The verdict in three sentences
Digital accessibility is no longer an image issue: since 28 June 2025, the European Accessibility Act, transposed in Luxembourg by the law of 8 March 2023, covers consumer services (e-commerce, banking, transport, telecoms) on top of public sector websites already in scope. A realistic budget combines an audit of EUR 2,500 to 8,000, EUR 5,000 to 40,000 of fixes and an accessibility statement with a multi-year plan. Doing nothing exposes you to orders, fines and service withdrawal; for reference, France caps the statement penalty at EUR 50,000 per service, renewable.
Who is in scope in 2026 and why
Two regimes overlap. Public bodies have followed the Web Accessibility Directive since 2019. The EAA covers products and services sold to consumers, whatever the company size, with an exemption for microenterprises. Luxembourg's financial centre is particularly exposed through online banking, payments and insurance.
| Company profile | Obligation | Standard | Required documents |
|---|---|---|---|
| Public sector body | Yes, since 2019 | EN 301 549 / RAWeb | Statement, multi-year plan |
| B2C e-commerce (≥ 10 staff or > EUR 2M turnover) | Yes, since 28/06/2025 | EN 301 549 | Statement, service accessibility information |
| Online banking, retail insurance, payments | Yes, since 28/06/2025 | EN 301 549 | Statement, compliant user journeys |
| Passenger transport (ticketing) | Yes, since 28/06/2025 | EN 301 549 | Statement, accessible booking flows |
| Pure B2B SME (corporate site) | Not in principle | WCAG 2.2 AA good practice | Recommended for public tenders |
| Microenterprise (< 10 staff and < EUR 2M) | Exempt for services | None | None |
Watch out: a B2B site that also sells to individuals, even marginally, can fall under the EAA for its checkout journeys.
What an accessibility retrofit costs in 2026
| Item | Corporate site (20 to 40 pages) | E-commerce or client portal | Complex platform (client area, app) |
|---|---|---|---|
| Audit (page sample) | EUR 2,500 to 3,500 | EUR 4,000 to 6,000 | EUR 6,000 to 8,000 |
| Technical and design fixes | EUR 5,000 to 10,000 | EUR 12,000 to 25,000 | EUR 25,000 to 40,000 |
| Content fixes (alt text, PDFs, videos) | EUR 1,500 to 3,000 | EUR 3,000 to 6,000 | EUR 6,000 to 12,000 |
| Verification re-audit | EUR 1,200 | EUR 2,000 | EUR 3,000 |
| Team training (1 day) | EUR 1,500 | EUR 1,500 to 3,000 | EUR 3,000 to 5,000 |
| Total timeline | 6 to 10 weeks | 3 to 5 months | 6 to 9 months |
The main variable is the quality of existing code. On a site built without accessible components, a rebuild can cost less than stacked fixes: we recommend it when the audit exceeds 60% failed criteria.
Penalties and a three-phase timeline
| Risk or step | 2026 detail | Amount or duration |
|---|---|---|
| Missing accessibility statement | Administrative penalty per online service (France benchmark) | Up to EUR 50,000, renewable every 6 months |
| EAA non-compliance of a consumer service | Formal notice from the market surveillance authority, then sanction | Fine and possible withdrawal of the service |
| Phase 1: diagnosis | Audit, interim "non-compliant" statement published | Weeks 1 to 4 |
| Phase 2: remediation | Critical journeys first (sign-up, payment, contact) | Months 2 to 5 |
| Phase 3: governance | Re-audit, 3-year plan, yearly action plan | Month 6 onward |
| Reputation and litigation | User complaints, disability association actions | Hard to quantify |
Publishing an honest statement, even "partially compliant", with a dated plan is always better than no statement.
Mini case study
Julien, digital director of a retail group operating in Luxembourg and the Greater Region (4 websites, 2 of them e-commerce), finds that no accessibility statement is published. Using the France benchmark, theoretical exposure is 4 services × EUR 50,000 = EUR 200,000, renewable every six months.
Need a professional website?
Kolonell builds websites that attract clients, optimized for the Sénégalese market. Free quote in 2 minutes.
He commissions 2 e-commerce audits (2 × EUR 5,000) and 2 corporate site audits (2 × EUR 3,000), EUR 16,000, then EUR 48,000 of fixes and EUR 6,000 of re-audits and training. Total: EUR 70,000 over 7 months. Measured side effect on checkout: mobile conversion up 0.3 points, about EUR 90,000 of extra revenue over a year for a EUR 30M site.
FAQ
Does my B2B company have to comply?
If you sell to consumers, yes. Otherwise it is not mandatory, but a EUR 1,200 to 2,500 basic audit reassures public buyers.
How long does an accessibility audit take?
From 5 to 15 days depending on the sample, usually 10 to 30 representative pages.
Should we aim for 100% compliance?
WCAG 2.2 level AA has 55 success criteria. Start with critical journeys, then go past 75% compliant criteria, a common threshold for a credible "partially compliant" site.
Are PDFs in scope?
Yes, any downloadable document needed to use the service. Remediating a PDF costs EUR 50 to 300 depending on length.
Is an overlay widget enough?
No. These EUR 50 to 500 a month scripts do not fix the code and do not make a site compliant.
Let's scope your project. Tell us how many sites and journeys are in scope: we will price the audit, fixes and accessibility statement, from EUR 2,500 to 40,000 depending on scope, with a three-phase timeline. 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.
