European Accessibility Act: who must fix their website

Since 28 June 2025, the Polish act of 26 April 2024 on accessibility requirements for certain products and services (Journal of Laws 2024, item 731) has been in force. It implements the European Accessibility Act. In 2026 many companies still read it as a duty for every website. The act is narrower than that.

This is not legal advice. Whether a given company is in scope follows from how it sells, not from its industry label.

Who the act covers

The act applies to selected services offered to consumers. Article 3 includes telecommunications, access to audiovisual media, services linked to passenger transport, retail banking, e-book distribution, and e-commerce.

E-commerce is defined tightly: a distance service, through a website or a mobile device, by electronic means, at the individual request of a consumer, in order to conclude a contract. A shop that completes a purchase online is in scope. A company site with a phone number and a contact form, which sells nothing, usually falls outside it.

For e-commerce, market surveillance sits with the minister responsible for computerisation. Anyone can report a lack of accessibility to PFRON, the state fund for rehabilitation of people with disabilities. After an inspection, a provider can be ordered to fix the service within no more than 120 days, or banned from providing it for up to 180 days.

Fines go up to ten times the national average monthly wage, and no more than 10% of turnover from the previous year. The amount depends on the scale of the breach. The act is in the Journal of Laws. An overview of scope is published by the Ministry of Funds.

Who is left out

Article 4 excludes services offered by micro-enterprises. Under the Polish Entrepreneurs’ Law, a micro-enterprise employed fewer than 10 people on average in at least one of the last two years and stayed within the equivalent of EUR 2 million in turnover or balance-sheet total.

The exclusion is about services. A micro-firm that manufactures or places covered products on the market still has duties for those products. An online shop run by a micro-firm drops out of the service duties.

The second limit is the transition in article 85. Service contracts concluded before 28 June 2025 may continue unchanged until they expire, and no later than 28 June 2030. Until that same date, a provider may keep offering a service on products that do not meet the requirements, if those products were already used for the same kind of service before the act took effect. A new shop launched after 28 June 2025, by a company outside the exemption, should meet the requirements from day one.

What a site has to meet

The act does not paste in a WCAG table. For websites it requires information that is perceivable, operable, understandable, and robust, and a consistent site along those four qualities. Those are the four principles WCAG is built on. Conformity is presumed when a harmonised standard is met, in practice EN 301 549.

For sites and shops, the practical counterpart of those principles is WCAG 2.2 at level AA: contrast, focus, keyboard, button names, form errors, and a text alternative for graphics.

For e-commerce, article 18 adds identification, security, payment, and signature. They have to be perceivable and understandable. A checkout that cannot be finished from the keyboard is the first place an inspection looks.

How an inaccessible site loses visitors apart from the act is in responsive design and WCAG 2.2. The technical pieces of the same site, including headings, are in the Next.js SEO checklist.