Insights · 22 October 2026

Where accessibility law stands in late 2026, and what changes in 2027

If you sell online into the EU or the US, three facts matter this year: the European Accessibility Act has applied for sixteen months, US web accessibility lawsuits hit a record in 2025, and the quick fixes are no longer accepted. Here is what that means in practice.

Europe: the Act is in force, enforcement is starting

Directive 2019/882 has applied since 28 June 2025 to e-commerce, consumer banking, telecoms, transport information and ticketing, e-books and audiovisual services offered to EU consumers. Where the company is based does not matter; non-EU companies must also appoint an EU representative. Service providers with fewer than ten employees and €2 million or less in turnover are exempt.

Enforcement is national and gradual. Germany's joint market-surveillance body has been fully operational since September 2025 and works through correction orders before fines of up to €100,000. In France, courts issued the first compliance orders in 2026, including one giving a major retailer six months to make its site and app accessible. No EU-wide pattern of fines exists yet; the pattern of complaints and orders does.

United States: lawsuits, procurement and a delayed rule

Seyfarth Shaw counted 3,117 website accessibility lawsuits in US federal courts in 2025, a 27% rise on 2024 and the highest on record. Including state courts, the total passed 5,000. Nearly half of federal defendants had been sued before, which says something about how many "fixes" did not hold.

In April 2025 the Federal Trade Commission ordered an overlay vendor to pay $1 million over claims that its widget made sites compliant. The order does not ban overlays, but it ends the marketing claim that they solve the problem.

The Department of Justice's rule for state and local governments was pushed back by a year in April 2026. Large public entities and the vendors they use now have until 26 April 2027; smaller ones until 26 April 2028. The standard is unchanged: WCAG 2.1 AA. The DOJ cited, among other reasons, the limits of generative AI for remediation.

What changes in 2027, and what is already due

• 26 April 2027: ADA Title II compliance for large US public entities and their vendors.
• Every new EU contract: service contracts agreed since 28 June 2025 must comply from day one. Contracts agreed before then may run unchanged until they expire, for at most five years, so until 28 June 2030.
• 11 December 2027: the EU Cyber Resilience Act's main obligations apply to software and connected products, a separate but related compliance load for the same teams.

What to do now

Treat WCAG 2.2 AA as the single target; it satisfies the EU standard, the US benchmark and procurement requirements at once. Fix defects in the code rather than over it. Keep evidence: a report that shows how each criterion was tested is what a procurement officer, a regulator or a court will ask for. And re-check after every release, because the record of repeat defendants shows that a one-time audit does not hold.

Sources: European Commission; Bavarian market surveillance; EAA enforcement overview; Seyfarth Shaw; FTC order summary; DOJ extension; Cyber Resilience Act.