all steps leading to the conclusion of a transaction, not just the checkout. The product page, the search, the account creation and the confirmation email are all part of the service.

Why we are writing about this at all

Because we run these checks on ourselves and publish the number. Every page of this site goes through axe-core’s automated WCAG 2.1 AA rules on every push, and a separate tool measures the contrast of text against the pixels actually rendered behind it rather than against the colour in the stylesheet.

In five runs on 23 and 24 September 2026 the worst reading ranged from 5.06 to 6.25 against a 4.5 requirement. It moves between runs, because the text sits over a live render, so the lowest is the one we quote.

We did not do that for Europe. We did it because a page an answer engine cannot parse and a page a screen reader cannot parse fail for overlapping reasons, and because a contrast failure is the one design fault that is invisible to the designer who introduced it.

Which is the practical argument for treating this as a build problem rather than a legal one. An audit is a photograph. A check that runs on every deploy is a fact about the site, and it is the only version that survives the next redesign.

Three things to establish before you spend anything

1. Whether you are in scope at all. Most UK professional firms are not: no e-commerce, no EU consumers, no listed service. Establish that in writing and stop.
2. What your site currently fails. Automated tooling catches a meaningful share of issues and costs nothing to run. It will not catch everything, and it is still the right first move because it tells you the size of the problem.
3. Whether the failures are in the template or the content. A template fault is one fix applied everywhere. A content fault — missing alt text, unlabelled links — recurs every time somebody publishes, which makes it a process problem and a candidate for a check rather than a rule.

What this does not tell you

We are not lawyers and this is not advice on whether a specific business is in scope. The directive is implemented through twenty-seven national laws, and the enforcement, the penalties and the exemptions — including any relief for very small businesses or for disproportionate burden — sit in those laws rather than in the directive we read.

It also does not tell you that compliance equals usability. A site can satisfy an automated rule set and still be miserable to use with a screen reader, which is why the standard asks for testing with people and the tooling only ever gets you to the starting line.

If you want the related argument about machines reading your pages, it is in the note on AI-search visibility, and the visibility checker asks a narrower version of the same question. Our own register of what we checked includes the accessibility numbers, and the retainer is where they stay fixed.