EAA website audit: who needs one and what it actually checks

The European Accessibility Act applies to consumer e-commerce since 28 June 2025. What an EAA/WCAG 2.1 AA audit covers, who is exempt, and why overlays fail.

Key answer

Key answer: The European Accessibility Act (EAA) has applied to consumer-facing e-commerce in the EU since 28 June 2025. An EAA website audit checks your site against WCAG 2.1 AA: automated scanning plus a manual expert review, resulting in a prioritised list of violations and fixes. Microenterprises providing services (fewer than 10 persons AND annual turnover or balance-sheet total of at most EUR 2 million) are exempt from the accessibility requirements for those services. Accessibility overlays do not make a site compliant. This article explains the scope; it is not legal advice.

Does the EAA apply to your website?

If you sell to consumers (B2C) online in the EU, the EAA has applied to you since 28 June 2025. The main exemption: microenterprises providing services, meaning fewer than 10 persons and annual turnover or balance-sheet total not exceeding EUR 2 million (Article 3(23) and Article 4(5) of Directive 2019/882).

Two honest caveats we give every client: check your company size before worrying, and have the final legal assessment confirmed by a lawyer — a technical audit is not legal advice.

What an EAA audit actually checks

The technical benchmark is WCAG 2.1 level AA. A serious audit combines two layers:

Automated scan

Tooling (e.g. axe-core) catches the mechanical issues: contrast, missing labels, ARIA errors, missing alt attributes. Many WCAG criteria still need human judgement.

Manual expert review

The rest can only be verified by hand: full keyboard operation, screen-reader flow, whether alt texts actually describe the image, focus order, touch target sizes.

The deliverable is a report with violations mapped to WCAG criteria, ranked by priority (blockers first), with a concrete fix list — so a developer can start the same day.

Why accessibility overlays don't solve EAA

Overlay widgets promise „compliance with one script". In practice they add a layer on top of an inaccessible site: keyboard traps, broken labels and unreadable structure remain underneath. The EAA expects accessibility at the source.

An audit will show precisely what an overlay leaves unfixed in the underlying code.

What fixing usually looks like

Typical quick wins: contrast, form labels, alt texts. More work: keyboard navigation, ARIA structure, focus management. After remediation, a re-audit confirms the fixes and your accessibility statement (a formal EAA requirement) reflects the real state.

Accessibility also overlaps with SEO and conversion: clear structure, readable forms and working keyboard paths help every user, not only those with disabilities. For the legal background, see our overview: EAA 2025: is your website accessible under EU law?

Our own site: 100/100 in the automated Lighthouse accessibility test

nostressstudio.com scores 100/100 in the automated Lighthouse accessibility test (checked October 2026), and we run the same process on our own site as on yours. We publish that not to brag but because it is the fairest proof we can offer: we audit others with a checklist we pass ourselves.

Want to know where your shop stands? Write to kontakt@nostressstudio.com — we will scope an EAA/WCAG 2.1 AA audit for your site.

FAQ

Is an EAA audit a legal certificate?

No. It is a technical conformity check against WCAG 2.1 AA with a re-audit after fixes; the legal reading of your obligations belongs to a lawyer.

We already have an accessibility widget — are we covered?

No; overlays do not provide WCAG conformity, and the audit will show what is still broken underneath.

How long does an EAA audit take?

Depends on site size; the report always arrives prioritised, so fixes can start with the worst violations first.

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