Does your hotel's booking website have to be accessible? The European Accessibility Act explained (2026)

Updated: 9 November 2026

The European Accessibility Act (Directive (EU) 2019/882) has applied across the EU since 28 June 2025. E-commerce services are among the services it covers, so many hoteliers ask whether their booking website must comply. The short answer: if your business has fewer than 10 people and does not exceed EUR 2 million, the directive exempts you; if it is larger, the prudent approach is to treat your booking website as an e-commerce service.

What the directive covers

Article 2(2) applies it to services provided to consumers after 28 June 2025, and point (f) includes "e-commerce services". Article 3(30) defines them as:

Services provided at a distance, through websites and mobile device-based services, by electronic means and at the individual request of a consumer, with a view to concluding a consumer contract.
Recital 43 adds that the e-commerce obligations apply to the online sale of any product or service.
The directive does not name hotels. That a website where guests book and contract a stay falls within the definition is a reasonable reading of the text, not a literal sentence in the law.

The microenterprise exemption

This is the part that matters most to a small property:

Article 3(23) defines a microenterprise: fewer than 10 persons and an annual turnover or annual balance sheet total not exceeding EUR 2 million.
Article 4(5) says microenterprises providing services are exempt from the accessibility requirements and the related obligations (recital 70).
Note: the exemption is for service providers. Microenterprises dealing with products have a lighter regime, but no full exemption.
Portugal (Decree-Law 82/2022, art. 2(5)(b)) and Italy (Legislative Decree 82/2022, art. 3(3)) repeat the exemption in their laws. Spain transposed the directive with Law 11/2023 of 8 May, and Greece with Law 4994/2022.

If your business is larger

For businesses that are not microenterprises, the directive requires (Articles 4 and 13):

Meeting the Annex I accessibility requirements for services: websites and apps must be perceivable, operable, understandable and robust, and e-commerce must give information about the accessibility of what is sold and make identification, security and payment functions accessible.
Publishing information on how the service meets those requirements, in written and accessible form, for as long as the service is in operation (Article 13).
In practice, the reference is the EN 301 549 standard and the WCAG 2.1 guidelines (as Italy's AgID guidelines state).
Article 14 allows not applying a requirement if it needs a fundamental alteration of the service or is a disproportionate burden, but this has to be assessed.

Who enforces it

Each country designates its authority:

Spain: the regional governments, with a national technical support unit created in 2026.
Portugal: ANACOM for e-commerce (art. 28 of Decree-Law 82/2022).
Italy: AgID for services (art. 21 of Legislative Decree 82/2022).
Greece: we have not found an official source naming the authority for e-commerce services.

Worth doing even if you are exempt

The exemption removes the obligation, not the benefit. A clear website is also easier for search engines and AI assistants to read:

Alt text on photos of rooms and common areas.
Prices, times and conditions as text, not inside images or scanned PDFs.
Buttons and forms that work with a keyboard and have good contrast.
Physical accessibility information (lift, steps, adapted bathroom) written on the website: it is what travellers who need it ask about.
If you use another company's booking engine, ask how it complies: no official source clarifies who is responsible in that case.

How iQuota helps

iQuota's booking page uses real text for prices, conditions and policies, and AI assistants receive the same data in structured form through the connector. It does not replace an accessibility review of your own website, nor does it guarantee that an AI will recommend you. Payment is made at the property, with no commission.

Want your property on AI assistants with clear data, direct booking and no commission? The first 30 hotels join free until 30 June 2027.

See the Founding Hotels programme

Frequently asked questions

Does my hotel with 6 staff have to adapt its website?

If it also does not exceed EUR 2 million in turnover or balance sheet, it is a microenterprise and the directive exempts it from the service accessibility requirements. Adapting it anyway is a good idea.

Since when does it apply?

Since 28 June 2025 across the EU.

Which technical standard is used?

EN 301 549, which refers to the WCAG guidelines; Italy's AgID checks against WCAG 2.1.

Does the directive mention hotels?

Not expressly. It covers e-commerce, defined as distance services to conclude consumer contracts; a booking website fits that definition on a reasonable reading.

Sources

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