In short: If you sell online to consumers, your website or mobile app has to meet the accessibility requirements introduced by the European Accessibility Act. In Bulgaria the Act is implemented by the Act on Accessibility Requirements for Products and Services, which has applied since 28 June 2025. Microenterprises providing services are exempt. For everyone else, fines for breaches committed after 1 June 2026 apply in full. The technical benchmark used in practice is the European standard EN 301 549, which includes WCAG 2.1 Level AA for web content.
This article explains the rules in plain language and is not legal advice. For your specific situation, speak to a lawyer.
What does the law require from a website?
The European Accessibility Act (Directive (EU) 2019/882) aims to let people with disabilities use essential products and services without help from others. Bulgaria transposed it through the Act on Accessibility Requirements for Products and Services, published in the State Gazette, issue 31 of 11 April 2025. The Act came into force on 28 June 2025.
For websites, the key duty sits with the service provider: the service is designed and delivered in line with the accessibility requirements, and the provider prepares information on exactly how it meets them. That information goes into the general terms and conditions or an equivalent document and has to be accessible to people with disabilities.
For e-commerce, the law adds three more points:
- Accessibility information about products: where the manufacturer or importer provides it, it has to reach the buyer.
- Accessible identification, security and payment: where these functions are part of the service itself, they have to be perceivable, operable, understandable and robust.
- Accessible identification methods, electronic signatures and payment services: for example, account login, order confirmation and the payment services used at checkout. What matters is not just the product page but the whole path to a completed order.
Who is covered and who is exempt?
The law covers several types of service: electronic communications, access to audiovisual media services, parts of passenger transport services, consumer banking, e-books and e-commerce services.
The law defines “e-commerce services” as services provided at a distance through websites and mobile apps, at the individual request of a consumer, with a view to concluding a consumer contract. What does that mean for your business?
- An online store selling to consumers: in scope. The same goes for online orders in retail with physical shops.
- A site with online booking or sign-up that creates a contract with a consumer: very likely in scope.
- A site that sells only to businesses: the definition refers to consumer contracts, so such a site is probably outside this scope. Check with a lawyer.
- A company website with no sales and no online contract: as a rule, not an e-commerce service.
The microenterprise exemption
Microenterprises that provide services are exempt from the accessibility requirements and from the related obligations. Under the law, a microenterprise has fewer than 10 employees and an annual turnover or balance sheet total of no more than EUR 2,000,000.
Content that is excluded
The law does not apply to pre-recorded audio and video with a set duration or to office documents published before 28 June 2025, to third-party content that the business does not fund, develop or control, or to archives that are not updated after that date.
There is one more route: the requirements apply only as far as they do not fundamentally alter the service or impose a disproportionate burden. A business relying on this has to carry out an assessment against the criteria in the law, document it and keep it for 5 years.
ScaleLab tip: If you believe an exception applies to you, write down why now. A missing documented assessment is a breach in its own right.
What are the deadlines and fines?
The requirements have applied since 28 June 2025. Service contracts concluded before that date may continue unchanged until they expire, but for no more than 5 years after it. For e-commerce services, enforcement lies with the Consumer Protection Commission, and consumers and disability organisations can send it complaints and reports.
For breaches committed up to 1 June 2026, the law sets fines and penalties at half their amount. For breaches committed after that date, the full amounts apply. The law states the amounts in leva; since 1 January 2026 they apply in euro at the rate of 1.95583. These are the main amounts for service providers, converted to euro and rounded to the cent:
| Breach | Fine | Financial penalty (for a company) |
|---|---|---|
| Failure to meet accessibility duties for services, Art. 89 | EUR 766.94 to EUR 5,112.92 | EUR 1,533.88 to EUR 10,225.84 |
| The same, repeated | EUR 1,533.88 to EUR 10,225.84 | EUR 3,067.75 to EUR 20,451.68 |
| No assessment for an exception under Art. 3, Art. 86 | EUR 255.65 to EUR 1,533.88 | EUR 511.29 to EUR 2,556.46 |
| Information not provided or incorrect on request, Art. 87 | EUR 511.29 to EUR 5,112.92 | EUR 1,022.58 to EUR 7,669.38 |
What does an accessible website mean in practice?
The law does not list buttons and colours. It refers to harmonised European standards: a service that meets them is presumed to meet the requirements. In practice the benchmark for websites is EN 301 549. According to W3C, most organisations addressing the European Accessibility Act use WCAG and EN 301 549. The standard includes WCAG 2.1 Level AA verbatim for web content, and W3C expects its next version to use WCAG 2.2.
Put simply, WCAG describes a site that people can perceive, operate and understand, and that works with assistive technology such as screen readers or voice control. That is the difference between a good-looking site and a site anyone can use.
A practical checklist: where to start?
We recommend starting with the path that brings in money: home page, category, product, basket, checkout and payment. Check it in that order.
1. Test the whole site with a keyboard only
Tab through the menu, filters, basket and checkout. Every button and link should be reachable, it should be clear which element is in focus, and you should never get “trapped” in a pop-up such as a cookie banner.
2. Measure contrast
WCAG requires a contrast ratio of at least 4.5:1 between text and background for normal text and at least 3:1 for large text. Light grey text on white and white text over photos are the usual problems.
3. Add alt text
Product photos, icons that do something and banners containing text need a short description. Decorative images do not need one and should be skipped by screen readers.
4. Sort out forms and error messages
Every field has a visible label, not just placeholder text inside the field. An error message says exactly what is wrong and how to fix it, rather than just turning the field red.
5. Test checkout and payment
Complete a test order using a keyboard and a screen reader. Check delivery options, discount codes, confirmation and the payment page. If payment is handled by an external provider, ask them for their accessibility information.
6. Publish an accessibility statement
Describe how the site meets the requirements, what is not yet right and how customers can report a problem. The law requires this information to sit in the general terms and conditions or an equivalent document.
ScaleLab tip: Automated checks only find some of the problems. Do not rely on an accessibility overlay widget alone: it does not fix form labels or the order of elements in the code.
Why does accessibility help SEO and orders too?
Many of the requirements overlap with good practice for search and for sales. Google says it uses alt text together with computer vision and the page content to understand what an image shows. A clear heading structure helps both screen reader users and people skimming a page on their phone.
The same goes for forms. Clear labels and understandable error messages mean fewer abandoned enquiries and orders, because every customer finds it easier to finish. Do not expect a ranking jump from accessibility alone, but do expect fewer obstacles on the way to an order.
How to organise the work
Start by checking the path to an order, list the problems by importance and fix first the ones that stop a purchase. Then build accessibility into the rules for all new content: images with descriptions, headings in the right order, keyboard tests before launch. Separately from an accessibility check, if you want to see where your site and marketing are losing customers, use the free website audit. For online stores, accessibility is one of several checks this year, and the euro price checklist for your website is another. A site changes constantly, so accessibility belongs to ongoing maintenance, just like WordPress security.
If you are preparing a new site, we recommend planning accessibility at the design stage and testing with a keyboard and a screen reader before launch, rather than adding it after a complaint. You can see what our website work covers on the website development page.
Frequently asked questions
Is accessibility mandatory for every website?
No. The law covers specific services, including e-commerce services for consumers. A company website without online sales is generally out of scope, and microenterprises providing services are exempt.
Who checks online stores?
The Consumer Protection Commission enforces the rules for e-commerce services. Consumers and disability organisations can send it complaints and reports.
What are the fines?
The general penalty for failing to meet accessibility duties for services is a fine of EUR 766.94 to EUR 5,112.92 or a financial penalty of EUR 1,533.88 to EUR 10,225.84, and the amounts double for a repeat breach. The law states the amounts in leva (BGN 1,500 to 10,000 and BGN 3,000 to 20,000), and since 1 January 2026 they apply in euro at the rate of 1.95583. For breaches committed after 1 June 2026 the full amounts apply.
Which standard should we follow?
In practice the benchmark is the European standard EN 301 549, which includes WCAG 2.1 Level AA for web content. If you are building a new site, check the WCAG 2.2 requirements as well, because the next version of the standard is expected to use it.
Is an accessibility widget enough?
We recommend not relying on a widget alone. Problems such as missing field labels, element order and keyboard access are solved in the site’s code and content.
Sources
- State Gazette: Act on Accessibility Requirements for Products and Services, issue 31 of 11 April 2025 (in Bulgarian)
- Bulgarian National Bank: Act on the Introduction of the Euro in the Republic of Bulgaria (in Bulgarian)
- European Commission: European Accessibility Act
- W3C WAI: WCAG 2 Overview, section ISO/IEC 40500, EAA, EN 301 549
- W3C WAI: European Union, web accessibility laws and policies
- W3C WAI: Understanding Success Criterion 1.4.3, Contrast (Minimum)
- Google Search Central: Google image SEO best practices