Accessibility rules your EU clients now push down to you
You are probably exempt as a micro business. Your client is not, and that is how the requirement arrives in your contract.
The Delivvo team· July 24, 2026 7 min read
If you build websites, apps, or online shops for clients in the European Union, there is a good chance a contract has landed on your desk in the past year with an accessibility clause in it that was not there before.
It is not boilerplate. It comes from the European Accessibility Act, and the reason it is being pushed onto you is that your client cannot push it anywhere else.
What the law covers
The European Accessibility Act sets common accessibility requirements for a defined list of products and services. The European Commission lists computers and operating systems, ATMs and ticketing machines, smartphones, television equipment, telephony services, access to audiovisual media, passenger transport, banking services, e-books, and e-commerce.
E-commerce is the one that touches most freelance work. If your client sells to consumers in the EU through a website or an app, the service they operate has to meet the requirements.
Enforcement is not run from Brussels. The Commission monitors transposition and runs an expert group of national administrations and market surveillance authorities, but the supervision that produces letters and deadlines happens at national level.
In the Netherlands, for example, the regulator ACM told businesses to prepare for the rules covering webshops and electronic communication services, and has supervised them since 28 June 2025. ACM says it will check digital accessibility and address companies where needed, prioritising critical accessibility problems with significant negative impact while weighing the effort a company has made.
Keep reading
Why the micro-enterprise exemption does not save you
Here is the part that gets misread constantly.
There is an exemption. ACM states the obligations apply to businesses with 10 or more employees and, or, more than 2 million euro in annual turnover, and that companies below both thresholds are exempt from the service rules.
So as a one-person studio, you personally are almost certainly outside the scope. That fact is worth exactly nothing commercially, for one simple reason: the exemption belongs to the service provider, and on the client's website, the service provider is the client.
Your client, if they are above those thresholds, is on the hook for a website you built. They cannot delegate the obligation. What they can do, and are now doing, is delegate the work and the warranty. That is why accessibility language is appearing in briefs, in acceptance criteria, and occasionally in indemnity clauses written by someone who has never opened a screen reader.
Read those indemnity clauses carefully before you sign them. Agreeing to build to a standard is normal. Agreeing to underwrite a client's regulatory exposure for the life of a site you will not maintain is not.
A designer working on a laptop with a graphics tablet and creative tools nearby
What "accessible" means on a spec sheet
Vague clauses are the enemy here. "Must be accessible" is unbuildable and untestable.
The concrete answer in Europe is the harmonised standard EN 301 549, published by ETSI, which pulls in the Web Content Accessibility Guidelines for web content. The W3C confirms that EN 301 549 currently references WCAG 2.1, with the next version of the standard expected to move to WCAG 2.2, and that conformance is expressed in levels A, AA, and AAA.
So the version of the clause you want in the contract is specific: the deliverable conforms to WCAG 2.1 Level AA as referenced by EN 301 549, tested against an agreed list of templates and user journeys.
That single sentence does three useful things. It gives you a finite target, it gives the client something their lawyer can point at, and it stops the scope from drifting into "make everything perfect for everyone forever".
How to scope and price it
Accessibility is not a checkbox at the end. Retrofitting it is where projects lose money.
Quote it as a named line item. Not hidden in the build. A line the client can see, question, and approve, on templates rather than pages: home, listing, product, cart, checkout, account, forms.
Define the test surface up front. Five key journeys tested with keyboard only, one screen reader, and automated checks, with results delivered as a report. Unlimited testing of unlimited pages is not a scope, it is a liability.
Carve out what you do not control. Third-party embeds, payment widgets, chat bubbles, review scripts, and any content the client adds after handover. You can commit to what you build and to raising issues in what you do not.
Put the standard in the statement of work, not the email thread. If you need a structure for that, the statement of work guide covers where obligations like this belong.
Charge for the report. The client needs evidence more than they need a certificate. A dated conformance report against a named standard is the artefact a regulator asks for, and it is worth real money because it is the thing the client cannot produce themselves.
As a rough planning number, treat accessibility as work that adds meaningfully to a build when it is designed in from the start, and as work that can rival a redesign when it is bolted on afterwards. The expensive failures are structural: a custom dropdown nobody can operate with a keyboard, a checkout built as a sequence of divs, a colour system chosen from a mood board without a contrast check. Catch those in design and they cost hours. Catch them in user acceptance testing and they cost a rebuild.
That is also the honest sales pitch for existing clients. The cheapest moment to fix this passed in June 2025. The second cheapest is the next redesign, and the most expensive is a letter from a supervisory authority with a deadline attached.
If you are not in the EU, this still lands on you
Plenty of the designers and developers dealing with this sit in the US, the UK, India, or the Gulf.
Location does not help you. The obligation attaches to the service offered to consumers in the EU market, not to the passport of the person who wrote the CSS. If your client sells into the EU and clears the size thresholds, they are in scope, and the requirement will be handed to whoever builds their front end.
Two practical consequences.
Assume any brief from an EU-facing client now carries an accessibility expectation whether or not it is written down, and price accordingly rather than discovering it at acceptance. And be careful signing warranties that outlive your involvement. Committing that what you deliver conforms to WCAG 2.1 Level AA on the date of handover is reasonable. Committing that a site stays conformant after a marketing team has added six months of content and three tracking scripts is not, and no amount of good intent survives that clause when someone actually reads it.
What regulators are actually doing
Do not sell fear here, because the picture is uneven and clients can read.
Supervision started at different speeds across member states. Some authorities spent the first period building capacity. Others, like ACM, published guidance and began checking. The consistent signal from what regulators have said publicly is that they are triaging: critical barriers first, and credit for demonstrable effort.
That last point is the commercially useful one. A client with a dated audit, a prioritised remediation plan, and a developer working through it is in a materially different position from a client with nothing. You can sell the plan even when you cannot deliver perfection.
It also changes the shape of the offer. The first sale is an audit against WCAG 2.1 Level AA on the templates that carry the revenue, delivered as a written report with issues ranked by severity. The second is remediation, priced per template. The third, and the one worth having, is a review each time the site changes materially. That sequence turns a compliance scare into a small retainer, and it puts you in the room the next time the client redesigns anything.
Delivvo gives freelancers one branded portal for the contract, the deliverables, and the sign-off record, so when a client is asked to show what was tested and when it was approved, the accessibility report sits with the work instead of in an inbox. See how it works
A short handover checklist
Before you call an EU-facing build finished, confirm the basics that account for most real failures: every interactive element reachable and operable by keyboard with a visible focus state, form fields with real labels and errors announced in text, images with meaningful alternative text and decorative images marked as such, contrast that meets AA for text and interface components, headings in a logical order, and video with captions.
Then write the date, the standard, the pages tested, the tools used, and the open issues into one document and hand it over with the files. If the client has recorded acceptance of that document, you both have an answer if a supervisory letter ever arrives, and the documented sign-off habit is what makes that answer available a year later.
