European Accessibility Act
The European Accessibility Act is already in force and affects a large share of business websites and online stores in Bulgaria. Since 28 June 2025, digital services aimed at consumers must be usable by people with disabilities, including blind users, people with reduced vision, hearing difficulties or limited motor control. This article explains who is affected, from when, which standard a website should follow and what sanctions apply, without legal jargon and without promises the law does not make.
In brief: The European Accessibility Act, Directive (EU) 2019/882, has been transposed in Bulgaria through the Accessibility Requirements for Products and Services Act, in force from 28 June 2025. It requires e-commerce and a number of other services to follow EN 301 549, which for web content is based mainly on WCAG 2.1 level AA. Microenterprises providing services are exempt. Transitional rules until 28 June 2030 apply only to existing contracts and services, not to all existing online stores.
Contents
- What is the European Accessibility Act and why does it affect your website?
- When does it apply and what are the deadlines?
- Which websites and businesses are affected?
- What does an accessible website mean in practice?
- Common mistakes that make websites inaccessible
- Who enforces compliance and what are the sanctions?
- How to check whether your website is accessible
- Why accessibility and SEO work together
- Frequently asked questions
What is the European Accessibility Act and why does it affect your website?
The European Accessibility Act is an EU directive that requires certain products and services offered to consumers to be usable by people with disabilities. In a digital context, this means that a website or application must work for a person who cannot see the screen, cannot use a mouse or has hearing difficulties. The goal is not cosmetic. It is equal access to trade, banking, transport and information.
Which law transposes it in Bulgaria?
In Bulgaria, the Act was transposed through the Accessibility Requirements for Products and Services Act, adopted in 2025 and in force from 28 June 2025. The law introduces the requirements of Directive (EU) 2019/882 and defines the scope, obligations of economic operators, enforcement bodies and sanctions. The EU framework is summarized in the official EUR-Lex overview of accessibility requirements for products and services.
Which products and services are covered?
The law covers both products and services. On the services side, it includes e-commerce, consumer banking services, electronic communications services, elements of passenger transport services, e-books and access to audiovisual media services. On the product side, it covers computers and operating systems, smartphones, self-service terminals such as ATMs and ticket machines, e-readers and equipment for digital television.
Accessibility is not the same as good visual design
Accessibility is not the same as a modern or attractive design. A visually polished website can still be unusable for a blind user if images have no text alternatives and forms have no labels. Accessibility is measured against a technical standard, not against taste. That is why the requirement can be checked and enforced, unlike a subjective opinion about design.
When does it apply and what are the deadlines?
The key date is 28 June 2025. From that date, products and services within the scope must meet accessibility requirements. The law also includes transitional rules that give existing businesses some time to adapt in specific situations, instead of forcing every legacy arrangement to change overnight.
28 June 2025 is the main date
From 28 June 2025, new services and newly placed products within the scope must be accessible. For a website or online store being launched or significantly rebuilt now, accessibility should be part of the initial brief, not an afterthought. Retrofitting accessibility into a finished site is almost always more expensive than planning it from the start.
What the transition period until 2030 actually covers
The transition applies in narrow cases and is not a general delay for the whole store. Service contracts concluded before 28 June 2025 may continue until they expire, but no longer than five years after that date, meaning no later than 28 June 2030. Services provided through products lawfully used before that date also have transitional rules. A new website, a new checkout flow or a substantial rebuild, however, should be accessible immediately. That is why priority screens such as the homepage, product page, cart and checkout should be brought into line early.
Self-service terminals
Self-service terminals lawfully put into use before 28 June 2025 may continue to be used until the end of their economically useful life, but not for more than 20 years after they entered service. This affects businesses with ATMs, ticket machines or ordering kiosks, not the typical website. For online commerce, the relevant dates remain 2025 and 2030.
Which websites and businesses are affected?
Affected businesses are those providing a service within the scope of the law to consumers in the EU, whether they are established in Bulgaria or outside it. For most Bulgarian companies, this mainly means e-commerce, but the scope is broader than online stores alone.
Online stores and e-commerce
E-commerce is explicitly within the scope of the law. Any online store that sells to end consumers should in principle be accessible, from search and product pages through cart and payment. If you are planning a new store, see how we approach online store development so accessibility can be included in the structure from the beginning.
Banking, transport and other services
Beyond commerce, the law also covers consumer banking services, electronic communications services, elements of air, bus, rail and waterborne passenger transport, e-books and services providing access to audiovisual content. If your business falls into one of these categories, the requirements apply to the whole digital customer journey, including mobile applications.
The microenterprise exemption
Microenterprises that provide services are exempt from the accessibility requirements. A microenterprise is generally a business with fewer than 10 employees and annual turnover or balance sheet total of up to EUR 2 million. The important detail is that the exemption applies to services. A microenterprise that manufactures, imports or trades products within the scope does not benefit from that exemption for those products.
What does an accessible website mean in practice?
An accessible website is one that follows the harmonized standard EN 301 549, which for web content is based mainly on WCAG 2.1 level AA. This is the technical framework used to assess compliance. It is not a general feeling that the site is easy to use, but a set of concrete, testable criteria.
EN 301 549 and WCAG 2.1 level AA
EN 301 549 is the European standard for the accessibility of ICT products and services. For web content, it is based mainly on the Web Content Accessibility Guidelines (WCAG) 2.1 at level AA, while also adding some requirements beyond WCAG in specific cases. Level AA is the commonly accepted threshold for legal compliance in the EU. Level A is too low, while AAA is not required across an entire website.
The four principles: perceivable, operable, understandable, robust
WCAG is built around four principles. Content must be perceivable, meaning it can be seen or heard in more than one way. It must be operable, meaning it works with a keyboard and not only with a mouse. It must be understandable, with clear language and predictable behavior. It must also be robust, with code that assistive technologies can interpret correctly. Each success criterion sits under one of these principles.
Requirements that are checked most often
Some criteria appear in almost every accessibility review. The table below summarizes common level AA requirements and why they matter to real users.
| Element | WCAG 2.1 AA requirement | Why it matters |
|---|---|---|
| Images | Text alternatives for meaningful images | A screen reader can describe the image to a blind user |
| Contrast | At least 4.5:1 for normal text against the background | Readable text for users with low vision and in bright light |
| Keyboard | All functionality available from the keyboard | Users with limited fine motor control may not use a mouse |
| Forms | Visible labels and clear error messages | The user understands what each field requires |
| Focus | Visible indicator of the active element | Orientation while navigating with a keyboard |
| Zoom | Text can be resized up to 200% without content loss | Usability for people with reduced vision |
Common mistakes that make websites inaccessible
Most websites are not inaccessible on purpose. Problems usually come from a few repeated omissions. The good news is that those mistakes can be found and fixed relatively easily when they are addressed early.
Images without alternative text
A meaningful image without an alt attribute is invisible to a screen reader. A product image, icon button or infographic without a text description leaves a blind user without important information. Decorative images, on the other hand, should use an empty alt attribute so they do not create noise. Distinguishing meaningful from decorative images is one of the first checks.
Weak contrast and small text
Light grey text on a white background can look elegant, but it often falls below the 4.5:1 contrast requirement and becomes hard to read for part of the audience. The same applies to text placed over images without a supporting background. Contrast checks are quick with free tools and are often solved with a small color adjustment.
Forms and buttons without labels
An input field whose only label is grey placeholder text inside the field becomes unclear once the user starts typing and may not be read reliably by assistive technologies. An icon-only button without a text label or accessible name is also ambiguous. Every form field needs an associated label, and every button needs a clear name.
Content that does not work with a keyboard
A menu that opens only on mouse hover, a pop-up that cannot be closed with the Escape key or a carousel without accessible controls can block a keyboard user. The rule is simple: if something can be done with a mouse, it should also be possible with a keyboard in a logical order.
Who enforces compliance and what are the sanctions?
Enforcement is distributed between several authorities depending on the type of service, and e-commerce is supervised by the Consumer Protection Commission. The law provides administrative sanctions, including fines for individuals and property sanctions for companies, when a violation is established.
Authorities by service type
The law assigns different authorities to different services: the Communications Regulation Commission for electronic communications, the Bulgarian National Bank for banking services, sector transport administrations for passenger transport, and the Ministry of Culture for e-books. For e-commerce services, the competent authority is the Consumer Protection Commission. Product market surveillance is carried out by the State Agency for Metrological and Technical Surveillance.
Sanctions under Bulgarian law
Sanctions are scaled according to the violation and the operator. For manufacturers and importers of non-compliant products, fines start from BGN 1,000 and property sanctions can reach BGN 25,000, increasing to BGN 50,000 for repeat violations. Service providers can also face sanctions reaching tens of thousands of levs. Penalty decisions follow the procedure under the Administrative Violations and Sanctions Act. The exact amounts are set out in the text of the Bulgarian law.
Consumer complaints
In addition to sanctions, the law allows consumers to submit complaints and signals to the relevant authority when a service does not meet accessibility requirements. For businesses, the risk does not come only from planned inspections. It may also come from a specific user who could not complete an order or use the service. Accessibility is therefore a reputation issue as well as a compliance issue.
How to check whether your website is accessible
Accessibility checks work best in two stages: automated testing and manual review. Neither is sufficient on its own. Automated tools catch part of the issues quickly, while manual testing finds barriers that machines miss.
Automated tools and their limits
Free browser audit tools can detect missing alt text, weak contrast and some structural errors in seconds. However, they only find part of the barriers and cannot replace manual testing with a keyboard and screen reader. An automated test is a good first step, not a final accessibility assessment.
Manual testing with a keyboard and screen reader
The most revealing test is practical: try to move through the entire site using only the keyboard, with Tab for navigation and Enter for selection, without touching the mouse. If you can reach the cart and complete a purchase, you have covered much of the operability requirement. A test with a free screen reader adds the perspective of blind users.
Accessibility statement
A service provider should keep information on how the service meets the applicable accessibility requirements and provide it in an understandable form. In practice, this is a public accessibility statement or accessibility page on the website. It shows that the business has assessed compliance consciously rather than formally and is often the first thing a regulator or user would look for.
Why accessibility and SEO work together
Accessibility and search engine optimization share a technical foundation, so work on one often supports the other. A site that is clear to a screen reader is usually also clearer to Google's crawler.
A shared foundation with SEO
Semantic HTML, descriptive headings, alt text, logical page structure and good speed are useful both for accessibility and for SEO optimization. Alt text helps blind users and image indexing. A clear heading hierarchy helps screen readers and also helps search engines understand the content.
Better experience and more conversions
An accessible website is more usable for everyone, not only for people with disabilities. More readable text, working forms and fast navigation reduce drop-offs and increase completed orders. This overlaps with technical SEO and user-experience checks, such as those covered in our SEO audit for online stores. If you are considering a full rebuild, review our approach to website development.
Frequently asked questions
Since when has the European Accessibility Act applied in Bulgaria?
The requirements have applied since 28 June 2025 through the Accessibility Requirements for Products and Services Act. Existing service contracts may continue until their expiry, but no later than 28 June 2030. New websites and services should be accessible now.
Does my online store need to be accessible?
Yes. E-commerce is explicitly within the scope of the law. Any online store serving end consumers should in principle meet accessibility requirements. There is an exemption only for microenterprises providing services, with fewer than 10 employees and turnover of up to EUR 2 million.
Which standard should the website follow?
The applicable standard is EN 301 549, which for web content is based on WCAG 2.1 level AA. This includes text alternatives, sufficient contrast, keyboard operation, clear form labels and visible focus during navigation.
What are the sanctions for an inaccessible website?
The law provides fines for individuals and property sanctions for companies. For products, they can reach BGN 50,000 for a repeat violation, while service-related sanctions can also reach tens of thousands of levs. For e-commerce, enforcement is carried out by the Consumer Protection Commission under the administrative sanctions procedure.
Are microenterprises fully exempt?
Microenterprises are exempt from accessibility requirements only when they provide services. If a microenterprise manufactures, imports or trades products within the scope of the law, the exemption does not apply to those products.
Does accessibility help Google rankings?
Accessibility is not a direct ranking factor, but it shares a common foundation with SEO: semantic code, alt text, clear structure and good speed. These elements help both assistive technologies and search engine crawling, while a better experience can reduce drop-offs.
The European Accessibility Act has turned website accessibility from good practice into a legal requirement with clear deadlines and enforcement bodies. For most Bulgarian businesses, the most sensible next step is an audit of the current state and priority fixes on critical screens: homepage, product page, cart and checkout. Accessibility is only one legal topic for a website. Another important one for online stores is cookie consent and Google Consent Mode v2. If you want us to review your website against these criteria, contact us through the contacts page.
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