Is Your Booking Website Legal? The EU Accessibility Act, Explained for Belgian Hotels & SMEs

A quiet EU deadline that touched a lot of websites

On 28 June 2025 a piece of EU law called the European Accessibility Act (formally Directive (EU) 2019/882) started to apply across every member state, Belgium included. It got far less attention than GDPR, but for anyone who sells or takes bookings online it matters just as much, because it reaches ordinary business websites, not just big platforms.

The good news: it is not the compliance monster the scare-mailings suggest. Once you understand who it applies to and what it actually asks for, it is manageable, and much of it is simply good web design you would want anyway.

What the law is really about

The Act's goal is simple: products and services should be usable by people with disabilities, roughly 87 million people across the EU. For websites, that means someone using a screen reader, navigating with a keyboard instead of a mouse, or needing larger text and stronger contrast should still be able to browse your site and complete a booking.

The category that catches most local businesses is "e-commerce services": any website or app where a consumer can conclude a contract online. A hotel booking engine, a restaurant that takes paid reservations or sells vouchers, a shop that sells online, a ticketing page, these are all in scope.

Who has to comply, and who does not

This is the part worth reading slowly, because it decides whether the law is your problem at all.

• In scope: businesses offering an in-scope service (like online booking or online sales) to consumers, above the microenterprise threshold.
• Exempt (for services): microenterprises providing services, defined as fewer than 10 people and an annual turnover or balance-sheet total of €2 million or less. A small café or a family restaurant that only shows its menu and a phone number very often sits here.

So a two-person bistro with a simple website is usually outside it. A hotel with a real booking system, or an SME running an online shop, especially once it grows past those thresholds, is usually inside it. If you are near the line, treat the €2 million and 10-people figures as the test, not a guess.

One honest note: this is general information, not a legal opinion on your specific business. The thresholds are clear, but if your setup is borderline it is worth a proper check.

What "accessible" means in plain terms

Belgium, like the rest of the EU, leans on the harmonised standard behind the Act, which lines up with WCAG 2.1 level AA — the widely used web accessibility guidelines. You do not need to memorise them. In practice they come down to a handful of concrete things:

• Text alternatives on meaningful images, so a screen reader can describe them.
• Keyboard operability: every menu, form and button works without a mouse.
• Enough colour contrast between text and background, and never using colour alone to carry meaning.
• Readable, resizable text that does not break the layout when enlarged.
• Properly labelled forms with clear, specific error messages.
• Captions or transcripts for video, and a visible focus outline so keyboard users can see where they are.

Most of these are invisible to your average visitor and quietly helpful to everyone, older guests, people on a phone in bright sunlight, anyone in a hurry.

Why this is worth doing even if you are exempt

Here is the part the compliance framing misses. An accessible site is a better site. Clear structure, good contrast and labelled forms improve conversion for all visitors, and search engines read the same clean structure that assistive technology relies on. Accessibility, usability and SEO pull in the same direction.

Put differently: the businesses that treat this as "one more rule" do the minimum. The ones that treat it as "make the site easier to use" tend to book more guests, exempt or not.

A short, practical way forward

1. Decide if you are in scope. Do you sell or take bookings online, and are you above the microenterprise threshold? If yes, this applies to you.
2. Run a basic check. A quick audit against WCAG 2.1 AA will surface the obvious gaps, usually contrast, missing alt text and unlabelled forms.
3. Fix the essentials first. Keyboard navigation, form labels and contrast are the high-impact, low-effort wins.
4. Bake it into future changes so you do not drift back out of compliance.

We build and maintain sites with this standard in mind as part of our web design service, so accessibility is designed in rather than bolted on later. If you are not sure whether the Act applies to you or where your site stands, tell us about your site and we will give you a straight read, in plain language, no jargon.