Does my website have to be accessible?

It depends on the website's role. If it delivers a covered consumer service, such as e-commerce, and the service provider is not an exempt microenterprise, the website and the complete service journey should meet the applicable accessibility requirements.

What accessibility requirements apply to a website?

A website should support keyboard use, zoom and reflow, sufficient contrast, correctly labeled forms, meaningful alternative text, logical structure, and feedback available to assistive technologies. WCAG 2.1 AA is an important reference, but legal compliance can include broader service and information duties.

Which organizations are covered by the EAA and Polish Accessibility Act?

The rules cover specified products and consumer services, including e-commerce, consumer banking, e-books, certain transport services, electronic communications, and access to audiovisual media. Polish microenterprises providing services are generally exempt from the service requirements.

Does every business website need to meet WCAG 2.1 AA?

No. Owning a website does not by itself place a business within the Polish Accessibility Act. The product or service, consumer audience, provider size, and other applicable laws or contracts must be considered.

When did the EAA requirements take effect?

Poland's implementing act has applied since June 28, 2025. In 2026, covered businesses should already be meeting the requirements.

Can an automated scanner confirm WCAG conformance?

No. A scanner detects only some technical issues. A complete assessment also requires manual, keyboard, screen-reader, and end-to-end journey testing.

Does Your Business Need to Comply With the EAA and WCAG 2.1 AA?

The European Accessibility Act (EAA) has applied across the EU since June 28, 2025. In Poland, it is implemented through the Polish Accessibility Act (PAD). For covered businesses, accessibility is no longer a future project.

This guide helps you ask the right questions. It is general information, not legal advice; confirm borderline cases with qualified counsel.

EAA, PAD, and WCAG 2.1 AA

The EAA is EU Directive 2019/882, which establishes accessibility requirements for specified products and services. PAD is the Polish act implementing those requirements. WCAG 2.1 AA is a key technical benchmark for websites and apps, also reflected in EN 301 549, but legal compliance may include additional information, support, and sector-specific duties.

A six-step applicability check

1. Do you offer a covered product or service?

Covered areas include certain consumer computer hardware and operating systems, payment terminals, self-service terminals, e-readers, electronic communications, access to audiovisual media, parts of passenger transport, consumer banking, e-books, and e-commerce.

For a website, e-commerce is especially important: a service provided remotely, through a website or mobile service, at a consumer's individual request, with a view to concluding a consumer contract.

2. Is the service offered to consumers?

The EAA focuses on consumer products and services. A purely business-to-business offer may fall outside this particular regime, although other laws, contracts, procurement rules, or funding conditions can still require accessibility.

3. Is the service provider a microenterprise?

Under the EAA framework, microenterprises providing services are exempt. A microenterprise generally employs fewer than 10 people and has annual turnover or an annual balance-sheet total no greater than EUR 2 million. This service exemption should not be assumed to cover products.

4. Is the website part of the covered service?

An informational company page does not automatically become covered merely because a business owns it. A site used to select, order, pay for, manage, or obtain support for a covered service is much more likely to be part of that service.

5. Does an exclusion or transitional rule apply?

Some archived content, third-party content outside the provider's control, and certain pre-existing media or documents may be treated differently. Specific transitional provisions can also apply. Review the exact statutory language rather than relying on a summary.

6. Would compliance impose a fundamental alteration or disproportionate burden?

These are not blanket opt-outs. They require a documented assessment based on the statutory criteria, and any parts that do not create the claimed burden should still be made accessible.

A practical WCAG review

For a first assessment:

Complete every journey with a keyboard alone.
Test zoom to 200% and reflow at 320 CSS pixels.
Check text and non-text contrast.
Review alternative text and decorative images.
Verify headings, landmarks, and reading order.
Test labels, instructions, validation, and error recovery in every form.
Read links and buttons out of context.
Test representative journeys with a screen reader.
Check captions, motion, flashing content, and time limits.
Complete the entire service process, including payment, confirmation, and support.

An automated scanner cannot perform most of these judgments. A high score is evidence about the checks that ran, not proof of conformance.

What should a covered business do now?

Determine the legal scope, inventory all digital touchpoints, audit representative components and complete journeys, prioritize barriers by impact, publish the required accessibility information, and add accessibility to procurement, design, development, content, and quality assurance.

Common assumptions—“we are small,” “the site existed before 2025,” “a widget makes us compliant,” or “the scanner reports 100”—are not reliable legal or technical assessments.

Official sources

Because this topic concerns legal obligations, use the official law applicable to your organization and obtain legal advice where necessary.