WCAG standards

WCAG (Web Content Accessibility Guidelines) uses three compliance levels: A, AA, and AAA. Across the EU and UK, Level AA (version 2.1) is the universal benchmark. It focuses on four principles (POUR):

• Perceivable: Text alternatives for images, captions for video, and clear colour contrast (minimum 4.5:1 ratio).
• Operable: Complete navigation via keyboard (no mouse required) and no flashing content.
• Understandable: Consistent layouts, predictable actions, and clear form error handling.
• Robust: HTML code compatible with screen readers and assistive tech.

EU requirements & expectations

The European Accessibility Act (EAA) took effect on 28 June 2025. It targets consumer-facing digital products and key services sold or used in the EU market.

• Expectations: Organisations must actively ensure user interfaces meet WCAG 2.1 AA, produce technical compliance documentation, publish a public accessibility statement, and offer reporting channels for users with disabilities.
• Exemptions: Micro-enterprises (fewer than 10 employees AND under €2M turnover) are exempt, as is content where making it accessible would create a “disproportionate burden” or alter the product’s fundamental nature.

Punishments & enforcement

Enforcement is handled at the individual national level by each EU member state. Penalties mirror GDP-related regulatory frameworks (like GDPR):

• Fines: Financial penalties vary by country, but severe/repeated breaches can scale up to millions of euros or a percentage of annual turnover.
• Operational restrictions: Member state authorities hold the power to force companies to withdraw non-compliant digital products or services from the market entirely until rectified.
• Legal action: Consumers and accessibility advocacy groups can launch class action lawsuits or formal complaints directly through national courts.

Impact on the UK

The UK is no longer an EU member, so the EAA was not adopted into domestic law for private businesses.

• Domestic UK law: UK private sector companies operate under the Equality Act 2010, which mandates “reasonable adjustments” to prevent discrimination against disabled individuals. Public sector bodies fall under the strict Public Sector Bodies Accessibility Regulations 2018 (requiring WCAG 2.1 AA).
• Extraterritorial reach: If a UK business sells B2C digital products, e-commerce, or consumer apps into the EU market, it must comply with the EAA regardless of where its headquarters or servers reside.

Closed B2B products

Purely internal or business-to-business (B2B) products sit in a unique position:

• Direct EAA scope: Closed B2B software (such as an internal enterprise CRM or a B2B insurance platform) is largely excluded from the direct mandates of the EAA, which primarily targets B2C services (e-commerce, banking, consumer apps).
• Procurement pressure: While direct statutory fines may not apply to closed B2B software under EAA, commercial buyers (enterprise clients, public bodies, or EU-based employers) face strict employment and public sector accessibility laws. Consequently, enterprise procurement teams routinely mandate WCAG 2.1 AA compliance as a strict contractual requirement before purchasing B2B software.