Web accessibility: what the European Accessibility Act requires of Belgian businesses

The European Accessibility Act (EAA), European Directive (EU) 2019/882³, entered into force on 28 June 2025¹. Its aim, as stated by FPS Economy, is to improve access to products and services for people with disabilities throughout the European Union¹.

Until that date, digital accessibility obligations mainly targeted the public sector. The EAA broadens the scope: it brings part of the private sector into the framework, starting with e-commerce. For many Belgian businesses, this is the first time their website's accessibility has become a legal issue rather than simply a question of quality.

FPS Economy lists the services covered: consumer banking services, e-commerce services, e-books, self-service terminals, payment terminals and e-readers². In practice, the simple rule to remember is that if your website sells online, you are very likely within scope.

Micro-enterprises in Belgium. For consumer banking and e-commerce services, FPS Economy specifies an additional transition period until 28 June 2030 for businesses employing fewer than ten people whose annual turnover or balance sheet total does not exceed €2 million². This sector-specific arrangement should not be applied to every product and service: check the applicable legislation and competent authority for your activity.

The two substantive exceptions. The directive also provides two cases in which a provider may not comply: where adaptations represent a disproportionate burden or require a fundamental alteration that would radically change the service. To invoke them, you must notify the Economic Inspectorate beforehand². In other words, these exceptions must be declared, not presumed.

The European technical reference is the harmonised EN 301 549 standard, built on WCAG 2.1 (Web Content Accessibility Guidelines)⁴. It is organised around four principles, summarised by the acronym POUR: a website must be Perceivable, Operable, Understandable and Robust⁴. The operational threshold remains WCAG 2.1 level AA (version 2.2 has not yet been incorporated into the harmonised standard)⁴.

FPS Economy translates these principles into concrete obligations for banking and e-commerce services²:

• provide information through at least two different sensory channels (for example, visual and auditory);
• ensure content can be read by screen readers or printed in braille;
• provide a description for images and other non-text content;
• allow the text font to be adapted;
• provide information about the service's accessibility and compatibility with assistive technologies¹.

The law sets a standard. The web is a long way from meeting it. The February 2026 WebAIM Million analysis, which automatically audits the million most visited homepages, detected WCAG failures on 95.9% of them, with an average of 56.1 errors per page⁵.

The good news within the bad news: six categories of errors alone account for 96% of the problems detected⁵. Fixing these six points takes you most of the way.

A detail directly relevant to French-speaking Belgium: pages written in French average 58.5 errors per page, 4.2% more than the global average⁵. The French-speaking market is not ahead.

The technical foundation matters too. WebAIM also measures accessibility by website technology. The gap is striking and structural: a website built on a lightweight, well-rendered foundation starts with much less accessibility debt than a stack of extensions.

The risk in Belgium. The Directorate-General for Economic Inspection is responsible for enforcing these requirements for e-commerce and consumer banking services². A consumer can report an inaccessible service, which may trigger an investigation².

Accessibility feels daunting when viewed as a whole. Broken down, it becomes a series of concrete actions. Here is the order in which we approach it when supporting a client with creating or redesigning their website.

• 1. Diagnose. Audit the website, starting with the six most common error categories: that is 96% of the way⁵. An automated audit sets the scene; a manual check (keyboard navigation, screen reader) confirms it.
• 2. Fix the foundations. AA-level contrast, meaningful alternative text, form labels, explicit link and button names, and a declared document language. Nothing exotic, but it changes everything for the user.
• 3. Choose a sound foundation. When redesigning a website, the choice of technology affects accessibility debt (see the table above)⁵. It is better to start cleanly than catch up: our website redesign guide explains how to handle the project without losing your traffic.
• 4. Publish an accessibility statement. Providing information about the service's accessibility level and contact options when difficulties arise is part of the expectations¹.
• 5. Document exceptions. If achieving compliance represents a disproportionate burden, it must be documented and reported to the Economic Inspectorate before relying on that exception².

Beyond compliance, accessibility overlaps substantially with what already makes a good website: readable contrast, a clear structure, understandable forms and fast pages benefit everyone, not just people with disabilities. Loading speed is measured through Core Web Vitals, another pillar of a high-performance website. Accessibility also sits alongside the other digital obligations we monitor for our clients, such as GDPR compliance and the new electronic invoicing requirements. Ultimately, the legal requirement is simply a reason to build better.