Maybe you’ve seen the email. Or the LinkedIn post. “New EU law! Your website has to be accessible, or you’re facing fines of up to ten million kronor.” The tone is always the same. Act now, or you’re in trouble.
It’s easy to get rattled. The European Accessibility Act has fuelled a fair amount of scare-marketing since it took effect, and much of what you read blurs the line between what the law actually says and what someone wants to sell you.
So let’s sort it out. Does this law apply to your website? And if it does, what do you actually need to do?
What the European Accessibility Act actually is
The European Accessibility Act (EAA) is an EU directive that Sweden has implemented through its own law, the accessibility act (lag 2023:254). The aim is to make products and services usable for more people, including those with visual, hearing or mobility impairments. The law took effect on 28 June 2025.
Several authorities share supervision, depending on the type of service involved. For e-commerce, it’s the Swedish Post and Telecom Authority (PTS) that checks compliance, and that’s the part affecting most business websites.
So much for the easy part. The tricky bit, the one almost no article explains properly, is who the law actually applies to.
Does the law even apply to your website?
Here’s the single most important point in this whole piece. The law applies to services, not to websites in general.
A site that only provides information normally falls outside the law. Picture a physiotherapist showing their opening hours, an electrician listing what he does, or a consultant describing their services with a contact form. That kind of site doesn’t sell anything on the spot and isn’t covered.
A site that delivers a service is a different matter. E-commerce above all. What matters isn’t whether money changes hands on the page, but whether the customer can enter into a contract there. If someone can shop in a webshop, or make a binding booking online, then you’re delivering a service the law may cover.
So where’s the line for a booking function? If the customer enters into a binding agreement on the site, it starts to look like e-commerce, whether payment happens immediately or later. A plain information page with a phone number does not.
Microenterprises are exempt
And even if your site does count as a service, there’s an exemption that catches the vast majority of small businesses.
If you’re a microenterprise, you’re completely exempt from the requirements on services. A microenterprise means a business with fewer than ten employees and an annual turnover or balance-sheet total of no more than two million euros, roughly 20 million kronor. The headcount must be under ten. After that, it’s enough for either the turnover or the balance-sheet total to fall under the threshold.
For a typical small clinic, tradesperson or consultant with a webshop or online booking, that means the law’s requirements on services don’t apply. It’s not a loophole or a grey area. It’s written plainly into the text of the law.
But one thing is worth bearing in mind. There’s no transition period the day you grow past the threshold. Hire your tenth person, or cross the turnover ceiling, and the exemption disappears at once. If you’re already building for growth, it’s easier to allow for accessibility from the start than to fix everything after the fact.
What the law requires if it applies to you
Say you’re not exempt. You have a webshop, more than ten employees, and the law applies. What does the site need to manage then?
The law points to a European standard called EN 301 549. It’s broader than just the web, but for the website itself it builds on a well-known set of guidelines, WCAG 2.1 at level AA. Behind the technical names sit four fairly simple principles. The content should be perceivable, operable, understandable, and technically robust.
In practice it comes down to things like this. Text that stands out clearly against the background. Images with a description for those who can’t see them. Everything usable with a keyboard alone, not just a mouse. Forms with clear fields and understandable error messages. And a code structure a screen reader can interpret. It ties into the technical quality of your website more broadly: clean code and good structure help visitors, assistive tools and Google alike.
This is also where most sites fall down. Weak colour contrast is by far the most common error, followed by images without a description and form fields without labels. It shows in WebAIM’s review of the world’s top one million home pages (February 2026): 95.9 percent of them had automatically detectable failures, up from 94.8 percent the year before. Low contrast appeared on 83.9 percent of pages, images without alt text on 53.1 percent and unlabelled form fields on 51 percent. So it isn’t a problem that only affects careless businesses.
If the law applies to you, you also need to be able to explain how your service meets the requirements, in your terms or a similar document.
What you actually risk
So what happens if the law applies and you do nothing?
On paper, a supervisory authority can require you to fix the shortcomings, and ultimately decide on a penalty fee. It can land somewhere between 10,000 and 10 million kronor, depending on how serious and far-reaching it is. That’s the figure the scare emails lean on.
But that isn’t what reality looks like yet. PTS has started with the large e-commerce players, reviewing a few at a time, and works through dialogue rather than fines. PTS has opened 28 supervision cases against e-commerce services, most recently extended by eleven more during 2026, but no case has ended in a sanction fee. The risk that a small, exempt business suddenly gets an invoice from the state is in practice very low.
The real cost lies elsewhere. A large share of the population has some form of disability. A site that’s hard to use shuts out customers, whatever the law says. Remember that your website is often the first impression of your business. It rarely shows when someone turns away at the door, because they don’t get in touch. They just move on to the next one.
The accessibility act isn’t the only EU rule to have landed on Swedish websites recently either. The withdrawal button requirement has applied since June 2026, and the question of whether your website needs a cookie banner has the same kind of answer as this one: it depends on what you actually do, not on what the scare emails claim. And if you have an AI chat, since August 2026 it has to tell visitors it is an AI.
A simple checklist
Want a feel for where your site stands? Here are the most common things to look at, from what you can often fix yourself to what needs a developer.
These you can usually change on your own:
- Colour contrast between text and background
- Descriptions (alt text) on images that carry meaning
- Clear link text, not “click here”
- A logical heading structure
- Captions or transcripts on videos
These usually need someone who knows the code:
- Form fields with correct labels and error messages
- Everything reachable and usable with a keyboard
- Visible focus markers as you tab through
- Menus, pop-ups and search working with a screen reader
There are free tools like WAVE and axe that give you a first indication. But be careful with the conclusion. An automated test only finds a smaller share of the problems, and a so-called overlay, a widget that promises to make the site accessible automatically, rarely solves it. The European Commission is explicit that overlays, or any other tools that don’t make the website itself meet the standard, are not an appropriate solution — issues should be fixed at their source. The European Disability Forum and accessibility experts go further, reporting that such tools can interfere with the assistive technology visitors already use, and in some cases make the site worse. The real work, especially the technical part, needs to be done by hand. And it doesn’t stop at launch: a new plugin or a rebuilt form can break what used to work, so accessibility needs re-testing after changes.
Start with the two questions
Can a customer enter into a contract on your site, and is your business too large for the micro-enterprise exemption? If the answer to either is no, the Act’s requirements for services don’t apply to you today. It’s still worth fixing contrast and form labels, because that’s where visitors most often get stuck.
If the answer to both is yes, we go through the purchase or booking flow step by step using only the keyboard, which is what an automated test can’t catch, and write down what needs fixing, in order of how many visitors it affects. It’s part of how we work on web design and rebuilds.
Updated 27 September 2026: new title, and we’ve reviewed the latest amendment to the law, SFS 2026:1026. It applies from 20 November 2026 and only changes how consumer banking services are defined, so it doesn’t affect ordinary business websites. PTS supervision was re-checked the same day: the authority’s latest word is still 28 supervision cases (3 March 2026), and we found no public decision on a penalty fee.