In this article
Since 28 June 2025, your online reservation page, your order button and your gift-card checkout have legally counted as 'e-commerce' under the European Accessibility Act. That is not a future deadline — the law has already been in force for over a year, and the first real enforcement is under way. Seven numbers tell you exactly what the law asks, who's exempt, and how accessible your own site already is.
When a venue thinks about 'accessibility', it almost always means the front door, the accessible toilet and a braille menu — the physical side of the dining room. This site already has a thorough article on that, including the revenue an accessible venue picks up. This article is about something else entirely: the digital side. Your website, your online reservation form, your order button, your gift-card checkout — each one a place where a guest with a disability can already be getting stuck today, long before that person ever reaches your door.
This is a house explainer, not legal advice. The European Accessibility Act (Directive (EU) 2019/882) applies EU-wide, but its transposition into national law, the exact enforcement body and the fines differ per member state. Check with your own hospitality or business federation for how your country has implemented it, especially around the microenterprise exemption.
The surprise is in what the law actually calls a 'digital service'. You might think: I don't sell software, I'm not a webshop, so this isn't about me. But the law draws its line at 'e-commerce services' — a deliberately broad definition: every step that leads to concluding a transaction with a consumer counts. A reservation you confirm and charge online, an order taken through a QR-code menu, a gift card a guest buys through your site — all of that is e-commerce in the sense of this law, even though it feels to you like 'just my booking system'.
Seven numbers give you the essentials: when the law took effect, what 'e-commerce service' actually covers, who's exempt, what 'accessible' technically means, how likely your website already is to fail, what a violation can cost, and how many guests this touches directly. Test where your own site stands today in two minutes, at the bottom of this article.
Why this deserves your attention now
The European Accessibility Act is no longer a draft you'll 'get to eventually' — it became enforceable EU-wide on 28 June 2025, meaning every member state has by now transposed it into its own law. That date is over a year behind you, not ahead of you.
And the first real enforcement is happening as you read this: France's consumer watchdog, the DGCCRF, sent formal notices to Auchan, Carrefour, E.Leclerc and Picard in November 2025, after inspections found exactly the failures an average reservation form also has — keyboard navigation that doesn't work, missing alt text, a checkout flow a screen reader can't get through. Penalty decisions are expected in Q2 2026.
This touches you directly as a restaurant owner regardless of whether you built your own website or run on an off-the-shelf reservation system: responsibility for what a guest experiences on YOUR page sits with you as the service provider, not solely with the software vendor behind it.
The 7 numbers
From the date the law took effect to the number of guests it touches directly — in the order you need them to judge your own situation.
1. 28 June 2025 — the deadline that has already passed
The European Accessibility Act (Directive (EU) 2019/882) entered into force as a directive in 2019, had to be transposed into national law by 28 June 2022, and became effectively enforceable in every member state from 28 June 2025. There is no transition period left to wait out — the obligation applies today, for every new or modified service.
For existing services already running before that date, some member states carved out a limited transition window for certain existing contracts and self-service terminals — but that is a bounded exception with its own end date, not a blanket pass. For a reservation page or order button you put online or change today, the obligation applies immediately.
2. 'E-commerce services' — a wider net than you'd assume
The law lists a set of product categories and service sectors it covers — banking, e-books, telephony, passenger transport — and sitting among them is one category that catches almost every restaurant with a website: e-commerce services. The official description is deliberately broad: it covers every step that leads to concluding a contract with a consumer through a website or app, not just the final payment step.
In concrete terms: an online reservation you confirm and possibly charge a deposit or no-show fee on, an order placed through a QR-code menu, a gift card a guest buys on your site — all of it is e-commerce under this law. A purely informational website with no online transaction at all generally falls outside the scope; the moment even one button leads to a payment or a confirmed agreement, the e-commerce obligation is in play.
Four steps every guest goes through, and the failure that shows up most often at each one.
None of these four require a new website — they're fixes you can make with the tools you already have.
3. Fewer than 10 employees and up to €2 million in turnover — who actually gets an exemption
Microenterprises — fewer than 10 employees AND an annual turnover or balance sheet total of no more than €2 million — are exempt from the law's service obligations. That is a threshold most independent, single-location restaurants clear, and it is the single most important number in this whole article for anyone who just wants to know 'does this affect me'.
Three caveats that make the difference. One: the exemption covers services only, not certain products the law also regulates (self-service terminals, for instance, still fall under it). Two: the exemption disappears the moment you grow past the threshold — there is no grace period. Three: it's a self-assessment, not an automatic tick-box — you need to be able to demonstrate you qualify if a regulator asks, and the exact proof required differs by member state.
4. Roughly 50 checkpoints, 4 principles — what 'accessible' actually means
The law itself doesn't spell out a technical checklist — it points to the harmonised European standard EN 301 549, which in turn adopts WCAG 2.1 Level AA, the international benchmark for digital accessibility. At AA level (Level A plus AA combined), that's roughly 50 individual success criteria, grouped under four principles: perceivable, operable, understandable and robust.
For a restaurant website, that translates into very concrete, recognisable things: alt text on dish photos so a screen reader knows what's there, a reservation form that's fully usable with the keyboard alone, sufficient colour contrast between text and background, and captions on a promo video. Further down this article, we break the four principles out one by one with an example from a real booking flow.
Perceivable, operable, understandable, robust — each with an example from a real booking flow.
Together they cover roughly 50 checkpoints at AA level — these are the four broad categories they fall into.
5. 94.8% — the odds your site already fails somewhere
The WebAIM Million, the annual audit of the top one million most-visited home pages worldwide, found at least one automatically detectable WCAG failure on 94.8% of them in its 2025 edition — a slight improvement on 95.9% a year earlier, at an average of 51 errors per page. That figure isn't specific to restaurant websites, but there's no reason to assume hospitality does better than the average of the web.
The most common failures are strikingly recognisable on a restaurant site: too little contrast between text and background, images with no alt text, form fields with no clear label, and links or buttons only usable with a mouse. None of those four requires rebuilding your site — they're exactly the four the free test at the bottom of this article checks for you.
6. €100,000 to €1,260,000 — what a violation can cost
Fines for non-compliance vary sharply by member state, because each country had to transpose the directive into its own national law. Germany allows fines of up to €100,000 per violation, France uses a scale of €5,000 to €250,000 plus an annual €25,000 penalty for missing a mandatory accessibility statement, and Hungary and Spain have written maximum amounts of roughly €1,260,000 and €1,000,000 respectively into their laws.
Worth putting in perspective: no fine has actually been issued under this law yet — the first cases, like the French supermarket chains', are still at the formal-notice-and-remediation-period stage. For a venue covered by the microenterprise exemption, the risk of a fine is also generally low. But the range shows member states are taking this seriously, and that enforcement has genuinely begun.
7. 24% — nearly 90 million EU residents this touches directly
According to Eurostat's 2024 figures, 24% of the EU population aged 16 and over reports some form of disability — roughly 90 million people, about one in four adults. That isn't just wheelchair users: it includes low vision, deafness or hearing loss, motor impairments that make typing or using a mouse difficult, and cognitive disabilities that make an unclear form incomprehensible.
The difference with a physical barrier is that a digital one stays invisible to you. You see a guest who can't get up your steps standing there; a guest whose screen reader can't read your reservation form just closes the tab and books next door — no phone call, no complaint, no way for you to ever know you lost that booking.
Test your own site — two minutes
The seven numbers above tell you what the law asks and who it touches. They don't tell you where your own site stands today — that depends on your size and on six concrete, checkable things.
Enter your employee count and annual turnover for your legal status, and tick off what you already have in place for your accessibility score.
Am I covered — and how ready am I?
Your size decides your legal status. Six checkboxes decide your score.
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This is a self-assessment, not a legal ruling — the microenterprise exemption isn't automatic and its exact application differs by member state. The score measures six common, checkable points, not a full WCAG audit.
This is a quick self-scan, not a substitute for a real WCAG audit — that tests with a screen reader, real keyboard navigation and automated tools against all roughly 50 AA criteria, not just the six above.
What the test does do: show you in two minutes whether your legal status and your practical state of readiness line up. For most independent venues the honest answer is 'likely exempt, with real room to improve' — and that improvement is exactly what a guest with a disability feels first.
What to do with this, this week
None of these steps require a new website — this is a sequence that starts with what pays off most for the least effort.
Today
- Run the test above and note your score and your legal status.
- Check whether your reservation system or website builder already ships accessibility features — many off-the-shelf systems already do part of the work for you.
- Add alt text to your key photos: the dish photos, the ambience shots on your homepage.
This month
- Test your reservation form with the keyboard alone — Tab, Enter, arrow keys — without touching the mouse, and fix what doesn't work.
- Replace a menu-as-image or PDF with a plain text page, or at least add a readable text version alongside it.
- Check the colour contrast of your key text and buttons with a free online contrast checker.
By the end of the year
- Publish a short accessibility statement on your site — what's already in place, what's coming, and how a guest can report a problem.
- Ask your own hospitality or business federation whether you clear the microenterprise exemption exactly, and what it covers in your country.
- Re-run the test above and compare your score to today.
The short version
The European Accessibility Act is no longer something to plan for later — it has applied since 28 June 2025, and the first real enforcement is under way. It touches every restaurant website with an online reservation, order or gift card, because all of that counts as an 'e-commerce service' under the law.
Most independent, single-location restaurants fall under the microenterprise exemption — fewer than 10 employees, up to €2 million turnover — but that's a self-assessment for the service obligations, not a free pass to do nothing: 94.8% of websites worldwide fail at least one of roughly 50 accessibility criteria today, and nothing suggests restaurant sites do better.
Test today, fix the six most common failures, and you'll do it without a rebuild and without a large cost — while reaching the nearly 90 million EU residents who may already be turning away today without you ever knowing it.