Web accessibility: what a Greek website has been required to do since 2025

Let me start with the bottom line, because that is the part you were going to scroll to anyway. If your website sells, meaning it has a cart and a checkout, then since 28 June 2025 it falls under the European Accessibility Act and is required to meet WCAG at Level AA. If it is a simple presentation site for a small business, it most likely does not. Most likely. Because the exemption is narrower than most people assume, and in a minute you will see exactly where it pinches.

The deadline passed a year ago and the Greek market walked past it almost silently. No panic, no seminars, not even a courtesy email from a supplier. Am I wrong? So let us go through what actually applies, without scare tactics and without invented fines. I have watched plenty of “new obligations” get sold as fear and very few explained as work.

What the law actually says, minus the pomp

Directive (EU) 2019/882, known as the European Accessibility Act, was adopted on 17 April 2019 and applies from 28 June 2025. In Greece it was transposed by law 4994/2022 (Government Gazette A’ 215/18.11.2022), whose Part B applies from the same date. Years passed between adoption and application, not weeks.

And no, it does not cover every website. It covers specific services, listed in Article 2(2) of the Directive:

• E-commerce services, meaning any sale of goods or services to a consumer concluded electronically.
• Consumer banking services.
• E-books and dedicated software.
• Electronic communications services.
• Elements of passenger transport services, such as websites, apps and electronic tickets.
• Access to audiovisual media services.

The first item is the one that matters for the Greek market, and you spotted it already. An online shop is in scope, however small its till.

The micro enterprise exemption, and the thorn in it

Article 4(5) of the Directive exempts micro enterprises. Lovely, you will say, article over, coffee time. Hold on. Article 3(23) defines them as enterprises which employ fewer than 10 persons and have an annual turnover or annual balance sheet total not exceeding 2 million euro. Both limbs must hold, not whichever one suits us.

Now the thorn: the exemption applies to services only. A micro enterprise that places products covered by the Act on the market, for example self service terminals or devices with an interface, is not exempt. Article 14(4) and (8) only give it lighter documentation obligations. Lighter. Not zero.

In practice, if you run an online shop with two employees, your service is exempt. That does not mean accessibility is not worth your while, as we will see, it means you have no legal obligation from this particular provision. And between “not required to” and “does not concern me” sits a fair amount of revenue you never made.

Which standard applies, and which one does not yet

The European standard is EN 301 549. The version cited in the Official Journal, through Implementing Decision (EU) 2021/1339, is V3.2.1 of March 2021, and clause 9.6 states that conformance with WCAG 2.1 Level AA satisfies the web requirements.

Two clarifications I rarely hear stated correctly:

First, version V4.1.0 of June 2026, aligned to WCAG 2.2, exists only as a final draft. It is not cited in the Official Journal.

Second, and more important: no harmonised standard has yet been published for the European Accessibility Act. The Official Journal citation of EN 301 549 relates to Directive 2016/2102 for the public sector. Anyone selling you “EAA certification” on the basis of a harmonised standard is selling something that does not yet exist. And selling it with a very handsome badge, believe me. What does exist is the presumption of conformity you get by meeting WCAG AA, and that is the sensible route.

In numbers, because numbers calm a conversation down: Level A plus AA means 50 success criteria under WCAG 2.1 and 55 under WCAG 2.2. WCAG 2.2 became a W3C Recommendation on 5 October 2023, was updated on 12 December 2024, and corresponds to ISO/IEC 40500:2025. WCAG 3.0 remains a Working Draft.

What the state of the web actually looks like out there

Every February, WebAIM scans one million home pages. The February 2026 edition, the eighth, tests against WCAG 2.2 Level A and AA and finds:

• 95.9% of home pages had detectable errors, up from 94.8% in 2025.
• 56.1 errors per page on average, a 10.1% increase in one year.

An average never gets fixed; individual errors do. So the breakdown is the useful part:

Those six categories account for roughly 96% of all detected errors. That is very good news, because none of them is difficult or expensive to fix. Colour contrast is one line of CSS. alt text is one sentence per image. The page language is one attribute on <html>. This is not a rebuild. It is a keyboard and a little patience.

The worsening trend is largely down to pages growing more complex faster than they get fixed. We build faster than we tidy up. Then act surprised.

How many people this actually affects

There is a number in circulation here that needs care. The “87 million Europeans with disabilities” figure comes from a 2021 Commission estimate in COM(2021) 101, not from a current statistic. I have seen it in slide decks, in proposals, in articles. With its source? Rarely.

The current statistic is Eurostat, series hlth_silc_12: 23.9% of the EU population aged 16 and over reported activity limitation due to a health problem in 2024, of which 17.2% to some extent and 6.7% severely.

For Greece, ELSTAT published the results of its 2025 Survey on Income and Living Conditions on 8 April 2026: among the population aged 16 and over, 8.7% with severe limitation and 9.1% with some limitation, a total of 17.8%. By functional difficulty: vision 17.3%, mobility 15.1%, hearing 9.9%, memory or concentration 9.9%, self care 8.0%, communication 5.2%.

One caution so you are not misled, because plenty of people slip here: it makes no sense to compare that 17.8% with older percentages from the European Health Interview Survey, because the two instruments measure different things. This is not a rise.

One adult in six, however, is a real number. Not a figure of speech, not an estimate. And vision, which leads the list at 17.3%, is precisely what low contrast text hurts, the first error in the table above. You can see where this is going.

What you actually risk in Greece

Honesty here too, because this is where the circus sets up its tent. Article 27(2) of law 4994/2022 delegates penalties to a presidential decree. No published decree with specific amounts can be found. Any figure circulating in articles or sales pitches without a Gazette citation is unsupported. Ask for the Gazette reference next time. Watch how fast the subject changes.

That does not mean there is no risk, and the risk recently became more concrete. Law 5218/2025 (Government Gazette A’ 125/14.07.2025) added Article 25A to law 4994/2022, providing for a collective action before the Multi member Court of First Instance, plus an administrative appeal with a 30 day deadline.

So the exposure is not primarily an administrative fine. It is that a consumer association or a disability organisation can act collectively against an online shop that does not work with a keyboard or a screen reader. That means time, lawyers and publicity. Guess which of the three costs most.

Five things you can check this afternoon

Five tests you can run yourself in half an hour, with no paid tooling. No licences, no subscriptions, no consultants:

1. Unplug the mouse. Navigate with Tab and Enter from the home page through to checkout. If you get stuck anywhere, or cannot see where you are, that is an access barrier. Yes, it is infuriating. That is exactly why it is worth doing.
2. Zoom to 200%. Content must stay readable, with no horizontal scrolling.
3. Check the contrast of your grey helper text. Normal text needs a ratio of at least 4.5:1. Light grey on white is the single most common failure on the web, and somebody picked it because it looked “elegant”.
4. Open a form and check the labels. A placeholder is not a label; it disappears the moment you start typing. And then your visitor stares at an empty box, trying to remember what it wanted.
5. View the page source and confirm there is a lang attribute on <html>. Without it, a screen reader reads Greek text with an English accent.

And one more that costs nothing: alternative text on product images. It is an accessibility obligation and at the same time one of the few things that directly helps your visibility in search. Two birds, one stone, no invoice.

Why this matters in the end

Accessibility in Greece today sits roughly where SSL sat in 2016: an obligation for some, good practice for everyone, and ignored by most until someone knocks on the door. Remember how fast we all moved back then? It goes like that.

The substance is simpler than the legislation. Six error categories account for 96% of the problems, none of them is expensive to fix, and the one adult in six who struggles is also a customer who did not finish the order. A customer who could not read the grey text, could not find the field, and left without ever telling you why.

We started with whether your site sells. Let us end there: if it sells, it sells to people. All of them.

If you want an accessibility audit of your site, with a fix list in priority order rather than an automated 400 page report, get in touch.