Web Development·13 July 2026·updated 28 September 2026·7 min read
Is your booking website legal? The EU Accessibility Act explained for Belgian hotels and SMEs
In short
- The European Accessibility Act (Directive (EU) 2019/882) applies since 28 June 2025 and covers "e-commerce services" — any website or app where a consumer can book or buy online. Hotel booking pages and online shops are squarely in scope.
- In Belgium, micro-enterprises (fewer than 10 people and turnover or balance-sheet total of €2 million or less) have until 28 June 2030; larger businesses have been in scope since 28 June 2025. A café site that only shows its menu and phone number is not an e-commerce service, so the rules do not reach it.
- In practice, compliance is measured against the European standard EN 301 549, which currently uses WCAG 2.1 level AA; building to WCAG 2.2 AA now is the safer choice. That means alt text, keyboard navigation, strong colour contrast and labelled forms.
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 according to the European Commission. 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.
- Micro-enterprises: fewer than 10 people and an annual turnover or balance-sheet total of €2 million or less. The EU directive exempts them from the service rules, but Belgium did not copy that exemption: in Belgium they have until 28 June 2030, while larger businesses have been in scope since 28 June 2025 (FPS Economy).
- Outside the rules: a café or family restaurant site that only shows its menu and a phone number is not an e-commerce service, so the rules do not reach it, whatever the size of the business.
A site that only gives information is outside the rules. A small business that takes bookings or sells online has until 28 June 2030, and a larger one has been in scope since 28 June 2025. 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
In practice, compliance is measured against the European standard EN 301 549, which currently uses WCAG 2.1 level AA; a version based on WCAG 2.2 was published in September 2026, so building to WCAG 2.2 AA now is the safer choice. You do not need to memorise the guidelines. 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 before your deadline
Here is the part the compliance framing misses. An accessible site is a better site. Clear structure, good contrast and labelled forms make the site easier 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.
A short, practical way forward
- Decide if you are in scope. Do you sell or take bookings online? If yes, this applies to you: since 28 June 2025 above the micro-enterprise threshold, from 28 June 2030 below it.
- Run a basic check. A quick audit against WCAG 2.2 AA will surface the obvious gaps, usually contrast, missing alt text and unlabelled forms.
- Fix the essentials first. Keyboard navigation, form labels and contrast are the high-impact, low-effort wins.
- Bake it into future changes so you do not drift back out of compliance.
Our web design service builds to this standard from the start, so accessibility is designed in rather than added 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.
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