The verdict in three sentences
Since 28 June 2025, the European Accessibility Act applies to companies offering online services to consumers, and a 120-employee services firm has no remaining argument for postponing the work. A realistic 2026 budget sits between EUR 7,500 and 26,000 excluding VAT: a WCAG 2.1 AA audit at EUR 2,500 to 6,000, then fixes at EUR 5,000 to 20,000 depending on your starting conformance rate. The method that works is to target 75% conformance within three months by fixing templates first, then 100% over 12 to 18 months with a published multi-year plan.
Who is covered and what you risk
Directive (EU) 2019/882, transposed in Ireland by the European Union (Accessibility Requirements of Products and Services) Regulations 2023 (S.I. No. 636 of 2023), covers e-commerce, banking services, passenger transport, electronic communications and e-books. Only service micro-enterprises (fewer than 10 staff and under EUR 2 million turnover) are exempt. If your website lets people subscribe, book, pay or open an account online, you are in scope.
The technical reference is EN 301 549, which maps to WCAG 2.1 level AA: 50 success criteria across perception, operability, understandability and robustness. In France the same requirements are expressed through the RGAA 4.1 framework (106 test criteria), which many auditors also use as a detailed checklist. Market surveillance authorities can investigate, and Irish law provides for fines of up to EUR 60,000 on indictment.
| Obligation | What it involves | 2026 order of magnitude |
|---|---|---|
| WCAG 2.1 AA audit | Criteria tested on 15 to 20 representative pages | EUR 2,500 to 6,000 |
| Accessibility statement | Conformance level, exemptions, contact, enforcement route | Included or EUR 400 to 800 |
| Multi-year accessibility plan | Three-year strategy, updated yearly | EUR 800 to 1,500 |
| Annual action plan | Prioritised fixes and schedule | EUR 500 to 1,200 |
| Footer link | Accessibility status: non, partially or fully compliant | One hour of integration |
| Penalty for non-compliance | Up to EUR 60,000 on indictment (Ireland) | Risk to provision |
Remediation cost by starting point
Most company websites we audit start between 30% and 50% conformance. The most frequent failures never change: insufficient contrast, images without text alternatives, form fields without labels, menus, carousels and modals unusable with a keyboard, untagged PDF documents. The rate is calculated on applicable criteria, usually 55 to 70 test criteria on a services website.
| Starting conformance | Applicable criteria failing | Remediation budget | Time to reach 75% |
|---|---|---|---|
| Below 30% | More than 40 | EUR 15,000 to 20,000 (or rebuild) | 4 to 6 months |
| 30 to 50% | 30 to 40 | EUR 9,000 to 15,000 | 2 to 4 months |
| 50 to 75% | 15 to 30 | EUR 5,000 to 9,000 | 6 to 10 weeks |
| Above 75% | Fewer than 15 | EUR 2,500 to 5,000 | 3 to 6 weeks |
| Validation re-audit | Same page sample | EUR 1,500 to 3,000 | 2 weeks |
| Content team training (1 day) | Marketing and editors | EUR 1,200 to 2,000 | 1 day |
Above EUR 20,000 of fixes on an ageing website, an accessible-by-design rebuild deserves consideration: on a new project, the accessibility overhead falls to 5 to 10% of the budget.
The method to move from 40% to 75%, then 100%
The order of work matters more than the budget. Fixing templates (header, menu, footer, standard forms) resolves 50 to 60% of failures at once, because they repeat on every page.
| Phase | Scope | Duration | Target rate |
|---|---|---|---|
| 1. Audit | 15 to 20 pages, keyboard and screen reader tests (NVDA, VoiceOver) | 2 to 3 weeks | Baseline |
| 2. Templates | Menus, forms, contrast, headings, skip links | 4 to 6 weeks | 60 to 65% |
| 3. Components | Modals, tabs, carousels, error messages | 3 to 4 weeks | 75% and above |
| 4. Publication | Partially compliant statement, multi-year plan | 1 week | 75% published |
| 5. Content and PDFs | Alternatives, tagged documents, captioned videos | 6 to 12 months | 90 to 100% |
| 6. Maintenance | Annual re-audit, check before every release | Ongoing | Stability |
Require a criterion-by-criterion report and a tracking grid your teams can use, otherwise the rate drops with the first marketing campaign.
Mini case study
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Kolonell builds websites that attract clients, optimized for the Sénégalese market. Free quote in 2 minutes.
Siobhan, CEO of a home services network based in Dublin (120 employees, contracts subscribed online), orders an audit for EUR 4,200. Result: 26 criteria passing out of 64 applicable, i.e. 41%. Fixes cost EUR 7,800 on templates, EUR 3,600 on components and EUR 1,400 on PDFs, i.e. EUR 12,800, plus EUR 2,000 for the re-audit. Total investment: EUR 19,000. Three months later, the re-audit measures 78%.
Measured side effect: the subscription form, now usable with a keyboard and with explicit error messages, gains 9% in completion rate. On 1,200 online subscriptions a year, that is 108 extra contracts at EUR 180 margin, i.e. EUR 19,440: the project pays back in under 12 months, before even counting the avoided penalty risk.
FAQ
Is a 120-employee company really covered by the European Accessibility Act?
Yes, as soon as it provides a service covered by the directive to consumers online. The exemption only applies to micro-enterprises with fewer than 10 staff and under EUR 2 million turnover. A purely B2B website is out of scope, but more and more public buyers and large accounts require WCAG 2.1 AA in their tenders.
How long does an accessibility audit take?
Allow 8 to 15 working days for a 15 to 20 page sample, report included. The deliverable must contain the full criteria grid, the conformance rate and a prioritised list of fixes.
Is an accessibility overlay widget enough?
No. These overlays at EUR 30 to 100 a month do not fix the source code and handle at best 20 to 30% of issues. They do not allow you to state a conformance level and have triggered many lawsuits in the United States.
Should we aim for 100% straight away?
No, what matters is demonstrating a credible process. Above 50% you can state partial compliance, and 75% within three months backed by a multi-year plan is a defensible position during an investigation.
What yearly budget should we plan once compliant?
Plan EUR 2,000 to 5,000 a year for a re-audit, training new editors and checking new pages. That is the price of not losing 15 to 20 points of conformance in a single year.
Let's scope your project. Send us your website address and we will price the audit, the remediation envelope and the schedule to reach 75% in three 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.
