The verdict in three sentences
Since 28 June 2025, the European Accessibility Act, transposed in Ireland and every EU member state, requires businesses selling digital services to consumers, including most mid-sized e-commerce retailers, to publish an accessibility statement based on an audit. A WCAG 2.1 AA audit (the EN 301 549 baseline) on a 20 page sample costs EUR 3,500 to 8,000 excl. VAT, and fixes EUR 8,000 to 30,000 excl. VAT depending on a starting conformance rate often between 35 and 55 %. Publishing nothing exposes you to fines that, depending on the member state, reach EUR 50,000 per non-compliant service in France and tens of thousands of euros in Ireland, on top of enforcement orders.
Who is covered and what the statement contains
The obligation covers e-commerce services, consumer banking, transport, electronic communications and e-books. Microenterprises with fewer than 10 staff and under EUR 2 million turnover are exempt for services. A 400-employee retailer selling online, with a customer account or booking feature, is clearly in scope.
The accessibility statement is a public page, reachable from every page of the site, stating the conformance level, inaccessible content and any exemptions claimed, the date and method of the audit, a contact for reporting issues and the enforcement route. It should be backed by a multi-year accessibility strategy over 3 years and an annual action plan.
| Required document | Minimum content | Update cycle | 2026 production cost |
|---|---|---|---|
| Accessibility statement | Conformance level, failures, contact, enforcement route | Each audit, at least every 3 years | EUR 500 to 1,200 if audit done |
| Multi-year strategy | Policy, resources, training, scope over 3 years | Every 3 years | EUR 800 to 2,000 |
| Annual action plan | Planned fixes, budget, owners | Yearly | EUR 400 to 1,000 |
| WCAG audit report | Success criteria tested on the sample | After any major redesign | EUR 3,500 to 8,000 |
| Re-test report | Verification after fixes | After each batch | EUR 1,500 to 3,000 |
What fixes cost depending on your starting point
Cost depends less on page count than on the number of templates and components: a defect in the menu is fixed once and disappears across 2,000 pages. Complex components (catalogue filters, carousels, checkout, multi-step forms, PDFs) often account for 70 % of the effort.
| Starting conformance | Typical site profile | 2026 fixes | Timeline | Target after fixes |
|---|---|---|---|---|
| Under 30 % | Old site, unmaintained theme, many PDFs | EUR 20,000 to 30,000, or redesign | 4 to 6 months | 75 to 85 % |
| 35 to 45 % | 3 to 5 year old site, custom JavaScript components | EUR 14,000 to 22,000 | 3 to 4 months | 80 to 90 % |
| 45 to 55 % | Partial design system, standard forms | EUR 8,000 to 15,000 | 2 to 3 months | 85 to 95 % |
| 55 to 75 % | Recent site built with care | EUR 4,000 to 9,000 | 4 to 8 weeks | 90 to 100 % |
| Over 75 % | Accessible design system | EUR 1,500 to 4,000 | 2 to 4 weeks | 95 to 100 % |
Add training for content teams (1 day, EUR 900 to 1,500 per session): without it, new pages reintroduce images without alt text and broken heading structures, and conformance drops 10 to 20 points within a year.
Fines and the real risk
Enforcement is carried out by the market surveillance authorities each member state designates, on complaint or through sweeps. A missing statement is the easiest failure to detect and the first to be sanctioned. Beyond fines, the commercial risk is concrete: more and more enterprise tenders and marketplace partners require a published statement and a minimum conformance level, often 75 %.
Mini case study
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Aoife, head of digital at a 400-employee medical supplies retailer in Cork, orders a WCAG audit on 20 pages for EUR 5,800 excl. VAT. Result: 42 % conformance, with 9 components at fault including checkout and catalogue filters. Fixes are priced at EUR 17,500 over 14 weeks, a re-test at EUR 2,200 and training for 12 contributors at EUR 1,300. Total budget: EUR 26,800 excl. VAT, under 54 % of a single EUR 50,000 fine. Her e-commerce site turns over EUR 3.2 million a year: a 1.5 % conversion uplift from clearer forms would represent about EUR 48,000 of additional revenue, a 2026 order of magnitude.
FAQ
Is a retailer that only sells B2B covered?
The EAA targets services offered to consumers. A purely B2B portal is generally out of scope, but around 75 % of mid-sized retailers have at least one consumer-facing service such as checkout or booking.
Can we publish a statement without an audit?
No, the statement must rest on a documented evaluation. An audit of 20 representative pages costs EUR 3,500 to 8,000 excl. VAT and stays valid for 3 years barring a major redesign.
Is an accessibility overlay widget enough?
No, these tools at EUR 500 to 3,000 a year do not fix the source code and do not make a site compliant. They can even interfere with screen readers.
How long to go from 42 % to 85 %?
Allow 3 to 4 months of fixes in batches, starting with shared templates and components, which cover 80 % of defects.
Should we aim for 100 % conformance?
100 % is rare on a feature-rich site. A rate of 85 to 95 %, justified exemptions and a tracked action plan form a defensible position.
Let's scope your project. Send us your site URL and a list of your online services: we scope the WCAG audit, fix plan, statement and training, with an indicative budget of EUR 12,000 to 35,000 excl. VAT and compliance in 2 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.
