Website accessibility stopped being a matter of good intentions in 2025. The European Accessibility Act (Directive (EU) 2019/882) has applied since 28 June 2025, and it binds any company that offers products or services to consumers in the EU — including companies headquartered outside it. In parallel, Turkey brought its own private sector into scope through Presidential Circular 2025/10, published in the Official Gazette on 21 June 2025: banks, private hospitals, private schools, passenger carriers and large telecom operators had one year to comply, and that window closed on 21 June 2026. E-commerce providers have until 21 June 2027.
If you sell into either market, the question is no longer whether accessibility applies to you but which standard you are being measured against. Here is who is covered, what the technical threshold actually is, and what you can check on your own site today.
| Regulation | Who it covers | Deadline | Standard |
|---|---|---|---|
| European Accessibility Act | Companies offering in-scope products or services to consumers in the EU, regardless of where they are established | 28 June 2025 — in force | EN 301 549, i.e. WCAG 2.1 AA |
| Turkey — Circular 2025/10 | Public bodies, universities, municipalities, banks, private hospitals, licensed private schools, road/sea/rail/air passenger carriers, Group A travel agencies, telecom operators with 200,000+ subscribers | 21 June 2026 — passed | WCAG 2.2, Level A |
| Turkey — Circular 2025/10 | E-commerce service providers under Law No. 6563 | 21 June 2027 | WCAG 2.2, Level A |
What is website accessibility?
Website accessibility means a site can be used by people with visual, hearing, motor or cognitive disabilities. In practice it means a page can be navigated with a keyboard and not only a mouse, images carry a text equivalent, text separates clearly from its background, and form fields announce themselves to a screen reader.
The yardstick is a single document everyone agrees on: the W3C's Web Content Accessibility Guidelines (WCAG). It defines three conformance levels — A, AA and AAA. Level A is the minimum threshold; Level AA is the practical target referenced by most regulations worldwide.
Does the European Accessibility Act apply to non-EU companies?
Yes. The obligation follows the market, not the company's address: what matters is whether the product or service is placed on the EU market. A Turkish e-commerce site that accepts orders from consumers in the EU is in scope, and so is a SaaS product sold to EU customers.
Three practical consequences follow:
- The technical threshold is EN 301 549. This harmonised standard adopts WCAG 2.1 AA in full for web content. Meeting it gives you a presumption of conformity with the Act.
- An accessibility statement is mandatory. You must publish information explaining how the service meets the accessibility requirements, and keep procedures in place for ongoing conformity as the service changes.
- The microenterprise exemption is narrow. It applies to services only, and only to businesses with fewer than 10 employees and annual turnover or balance sheet total not exceeding €2 million. Both conditions must hold, and microenterprises placing products on the market are not exempt at all.
Enforcement sits with national market surveillance authorities in each member state, so the penalties themselves vary by country — but the substantive requirement does not.
What changed in Turkey?
Circular 2025/10 is widely misread as a public sector rule. It is not: it names banks, private hospitals, schools licensed by the Ministry of National Education, passenger carriers, Group A travel agencies and telecom operators with more than 200,000 subscribers alongside public institutions, universities and municipalities. All of them were given one year, which expired on 21 June 2026. Only e-commerce service providers under Law No. 6563 received two years, putting their deadline at 21 June 2027.
The circular does not impose administrative fines. Enforcement runs through visibility instead: organisations found accessible earn the right to display an "Accessibility Logo" for two years, while those that miss the deadline have that fact shared publicly. A Monitoring Commission chaired by the Minister of Family and Social Services runs the assessment against the ministry's Level A checklist, and every covered organisation is expected to form its own internal review commission (Ministry of Family and Social Services).
Note the mismatch: Turkey's circular sets Level A, the EU's standard sets Level AA. For an exporter the sensible move is to build to WCAG 2.2 AA once — clearing the higher bar covers the lower one automatically.
Your site probably makes these six mistakes
WebAIM's February 2026 analysis of one million home pages, the WebAIM Million, found automatically detectable WCAG failures on 95.9% of them — an average of 56.1 errors per page, up 10.1% year over year. Six consecutive years of slow improvement reversed.
The useful part: the failures cluster into six categories, and every one of them is fixable at the design or markup level.
| Failure | Share of pages | Fix |
|---|---|---|
| Low contrast text | 83.9% | At least 4.5:1 for body text, 3:1 for large headings. Light grey on grey is the usual culprit. |
| Missing alternative text | 53.1% | Write alt for every image that carries information; give decorative ones an empty alt="". |
| Missing form input labels | 51.0% | Bind a label to every input. A placeholder is not a label. |
| Empty links | 46.3% | Give icon-only links an accessible name — otherwise a screen reader announces "link" and nothing else. |
| Empty buttons | 30.6% | Add aria-label to icon buttons. Hamburger menus and cart icons are the classic offenders. |
| Missing document language | 13.5% | Add <html lang="en">. One line, and correct screen reader pronunciation depends on it. |
How do you test your own site in 20 minutes?
You do not need to buy a tool for a first diagnosis. Work through these in order:
- Keyboard pass (5 minutes). Put the mouse down and go from the home page to the contact form using Tab alone. Can you always see which element has focus? Do you get trapped in the menu? If you do, so does every keyboard user.
- Zoom test (3 minutes). Set browser zoom to 200%. Does text overlap, do buttons push off-screen?
- Automated audit (5 minutes). Run Lighthouse's Accessibility audit in Chrome DevTools. Treat the issue list as a roadmap, not the score as a target.
- Screen reader (5 minutes). Turn on NVDA on Windows or VoiceOver on macOS and listen to the home page alone. Do the menu and buttons announce themselves?
- Contrast check (2 minutes). Measure the contrast ratio of body text, button text and form labels.
One caveat: automated tools catch only a portion of WCAG criteria. Scoring 100 in Lighthouse does not mean the site is accessible, and it does not replace the keyboard and screen reader passes. That is why the automated audit sits third on this list rather than alone.
On accessibility overlays, let's be direct: a widget bolted onto the page does not fix the markup underneath it. Both WCAG audits and Turkey's ministry checklist evaluate the page's own source, not the plugin sitting on top of it.
How does accessibility affect SEO and conversion?
Accessibility work overlaps with technical SEO because both want the same thing: page structure stated explicitly enough for a machine to parse. Correct heading hierarchy, descriptive link text, image alternatives and a declared document language are signals a screen reader and a search crawler both read.
That overlap grew sharper with generative search. When an AI engine cites a page, it leans on heading hierarchy, tables and question-answer structure; a page that fakes headings with bold paragraphs looks as unstructured to those systems as it does to a screen reader. Most accessibility fixes make a page more quotable at the same time.
The conversion effect is more direct. Unlabelled form fields, low contrast buttons and steps that cannot be reached by keyboard stop far more than disabled users — they stop anyone in a hurry on a small screen. The checklist in our post on web design principles that increase conversion rates looks at largely the same surface.
Frequently asked questions
Does a small business website have to be accessible?
Under the European Accessibility Act, the microenterprise exemption covers services provided by businesses with fewer than 10 employees and annual turnover or balance sheet total of no more than €2 million — both conditions must be met, and it does not extend to products placed on the market. In Turkey, Circular 2025/10 applies by sector rather than by size, so an e-commerce provider under Law No. 6563 is bound by the 21 June 2027 deadline regardless of headcount.
What is the difference between WCAG Level A and Level AA?
Level A is the minimum threshold for content to be usable at all: keyboard access, text alternatives for images, a declared page language. Level AA adds colour contrast ratios, text resizing and consistent navigation on top of that. Turkey's circular is based on Level A, while EN 301 549 — the standard behind the European Accessibility Act — is based on Level AA.
Is installing an accessibility overlay enough for compliance?
No. An accessibility toolbar added to a page does not repair missing labels, empty buttons or a broken heading hierarchy in the source code. Both WCAG audits and regulators' checklists evaluate the page's own markup. An overlay is at best a temporary aid, never a compliance record.
When exactly is the deadline for my e-commerce site?
If you sell to consumers in the EU, the European Accessibility Act has applied since 28 June 2025 — that deadline has passed. If you operate in Turkey as a service provider under Law No. 6563, Circular 2025/10 granted two years from its publication on 21 June 2025, making the deadline 21 June 2027.
What does an accessibility statement have to include?
Under the European Accessibility Act, service providers must publish information explaining how the service meets the accessibility requirements, in both written and accessible formats. It should describe the standard applied, the parts of the service covered, any features that fall short and why, and how users can report a problem.
Where to start
The sequence that usually works: measure the current state first — the 20-minute pass above is enough for that — then fix the failure that affects the most pages in one batch. Contrast and form labels are typically template-level items you can resolve once. After the template fixes land, add alt text and heading hierarchy rules to your content workflow so the same debt does not build back up.
If you want to see which items your site trips on, look at our UX-focused web development service or request a quote for an accessibility audit of your current site.