The verdict in three sentences
Since 28 June 2025, the European Accessibility Act applies to e-commerce and digital services of every company that is not a microenterprise. The first practical step is a WCAG audit at 3,000 to 8,000 EUR, which feeds an honest accessibility statement and a 3-year multi-year plan. A company that publishes nothing faces penalties set by each member state, up to 50,000 EUR per service and renewable in France, plus public enforcement notices.
Who is covered and which documents to produce
The general counsel of a mid-sized retailer usually asks three questions: are we covered, what must we publish, and how fast? The table below summarises the 2026 position, using France as the reference implementation; check national rules with your counsel for edge cases.
| Situation | Main obligation | Expected document |
|---|---|---|
| Microenterprise (fewer than 10 staff and turnover or balance sheet up to 2 million EUR) providing services | Exempt for services | Recommended, not required |
| Company with 10+ staff or over 2 million EUR, with an online shop | EAA compliance, EN 301 549 or national standard | Accessibility statement and compliance information |
| Banking, transport, telecoms, e-books | Sector-specific EAA rules | Statement and service-specific information |
| Company with over 250 million EUR turnover in France | Extended Article 47 of the 2005 law | Statement, multi-year plan, annual action plans |
| Public body or public service delegate | Web Accessibility Directive, mandatory | Statement, multi-year plan, homepage mention |
| Purely corporate site with no sales | Outside the EAA in most cases | Recommended, often required by large clients |
Even when a multi-year plan is not legally required, it is strongly advised: it proves a progressive compliance approach, which market surveillance authorities value when a complaint is filed.
The accessibility statement template
A compliant statement follows a stable structure. Here is the content to adapt, section by section.
| Section | What to write | Example |
|---|---|---|
| Commitment | Company name, website concerned, standard | "Company X is committed to making its website accessible in line with EN 301 549 and WCAG 2.1 AA" |
| Compliance status | Full, partial or non-compliant | "Partially compliant, 72% of criteria met" |
| Test results | Date, auditor, page sample, rate | "Audit of 12 March 2026, 15 pages, 50 applicable success criteria" |
| Non-accessible content | Failures, exemptions, out-of-scope content | "Checkout: 4 fields without labels" |
| Preparation of the statement | Date, technologies, test tools | "HTML5, CSS, JavaScript; NVDA, VoiceOver, Colour Contrast Analyser" |
| Feedback and contact | Email, form, postal address | "accessibility@company.com, reply within 10 days" |
| Enforcement procedure | Ombudsman or national authority | Link and address of the competent authority |
The multi-year plan fits in 3 to 6 pages: accessibility policy, named lead, staff and budget, team training, and a 3-year schedule. Each year, an action plan lists planned and completed fixes.
2026 compliance budget
| Item | Corporate site 20 to 50 pages | SME online shop | Multi-country enterprise shop |
|---|---|---|---|
| Initial WCAG audit (page sample) | 3,000 to 4,000 EUR | 4,500 to 6,000 EUR | 6,500 to 8,000 EUR |
| Statement and multi-year plan drafting | 800 to 1,200 EUR | 1,200 to 1,800 EUR | 1,800 to 3,000 EUR |
| Technical fixes (templates, forms, contrast) | 5,000 to 9,000 EUR | 9,000 to 16,000 EUR | 16,000 to 25,000 EUR |
| Team training (content, development) | 1,200 EUR | 2,400 EUR | 4,000 EUR |
| Re-audit after fixes | 1,500 EUR | 2,500 EUR | 3,500 EUR |
| Annual follow-up (light audit and update) | 1,500 EUR per year | 2,500 EUR per year | 4,000 EUR per year |
| Total timeline | 6 to 10 weeks | 10 to 16 weeks | 4 to 6 months |
The most variable item is fixes. A site built on a generic theme or page builder may need a partial template rebuild, while a recent custom site can often be fixed in a few days.
Mini case study
Need a professional website?
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Camille, e-commerce manager of an office supplies company (45 staff, 9 million EUR turnover, 40% online), orders a 5,000 EUR audit. Result: 61% compliance, with a checkout unusable by keyboard. Fixes cost 12,000 EUR, training 2,400 EUR and the re-audit 2,500 EUR, a total of 21,900 EUR. The re-audit reaches 89%. Mobile conversion rises from 1.8% to 2.0% thanks to simplified forms. On 3.6 million EUR of online sales, that gain represents about 400,000 EUR of additional revenue per year, not counting the penalty risk avoided.
FAQ
Is a "non-compliant" statement better than no statement?
Yes. Having no statement is a breach in itself, while an honest statement with a plan and schedule shows good faith.
Do we need to audit every page?
No, the audit covers a representative sample of 10 to 20 pages: home, contact, search, product page, basket, payment, customer account, legal notice. Fixed templates then benefit the whole site.
Is an accessibility overlay plugin enough?
No. These overlays at 300 to 1,000 EUR per year do not fix the source code and are regularly criticised by disability organisations. They replace neither the audit nor the fixes.
How long is a statement valid?
It must be updated after each major change to the site and at least once a year. An audit older than 3 years is no longer considered representative.
Should we target WCAG 2.1 AA or 2.2?
EN 301 549 still references WCAG 2.1 AA in 2026. Targeting WCAG 2.2 AA now costs 5 to 10% more and anticipates the next revision.
Let's scope your project. WCAG audit, accessibility statement, multi-year plan and fixes, from 4,000 to 35,000 EUR depending on site size, delivered in 6 weeks to 6 months. Detailed quote within 48 h. WhatsApp +221 77 596 93 33.
Mohamed Bah
Fondateur, Kolonell
Passionate about digital and entrepreneurship in Africa, Mohamed has been helping Sénégalese businesses with their digital transformation since 2020. Founder of Kolonell, he believes every SME deserves a professional and accessible online présence.
