WCAG 2.2 and EAA 2025: site accessibility in 30 minutes

WCAG 2.2 and the EAA law take effect 28 June 2025. We show the common errors, implementation costs and penalties for non-compliance. Check your audit in 30 minutes.

From 28 June 2025, the website of a cafe, furniture shop or accounting office must comply with WCAG 2.2 digital accessibility rules — required by the Polish law implementing the EU European Accessibility Act (EAA). We show who the new rules actually cover, what to check on your own site in half an hour, and what typical fixes cost.

Digital accessibility is not a wheelchair ramp bolted on at the side. It is a wide, comfortable entrance — easy to walk through with a stroller, a suitcase, or simply as a tired person holding a phone in one hand. The whole standard comes down to that one design decision.

What the EAA law is and who it covers

The European Accessibility Act is an EU directive from 2019, which Poland implemented through the law of 26 April 2024. It applies from 28 June 2025 and says a simple thing: a website, app, customer portal or ATM must give every client the same access to information, regardless of sight, hearing or mobility.

The rules cover mainly e-commerce, banking, passenger transport, telecoms, e-books, audiovisual media services and ATMs. Micro-enterprises with up to nine employees and turnover below 2 million euro that only provide services — for example, a small beauty salon with a business-card page — are exempt. But the moment the same salon starts selling cosmetics online, the exemption disappears.

If you run an online shop with delivery, a blog with online booking, or a SaaS service — your company is on the list of those required to comply.

What version 2.2 changed and what it is really about

WCAG is an international standard for web accessibility for people with disabilities, described by the W3C consortium. Version 2.2 from late 2023 added nine new criteria to the previous one: about phone gestures, button size and visible marking of where the keyboard cursor currently is.

There are three levels: A is the absolute minimum, AA is the standard required of business in Poland and across the EU, AAA is the maximum version, in practice unnecessary for an ordinary shop or blog. The real target: level AA. Free scanners check the same thing, and that is what the EAA enforces.

Four blocks that hide 80% of the errors

In day-to-day work it usually pays to close four things:

1. Text and background contrast — at least 4.5:1 for normal text, 3:1 for large (from 18 px bold or 24 px regular). The trendy grey #999 on white gives 2.85:1, so it fails.
2. Visible focus. When someone navigates with the keyboard, the active button or link must be clearly marked with a border, highlight or shadow. Many developers strip outline: none and forget to add their own style.
3. Full keyboard operation. The whole site must be reachable with Tab, activated with Enter and closed with Escape, without a mouse. A modal where the focus runs off below the page is a classic.
4. Forms and clickable areas. The minimum button size is 24×24 pixels. Social media icons on mobile are often squeezed so tightly that a finger hits the wrong one.

The most common errors we see at clients

• Icon without a label. A button with only a cart or hamburger glyph is read by a screen reader as just "button". It is enough to add aria-label="Otwórz menu".
• Carousel without a pause. A slider switching itself every three seconds tires people with dyslexia and is a formal violation. A visible stop button is needed.
• Colour as the only signal. A form field glows red with "error", and a colour-blind user sees only a dark background. Next to the colour there must be an icon or message: "Email address is invalid".
• Image without an alt attribute. A product photo in a shop needs a short description, a decorative background needs an empty alt="". A value like "DSC_1284.jpg" does not count.
• Scrambled heading hierarchy. One h1 per page, then h2 and h3 in order. Choosing the tag based on font size is a common sin.

How to check your site in 30 minutes

First the automated tool. In the Chrome browser open F12 → Lighthouse → Accessibility → Generate. After a minute you get a list of problems pointing to exact elements. It catches about 30% of real violations, but those are usually the cheapest to fix.

Then the axe DevTools extension by Deque. It finds more issues with ARIA attributes and contrast that Lighthouse missed. The free version is enough for auditing a small website, although a full digital accessibility audit with purchase paths already requires manual verification.

Finally a manual test. Put the mouse in a drawer, open the site and walk through it with Tab. Everything must be reachable, focus visible, popups closable with Escape. Turn on the built-in screen reader: on Mac it is VoiceOver (Cmd+F5), on Windows the free NVDA. Ten minutes of listening to the home page and cart is enough to hear what is off.

How much it costs to bring a site to WCAG 2.2

Bringing an existing landing page with 5–10 subpages up to level AA takes 8 to 20 hours of a developer's work. For a typical cafe or a small shop that is one assignment, not a monthly project. A bigger shop with a cart, customer account and several payment methods — from 40 hours upwards.

Interestingly, these fixes also pay off on the sales side. We recently corrected contrast and form labels in a cosmetics shop; changes on the product card and cart alone lifted conversion by about 5%, because readability improved for everyone, not just people with sight issues. Accessibility and UX are often the same work done from two sides.

WCAG-compliant website development is what we design from the start at level AA, with a concrete list of problems to fix and the cost of each fix — without "all inclusive" packages and without an add-on subscription service.

Penalties for missing WCAG and the legal risk

Supervision over EAA compliance in Poland is exercised by the President of the Management Board of PFRON, and in telecoms and e-media — by UKE and KRRiT respectively. When a violation is found, the body calls on the company to remove the problem within a set deadline. If the firm does not react, administrative fines follow — reaching tens of thousands of zlotys for more serious breaches.

The second risk is civil claims from consumers or organisations defending the rights of people with disabilities. In the US and Germany such class actions are everyday business; in Poland they are only emerging, but the law allows it.

Common questions about WCAG 2.2 and EAA

Who does the EAA law cover?

Online shops, banks, telecom companies, public transport, e-books, audiovisual media services and ATM manufacturers. Micro-enterprises providing services (up to 9 employees and turnover below 2 million euro) are exempt, but if they sell anything online — the exemption disappears.

Does a small shop also have to meet WCAG?

Yes. An online shop does not fall under the micro-enterprise exemption, because it sells products rather than only providing services. If you run a jewellery shop on WordPress — your site is covered by the full WCAG 2.2 requirements at level AA.

Which WCAG level is required — A, AA or AAA?

The standard for business in the EU is level AA. Level A is the absolute minimum, AAA is the maximum, hard and costly to maintain, in practice required only in some public institutions.

How long does bringing a site into compliance take?

For a typical company site of 5–10 subpages — 8 to 20 hours of work. For a shop with a cart and customer account — from 40 hours upwards. It all depends on how many errors come from the off-the-shelf theme and how many from custom code and plugins.

Is the free Lighthouse scanner enough for an audit?

Enough for a first pass and to catch 30% of the most common problems. A full digital accessibility audit always requires manual verification with a keyboard and a screen reader, because no scanner will check whether the site makes sense for a person who cannot see it.

In short

The EAA already applies, and WCAG 2.2 is the concrete list the law requires. Four blocks — contrast, focus, keyboard, forms — handle most problems in hours of work, not weeks. The rest is discipline on every new graphic project and piece of code. A site that works for every customer also sells better; that long ago stopped being only an ethical argument.