EAA Accessibility Checklist for a Small Business Website

The eaa accessibility checklist for a small business website starts with two questions: does the European Accessibility Act (EAA) cover your service, and can people with disabilities use your key website journeys? The checklist below helps you assess scope, find common barriers and organise practical fixes; it is not a legal compliance verdict.

Key takeaways

• The EAA covers specified products and services, including e-commerce—not every business website automatically.
• A microenterprise exemption may apply to qualifying service providers, but it is not a blanket exemption for all small businesses or websites.
• Test the complete journey, such as booking or checkout, rather than checking only the homepage.
• Automated scans can identify some issues, but manual checks and user-focused testing are also important.
• Record findings, fixes and retest results, and check your national requirements if the EAA may apply.

1. EAA accessibility checklist for a small business website: check scope first

Before reviewing colours, buttons or forms, work out whether the EAA applies to your business and service. The Act applies to specified products and services, and e-commerce services are among the covered categories. It does not automatically impose the same requirements on every business website simply because that site is available online.

The EAA began applying to covered products and services on 28 June 2025. If you sell to EU consumers online, or let customers arrange or pay for a service through your site, check whether your particular activity falls within the rules. The EU Your Europe guidance explains the scope and the microenterprise exemption. National implementation and the details of your service can matter, so confirm your position using the rules that apply where you operate.

Does the microenterprise exemption apply?

The Directive provides an exemption from its service requirements for microenterprises providing services. The definition is fewer than 10 employees and annual turnover or balance-sheet total not exceeding €2 million. Meeting the size test alone does not settle every question: the exemption is specifically for qualifying service providers, and your business activity matters.

Your situation	Practical next step
You run a general information website	Check whether the business or service is within an EAA-covered category; do not assume that every website is covered.
Customers buy products through your website	Check whether your online selling service is covered and whether any relevant exemption applies.
Customers book, arrange or pay for a service online	Review the service and your business status against the EAA and national rules.
You may qualify as a microenterprise service provider	Confirm the employee and financial criteria, the nature of your service and the national implementation.

Even if an exemption applies, accessible design can make your site easier for more people to use and can reduce friction in customer journeys. Treat the checklist as a practical improvement tool, while separating that work from the legal question of whether a requirement applies to you.

2. Choose the pages and journeys that matter most

A quick homepage review will not tell you whether a customer can complete a task. Start by listing the journeys that matter to your business and the pages or components each one uses.

For an online shop, include product discovery, product details, adding an item to the cart, checkout, payment and order confirmation. For a service business, include service information, availability, booking or enquiry, payment if offered, confirmation and a route to get help. Add the cookie banner, navigation menu and any account or contact forms that customers need to use along the way.

Create a short test list for each journey:

1. Start at the same point a customer would, such as a product page or booking page.
2. Complete the task using a keyboard, without a mouse.
3. Check that you can tell where you are on the page and what action to take next.
4. Try a common error, such as leaving a required field blank or entering an invalid email address.
5. Confirm that the error is clear and that you can correct it and finish the task.
6. Check the confirmation and any support route, not just the form submission.

Write down the page, the steps you took and what happened. A reproducible note such as “On mobile checkout, tabbing from the delivery field skips the continue button” gives a developer a much clearer starting point than “checkout is inaccessible.”

3. Run a hands-on accessibility checklist

The EAA’s web-accessibility requirements are organised around four principles: perceivable, operable, understandable and robust. These give you a useful way to group your checks. They are also reflected in the Accessibility Act text.

Perceivable: can people find and understand the information?

• Images: Check that meaningful images have text alternatives that explain their purpose or useful information. A product image may need a concise description of what it shows; a decorative image may not need a spoken description.
• Headings and structure: Read the page headings in order. They should describe the content and help people move through the page, rather than acting only as large or bold text.
• Contrast: Check text against its background, including button labels and text over images. WCAG 2.1 AA sets a minimum contrast ratio of 4.5:1 for normal text and 3:1 for large text, subject to stated exceptions. See W3C’s contrast guidance.
• Media: If a video gives customers important information, check that captions are available and accurate enough to convey its spoken content.
• Zoom and reflow: Enlarge text and view the site on a narrow screen. Check that text remains readable and essential content or controls do not disappear or require awkward horizontal scrolling.

Operable: can people use the controls?

• Keyboard: Use Tab and Shift+Tab to move through links, buttons and form fields. Use Enter or Space to activate controls where appropriate. You should be able to complete the important journey without a mouse.
• Visible focus: Watch for a visible indicator that shows which control is currently selected. It should not vanish against the page or be hidden behind a banner or sticky header.
• Menus and dialogs: Open and close the navigation menu, cookie banner and any pop-up. Check that keyboard users can reach the available choices and return to the page without getting stuck.
• Time and motion: Look for time limits or moving content that could make a task difficult to complete. Check whether users can pause, stop or extend where relevant.

Understandable and robust: do pages behave clearly?

• Forms: Check that every field has a clear label, required fields are identified, and instructions appear before people need them.
• Errors: Submit a form with missing or invalid information. Confirm that the problem is described in text, that the affected field is clear and that the user gets guidance on correcting it.
• Consistency: Check that navigation and recurring controls behave consistently from page to page.
• Compatibility: Test the site in more than one current browser and, where possible, with assistive technology. A control that looks clickable but is not announced or operated correctly can block a task.

For a useful checklist of quick checks and their limits, refer to W3C’s preliminary accessibility review. It is a starting point, not a definitive evaluation.

4. Combine automated scans with human checks

An automated scan can help you spot certain technical issues across multiple pages, such as missing labels or some contrast problems. It can save time and help you organise a first round of fixes. But it cannot reliably judge whether an image description makes sense, whether an error message helps a customer recover, or whether the booking journey is understandable from start to finish.

Use a simple three-part review:

1. Scan: Run an automated check on representative pages and note the page and element for each finding.
2. Manually test: Follow key journeys with a keyboard, zoom the page and test forms with errors. Review the meaning and clarity of content as well as technical flags.
3. Retest: After fixes are made, repeat the same steps and confirm that the issue is resolved without creating a new barrier.

Keep scan results in perspective. A clean automated report does not establish that your site complies with the EAA or that people using assistive technology can complete every task. W3C also describes its quick checks as covering selected issues rather than providing a definitive assessment.

If you want a structured first pass, the KlearKomply free Quick Scan can review up to 10 pages and flag issues for review. The €29 one-time Full Readiness Scan covers up to 50 pages and provides developer-ready fix briefs. Use either as a readiness and triage aid—not as a legal verdict—and verify findings through manual testing and remediation.

5. Turn findings into a clear fix list

A useful accessibility report helps someone act. Avoid a long list of technical warnings with no explanation. For each issue, record:

• Where it occurs: the page, component and, if possible, the relevant control.
• What you did: the steps that reproduce the issue, including device or input method when relevant.
• What happened: the observed result and the expected result.
• Who may be affected: describe the barrier in practical terms, such as a keyboard user being unable to submit a form.
• What to try next: give a suggested direction for investigation or remediation, without assuming one code change suits every site.
• Retest status: note when it was fixed and whether the original steps now work.

Prioritise issues that stop people completing a key task: inaccessible navigation, a blocked checkout, an unusable booking form or an error that cannot be found or corrected. Then address repeated component problems, such as buttons with missing labels, followed by less critical presentation issues. Prioritisation does not mean leaving other known barriers untracked; it helps you plan work in a sensible order.

Share the same reproduction steps with your web developer. For more context on what a scan can flag and how to follow up, see EAA Website Accessibility Scan: What It Checks and What to Do Next.

6. Document your approach and retest after changes

Keep a simple record of the pages tested, the checks performed, findings, decisions, fixes and retest dates. This helps you see what has changed and prevents a fix from being forgotten when a template or plugin is updated.

Do not assume that an “accessibility statement” is a universal substitute for accessible service information. EAA Annex V says service providers must include information assessing how their service meets accessibility requirements in their general terms and conditions or an equivalent document. What you need to provide depends on whether the rules apply to your service and on relevant national implementation. Check the Directive’s Annex V and local guidance for your situation.

Retest after changes that could affect access: a redesign, new checkout or booking tool, changed cookie banner, new form, updated theme or major content revision. Also repeat key checks periodically as part of ordinary site maintenance. You do not need a complicated system to start: a dated checklist and clear notes are more useful than an undocumented one-off scan.

7. A practical first-week plan

If you are starting from scratch, use this short sequence to make the work manageable:

Day 1: confirm scope and choose journeys. Identify what customers can do on the site and check whether the EAA may apply to the service. Note any uncertainty to verify against national rules.

Day 2: test the main journey. Choose the highest-value task—such as buying, booking or contacting you—and try it using only a keyboard. Record barriers and the steps that led to them.

Day 3: check core page basics. Review headings, image alternatives, labels, error messages, contrast and zoom on the pages in that journey.

Day 4: scan and compare. Use an automated scan as another source of findings. Combine its results with your own checks instead of treating the scan as a pass/fail verdict.

Day 5: assign fixes and retest. Give your developer a prioritised, reproducible list. Retest the original journey after changes and save the results.

This sequence turns a broad requirement into manageable work. Start with the customer tasks that matter most, make specific improvements, and keep checking as the site changes. For a guided starting point, explore KlearKomply’s website readiness tools.