The Digital Accessibility Law: Is Your Business Actually Covered?

It slipped by relatively unnoticed among the digital obligations, but it is in force: since 28 June 2025, the European accessibility regime for products and services applies in Portugal — the European Accessibility Act, transposed by Decree-Law 82/2022. And unlike the older accessibility rules, which mostly targeted the public sector, this law points squarely at private companies — including e-commerce.

As always with these topics: practical guide, not legal advice. Straight to what matters — are you obliged or not?

Who is covered

The law covers a defined set of products and services — among them consumer banking services, e-books, self-service and payment terminals, electronic communications and, the case touching the most SMEs, e-commerce services: if you sell goods or services to consumers through a website or app, the activity is within the law's scope.

The obligation, in short: covered services provided to consumers from 28 June 2025 must meet the accessibility requirements — in practice, websites and apps usable by people with visual, hearing, motor or cognitive impairments.

The exemption that saves most small businesses: micro-enterprises

Here is the line that decides your case: micro-enterprises providing services are exempt from the law's obligations. A micro-enterprise, for this purpose: fewer than 10 employees and an annual turnover (or balance sheet) up to €2 million.

Translated into concrete cases:

• The café, salon or garage with a brochure site and a contact form — besides typically being micro-enterprises, an informational site is not, by itself, one of the listed services. Breathe.
• A micro-enterprise's online store — the activity (e-commerce) is in scope, but the service-provider micro-enterprise exemption applies. Watch your growth: the exemption disappears when your numbers stop being micro, and you don't want to discover that during an inspection.
• An online store belonging to a company with 10+ employees or over €2M turnover — covered. This is where the topic goes from interesting read to task with a deadline.
• Anyone selling to covered companies — banks, telecoms and large retailers increasingly demand accessibility from their website and software suppliers. Even exempt, the market may oblige you by contract.

Non-compliance is an administrative offence, with fines set out in the law itself and enforcement by sector authorities. And there is the less-discussed risk: consumer complaints — anyone prevented from using your service now has legal grounds to file one.

What "accessible" means, in human language

The technical requirements point to the well-known international practices (WCAG, for acronym lovers), but the spirit fits a short list:

• Perceivable: sufficient text contrast, images with alternative descriptions, captioned video, nothing conveyed by colour alone;
• Operable: everything usable with a keyboard only, no focus traps, buttons with a decent touch area;
• Understandable: clear language, forms that explain errors ("email is missing", not "error 422"), consistent navigation;
• Robust: correct code that screen readers can interpret.

If that sounds like "a well-built website" — it is exactly that. Legal accessibility and good engineering are the same work under two names, as we argued before it was mandatory.

The case for complying even without the obligation

Three practical reasons, no moralising:

1. It is market. Visual, motor and cognitive limitations — permanent or age-related — cover a huge share of consumers. A site that excludes them is a shop with a step at the door.
2. It is SEO. Much of what accessibility demands — correct structure, alternative text, clear hierarchy — is precisely what Google and AI read. The screen reader and the search crawler consume the same code.
3. It is cheaper now. Accessibility designed in from the start costs a fraction of accessibility patched under inspection pressure — the same arithmetic as GDPR and the complaints-book link.

What to do, in order

1. Decide which group you are in — covered, exempt as a micro-enterprise, or out of scope. (If you are near the thresholds, treat yourself as covered.)
2. Run the five-minute test: navigate your site with the Tab key only; zoom to 200%; ask whether every important image has a description. The obvious failures show up immediately.
3. If covered, commission a proper audit and a plan with deadlines — and distrust instant "accessibility badges" sold as plugins, which fix about as much as they cost.

Laws change and details matter: confirm the wording in force in the Diário da República before sensitive decisions.

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On the sites we build, keyboard support, contrast, descriptions and structure are part of the delivery standard — not out of virtue, but because that is what building well means. If the law has caught you (or will when you grow), describe your case in our estimate form and you will get a concrete figure for bringing the site into compliance — no sales calls, no magic badges.