Digital Accessibility: Are All Websites Affected? Myths, Reality, and a French Warning

Myth #1: All websites must be accessible

Szabó Gergely

Reality: The law does not apply to all websites in general, but only to websites and mobile applications that are related to the provision of specific services. These include banking services, passenger information and ticket purchasing systems of transport companies, telecommunications service providers, e-commerce platforms, e-books and audiovisual media services. A website that is purely for information or contact purposes (for example, a law firm’s website) and does not provide for the conclusion of a consumer contract is not covered by the regulation.

Myth #2: The regulation applies to all economic operators

Reality: The scope of the law is not general. The regulation is only mandatory for service providers who provide digital services to consumers in the relevant sectors. In addition, micro-enterprises (fewer than 10 employees and a turnover of up to 2 million euros) are exempt from a significant part of the obligations. This means that a consulting firm or small webshop is often not subject to regulation, while a bank or a large online marketplace is.

Myth #3: All existing services must be converted immediately

Reality: The regulations only apply to services launched after June 28, 2025, i.e. newly provided to consumers. In the case of services that are already legally operating, there is a grace period until June 28, 2030 to transition. Important: “service” should be understood as digital services provided to consumers as specified in the EAA and the Aktv. – for example, an online banking interface, an e-commerce platform or a digital ticketing system. The grace period does not apply to introductory content, as it is not subject to the law in the first place.

Myth #4: Accessibility requirements must be met in all circumstances

Reality: The law specifically states that the requirements only apply to the extent that they do not constitute a disproportionate burden and do not change the essential nature of the service. This means that in certain cases – for example, in the case of technical impossibility or disproportionate cost – the service provider may be exempted from certain obligations, but this must be documented in writing in advance. Micro-enterprises are not required to report, but all other economic operators must inform the authority and – in the case of cross-border services – the competent authorities of other affected Member States.

Myth #5: It is just a mandatory burden

Reality: The risk of fines is indeed high. The fine can reach 5% of annual net turnover, but the authority considers the gravity of the case and the cooperation of the service provider. At the same time, accessibility actually improves the user experience, opens up a wider customer base and strengthens the company’s social responsibility. EAA compliance is an opportunity and not a burden, just like GDPR, NIS2 and AI Act compliance, we just need to retrain our brains – emphasized Dr. Gergely Gábor Szabó.