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The European Accessibility Act & Colour Contrast: What It Actually Requires
The Act is in application, the summaries online are a mixture of accurate, outdated and sales copy. This page states the contrast position with dates — and is explicit about where a colour tool's evidence ends.
The short version: Directive (EU) 2019/882 has applied since 28 June 2025. For covered digital services, the technical route is EN 301 549 → WCAG 2.1 AA, so the contrast duties are 4.5:1 (normal text), 3:1 (large text) and 3:1 (non-text, against adjacent colours). Enforcement is national; microenterprise service providers are exempt; the Act does not apply in the UK.
The chain: Act → standard → criteria
The Directive does not contain the numbers 4.5 or 3 anywhere. It requires covered products and services to be accessible, and points to harmonised standards for the technical detail. EN 301 549 is that standard for ICT, and its web clauses reference WCAG 2.1 Level AA. So the working contrast position for an EU-facing service today is exactly the WCAG position: criteria 1.4.3, 1.4.6 (enhanced, not required at AA) and 1.4.11, computed as the ratios guide explains — unrounded.
One live nuance: a newer edition of EN 301 549 (v4.1.1) has been published and points to WCAG 2.2, but at the date this page was last verified it had not yet been cited in the EU Official Journal, which is the step that makes an edition the referenced route. WCAG 2.2 does not change the contrast thresholds, so the practical difference for colour work is nil — but the framing matters for records, which is why this site states WCAG 2.1 as the basis and dates the statement.
Scope, exemptions, transition — the parts summaries skip
- Covered services include e-commerce, consumer banking, e-books and parts of transport and telecoms, sold to consumers in the EU. The list is specific, not "all websites".
- Microenterprises providing services are exempt. Products follow different rules.
- Transition: member states could allow certain services provided before 28 June 2025 to continue under pre-existing arrangements until 28 June 2030; self-service terminals have a longer horizon still.
- Enforcement is national — market-surveillance authorities and national penalties, not an EU contrast police. Complaint routes run through member-state bodies.
- The UK is out of the Directive; the Equality Act 2010 is the UK frame, and in practice it points auditors at the same WCAG criteria.
What evidence is worth keeping
For the contrast slice of your records: a dated, reproducible measurement of the pairings your product actually uses — roles, grounds, ratios, thresholds — kept with the palette it came from. That is what the audit sheet generates, and its face carries the limit in plain words: measured ratios are working evidence for one part of conformance, not a certification. A sheet that shows a failure found, repaired and re-measured is credible evidence of a working process; a "certificate" issued by a colour tool would be the opposite.
The rest of conformance — keyboard operation, focus order and visibility as a whole, labels, errors, motion, target size — needs its own audit against the full standard. This page's scope is the contrast corner, stated and sourced; treat any page that promises the whole Act from a palette the way you would treat this one if it tried.
Accessibility Act questions
Does the Accessibility Act name contrast ratios itself?
Not directly. The Directive sets accessibility requirements in functional terms; the technical route is the harmonised standard EN 301 549, which for web content references WCAG 2.1 Level AA — and that is where 4.5:1, 3:1 and the non-text 3:1 live. Meeting the standard gives a presumption of conformity with the Act’s requirements for the parts the standard covers.
My company is small. Are we exempt?
Service providers that are microenterprises — fewer than 10 employees and turnover or balance sheet at or under the Directive’s threshold — are exempt from the Act’s service requirements. Products are treated differently from services, and member states implement details nationally. Treat this page as a dated summary, not legal advice about your company.
We are in the UK. Does the Act apply to us?
The Directive does not apply in the UK. Selling covered services into the EU can still bring the Act into the picture for those services. Separately, UK accessibility duties rest on the Equality Act 2010 and sector rules, which predate the Act and point at the same WCAG criteria in practice.
Will generating an audit sheet make us compliant?
No. The sheet is evidence about one criterion family — colour contrast — measured properly and dated. Conformance involves the whole of WCAG 2.1 AA: keyboard access, focus visibility and order, names and labels, status messages, error handling and much more that no colour tool measures. Keep the sheet; do not mistake it for the audit.