The European Accessibility Act is in force, and B2B assumes wrongly that it is exempt
Most B2B companies concluded the European Accessibility Act was somebody else’s problem, and most of them read the scope correctly. The trouble is what they did next, which was to stop reading.
The Commission describes the Act’s reach plainly:
The European Accessibility Act covers products and services that have been identified as being most important for persons with disabilities.
European Accessibility Act, European Commission
The list that follows names computers and operating systems, smartphones, banking services, transport services — and e-commerce. Member States had to transpose the directive into national law by June 2022, and its requirements apply to products and services placed on the market from 28 June 2025. The technical yardstick is EN 301 549, which points at WCAG; W3C’s own summary of the EU position lists WCAG 2.2.
So: a studio selling consulting to other businesses is not obviously in scope. That much is true. Here is what makes the conclusion unsafe anyway.
Three ways B2B ends up inside the scope
You sell something online. “E-commerce” is not a synonym for retail. If a business can select a service and pay for it through your site, that transaction has the shape the directive describes. A checkout is a checkout whether the buyer is a person or a purchasing department.
Your client is in scope, and you built their site. This is the common case and the one that actually costs money. A studio that ships an inaccessible platform to a bank, a transport operator or a retailer has not breached the Act itself — the client has. What the studio has done is deliver something that fails a legal requirement, which is a contract problem, a remediation bill, and a reference lost.
Procurement asks before the law does. Large buyers push their obligations down the supply chain long before a regulator arrives. Accessibility statements are appearing in RFPs from companies that have no intention of testing whether you were technically obliged. Failing that question is a lost deal, not a fine — and it happens years earlier than enforcement.
What this costs when it is done early
Very little, and this is the part worth internalising: nearly everything WCAG asks for at level AA is a thing a careful build does anyway.
Text that meets contrast minimums. Every control reachable by keyboard. Form fields with real labels. Images with alternative text, or marked decorative when they carry nothing. Headings in order. Focus that is visible. A page that survives being zoomed.
None of that is a feature. It is the absence of six specific mistakes, and the cost of avoiding them during a build is close to zero. The cost of finding them afterwards, across a finished platform, is a project.
We were reminded of the asymmetry on this site last week: two footer links sat at 1.98:1 against a 4.5:1 minimum. Fixing it took one line and no design compromise — because it was caught while the stylesheet was still open. The same defect found in an audit is a ticket, a retest and an argument about whether it matters.
What to do, in order of value
- Decide whether you are in scope, in writing. One paragraph, dated, naming the reasoning. If procurement asks, you have an answer; if the answer was wrong, you have a record of what was assessed.
- Run the automated pass anyway. Lighthouse or axe catches contrast, labels and structure in minutes. It will not prove compliance — automated tools find perhaps a third of the real issues — but it is the cheapest third.
- Test with a keyboard. Unplug the mouse and complete your own primary journey. Most sites fail this within a minute, and the failures are unambiguous.
- Put it in the build standard, not the audit budget. The only version of this that stays cheap is the one where nobody has to remember it later.
The honest bit
Enforcement against B2B service companies is not, so far, where the attention is. If you are waiting for a regulator, you will probably wait. But the deadline that actually binds is commercial: the first serious client who asks for an accessibility statement, and the first project where the requirement arrives after the design is finished.
Sources: European Accessibility Act, European Commission; European Union policies, W3C Web Accessibility Initiative.
