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Web accessibility - who the obligation covers since 2025

Digital accessibility has stopped being a topic only for public bodies - since 2025 it covers some private companies too

Krystian Kacik 8 min read
Contents

Digital accessibility has stopped being a topic only for public bodies - since 2025 it covers some private companies too. The reason is the European rules on the accessibility of products and services, known as the European Accessibility Act, whose requirements have applied since 28 June 2025; in Poland they were implemented by the act of 26 April 2024 on ensuring compliance with accessibility requirements for certain products and services. In short: if you sell services to consumers electronically, your site or store should also be usable by people who do not see well, do not use a mouse or do not hear.

I am writing this as an introduction, not as legal advice - what follows is the technical substance, meaning what actually has to be fixed on a site and what it usually costs. If you want to see straight away what reviewing and improving an existing site involves, that is a separate topic, but accessibility fits into it naturally, because in practice it touches the same layers as speed and tidy code.

Who web accessibility really applies to

The new rules are aimed above all at services sold to consumers over the internet. In practice that means:

  • online stores and other services provided to consumers online, meaning the whole path from product page through cart to payment
  • banking and financial services for consumers
  • passenger transport - tickets, timetables, travel handling online
  • e-books and digital content platforms
  • telecoms - subscriber services, customer panels

A separate and much older track is the public sector. Sites of public offices, schools, hospitals and institutions have been subject to accessibility requirements for years, under a 2019 act refined by a 2023 amendment. That track continues on its own course - a second, commercial one has simply appeared alongside it.

And now an important caveat that has to be said outright: the rules provide exemptions for the smallest service companies, that is micro-enterprises, and the details depend on the type of activity and exactly what you sell. Watch for the catch: the exemption concerns providing services. If the same micro-company places products covered by the act on the market - payment terminals or e-book readers, for example - there is no exemption in that respect. Which means a blog article cannot answer “yes” or “no” for you. If you have doubts about whether your business falls under the obligation, check the current wording of the act or ask a lawyer - I describe the technical layer, not the legal one, and I will not pretend otherwise.

What level AA specifically means

The rules do not describe the look of a button or the colours. Formally they do not even say “WCAG” - they refer to a European technical standard, and that standard carries the WCAG 2.1 guidelines at level AA. That is today’s binding reference point. The newer version of the guidelines, 2.2, is being prepared for reference in the standard, but as of today it does not change the legal position.

In plain language AA means roughly this: the text can be read without squinting, the whole site can be operated with a keyboard alone, and what you can see with your eyes is also described in words - for a screen reader and for anyone who cannot see the image. It is not a list of technical extravagances but a set of things a good site should have anyway. I take levels A, AA and AAA apart in the piece on what an accessibility audit covers.

Six things that most often fail

When I look under the bonnet of a site that was never designed for accessibility, almost always the same six points come back:

  1. Text contrast - light grey text on white looks elegant on a designer’s monitor and disappears on a phone in sunlight. The most common problem and at the same time the cheapest to fix.
  2. Keyboard operation and a visible focus - go through your site using the Tab key alone. If you cannot see where you currently are, or you get stuck in a menu or a pop-up that will not close, you have a problem, and not only a formal one.
  3. Alternative descriptions for images - product photos with no description are a blank wall to a screen reader. It is not about typing in keywords, but about a short, honest sentence: what is in the picture.
  4. Forms - a field with no label, an error message expressed only as a red border, no information about which field exactly is filled in wrongly. That is a conversion killer on every form and in every cart.
  5. Heading hierarchy - one H1 heading, then sensible H2s and H3s. Headings used as decoration (“because that font looks nicer”) scatter all navigation through the content.
  6. Videos with no captions - a video on the home page where the entire message is spoken and written down nowhere. Captions solve it not only for deaf people but for everyone watching with the sound off.

What helps: before you order any audit, run two free tests yourself - walk the whole buying path using only the Tab key, then open the site on a phone outdoors in full sunlight. Those two passes catch more of the real problems than a long list of automatic warnings from a tool, because they show where the site stops being usable rather than only where it breaks a rule.

Why it pays off even when you do not have to

Reducing accessibility to an obligation is short-sighted. A site built on these principles is simply more comfortable for everyone. Better contrast means readability on a phone in sunlight, which is where most traffic actually lands. Correctly labelled forms mean fewer mistakes when filling them in and fewer people abandoning halfway - exactly the mechanism I write about in the piece on shortening WooCommerce checkout.

There is also a layer few people mention: a tidy page structure - headings, descriptions, sensible labels - is easier to understand for a search engine and for the AI systems that today answer questions instead of showing a list of links. It is the same tidiness in the code that improves Core Web Vitals scores. You do one job and collect from several directions.

And the most overlooked point: older customers. They are often the segment with the greatest purchasing power and the least patience for sites where a small button cannot be clicked or a price cannot be read. A comfortable site is not a gesture of goodwill towards them, it is the condition for them finishing the purchase at all.

What it costs - honestly

On a new site, accessibility costs little. It is mainly a matter of design decisions taken at the start: colours chosen with adequate contrast, a consistent heading hierarchy, forms built properly the first time. Done straight away it is part of the craft, not a separate line in the quote - with me it fits inside a normal fixed-bid project in the 5,000-10,000 PLN net range.

On an old site it can be a renovation. If the theme has poor contrast baked in, the menu does not work from a keyboard, and the forms are generated by a plugin that cannot be sensibly configured - that is not an hour’s fix. Which is why with existing sites I start with a review rather than rewriting everything: first we know what specifically fails and what can be fixed within the current construction, and what needs an element replaced. What an accessibility audit covers and what drives its price I set out separately. Very often it turns out half the list is minor fixes and the rest waits for the moment you are planning a site rebuild anyway. If the site is alive and changes every month, accessibility also fits naturally into ongoing care - then it is watched alongside every change instead of a big operation once every three years.

Frequently asked questions

Does my small brochure site have to be accessible? The rules are aimed at services sold to consumers electronically and provide exemptions for the smallest companies, so an ordinary brochure site with no online sales is in a different position from a store. It is worth confirming the specific answer for your business with a lawyer, because it depends on what you sell and to whom.

Does an accessibility widget plugin sort it out? No. Overlays that add font enlargement or a high-contrast mode improve a few things on the surface, but they do not fix what sits in the code: missing image descriptions, forms with no labels, or navigation you cannot get through with a keyboard.

Where do I start if I already have a site? With a review that identifies the specific places and their severity. Without it, it is easy to spend money on cosmetics while leaving untouched what really blocks people from using the site.

Will accessibility slow the site down or spoil the design? No, if it is done in the code rather than as a bolted-on overlay. Alternative descriptions, labels and a correct heading structure weigh practically nothing, and contrast and a visible focus are a design decision, not a surrender of aesthetics.


Sitting on this yourself and unsure where to start? I speed up and repair existing sites and stores - Core Web Vitals, outages, the features that are missing. Tell me what is happening and you will get a concrete quote with a date.

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