Since June 28, 2025, Poland has been enforcing the Act on Meeting Accessibility Requirements for Certain Products and Services (Journal of Laws 2024, item 731). Small business owners who run a simple website or small online store need to know whether the new regulations apply to them. As it turns out, for many micro-businesses the answer is "no" — but it's worth understanding why and what you gain from voluntarily implementing accessibility standards.
In this article you'll find clear criteria to determine whether your business falls under the exemption. You'll also learn why accessibility elements — readable contrast, appropriate button sizes, clear image descriptions — improve your site for all users, regardless of the legal requirement.
The Accessibility Act — what it regulates and when it started
The Act on Meeting Accessibility Requirements for Certain Products and Services (Journal of Laws 2024, item 731) entered into force on June 28, 2025, in accordance with Article 88 of the Act. This provision defines a range of digital services that must meet accessibility requirements derived from the European Accessibility Act.
The Act primarily covers large-scale electronic services: internet banking, booking platforms, ticket sales systems. In practice, these are products and services used by large numbers of people, including those with visual, hearing, or motor impairments.
For a micro-business owner, the key is understanding which services the Act covers and which it exempts. The law does not apply to all business websites — its sphere of application is much narrower than media headlines suggest.
Definition of electronic commerce services
Article 5 point 32 of the Act precisely defines what constitutes "electronic commerce services" under the law. These are services offered or provided remotely through websites and mobile devices, electronically, at the individual request of a consumer to conclude a contract (Dz.U. 2024 item 731, art. 5 point 32).
This is a crucial distinction: an electronic commerce service is one where a customer can conclude a contract through a website or mobile app — for example, order a product, book a service, or purchase access. If your website only presents your offer and requires a phone call or email to complete a transaction, it is not an electronic commerce service under the Act.
The micro-business exemption — Article 4 point 1
Article 4 point 1 of the Act states that the provisions do not apply to services offered or provided by micro-entrepreneurs [source: eli.gov.pl, art. 4 point 1]. This exemption is fundamentally important for small business owners in Poland.
What does this mean in practice? If you run a sole proprietorship or a company employing fewer than 10 people (which defines a micro-entrepreneur in Polish law), the Accessibility Act does not impose WCAG website compliance requirements — provided you offer services, not products.
The exemption applies only to services offered by micro-entrepreneurs. If you run an online store selling products (rather than services), the regulations may apply. Similarly, if your company exceeds the micro-entrepreneur threshold, the exemption ceases to apply.
Who fits the exemption — decision table
The following table shows situations where a micro-business can use the exemption and when they should consult a lawyer:
| Business type | Does the Act cover services? | What to check with a lawyer |
|---|---|---|
| Micro-business with a business card site (contact details only, no booking forms) | No | None — the site does not provide an electronic service |
| Micro-business with a contact form (no e-commerce) | No | None — no contract can be concluded through the site |
| Micro-business with a full online store (orders, payments) | Check | Whether you sell products (not services) — the exemption may not apply |
| Company with 10+ employees with any website | Yes | Scope of requirements — which site elements fall under the Act |
| Micro-business with online booking service (contract through site) | Check | Whether the service qualifies as "electronic service" — consultation with DPO recommended |
Why you should apply accessibility standards even without the requirement
Even if your business qualifies for the exemption, implementing basic accessibility standards brings concrete business benefits. The elements that make a site accessible for people with disabilities simultaneously improve the experience for all users.
Color contrast and text readability
Text-to-background contrast of at least 4.5:1 is the required minimum under Web Content Accessibility Guidelines (WCAG) 2.0 (web.dev on color contrast). This means text must be sufficiently distinct from the background to be readable even in low light or by people with reduced contrast sensitivity.
In practice, light gray text on a white background or white text on a light photo background causes problems for many users. Low contrast also makes the site hard to use on a phone in sunlight or for older people who naturally lose visual acuity.
Touch target sizes
The minimum recommended touch target size is around 48 device independent pixels (with a proper viewport) (web.dev on tap targets). This applies to buttons, links, and form fields — they must be large enough to tap easily with a finger, without accidentally clicking neighboring elements.
This is especially important for owners of hairdressing salons, beauty studios, or medical practices — their clients often browse the offer on their phone one-handed, on the way to the appointment. Too small "Book appointment" buttons lead to abandoned contact requests.
Alternative text for images
Every image on your site should have an alt attribute — a description that a screen reader will read to a blind user. Good alternative text is not just an accessibility requirement: it also helps Google understand what appears on the page, which affects SEO.
Instead of "image1.jpg" or "product photo," write "hairdresser trimming a client's hair" or "interior of a medical practice with modern diagnostic equipment." This is content that builds trust and shows professionalism.
Mini accessibility audit without a specialist
You don't need to hire an auditor to check your site's basic accessibility. The table below shows what to check yourself and how to fix it:
| Element to check | How to do it | Standard |
|---|---|---|
| Text contrast | Open the site on your phone in light and dark mode — is text readable? | 4.5:1 for normal text, 3:1 for large text |
| Keyboard navigation | Try navigating the site using only the Tab key — can you reach every link and button? | Every interactive element must be reachable |
| Image alt text | Right-click an image and choose "Inspect" — is there an alt attribute? | Every image has a descriptive alt |
| Form field labels | Click on a field — is a clear label visible while filling? | Every field has a visible label |
| Touch target sizes | Measure a button on your phone — is it at least 48px in each direction? | Minimum 48 × 48 px |
| Structural headings | Check if the page has one H1 and logically ordered H2, H3 | Hierarchy without skipping levels |
| Page language | In browser settings, change the language — does the site switch? | lang attribute in code |
| Multi-word links | Are links not single words like "here" or "more"? | Link makes sense out of context |
Automated verification tools
Lighthouse (built into Chrome and Edge) — in the Audits tab, select Accessibility and run the audit. The tool automatically detects missing alt attributes, low contrast, missing form labels, and navigation issues.
WAVE Web Accessibility Evaluation Tool (wavethinkers.github.io) — a browser plugin that shows errors directly on the page as icons. Quickly identifies which elements need fixing.
Automated verification detects only part of accessibility problems. It won't check the meaning of alt text, logical element order, or form readability for screen reader users.
Automated verification tools
Lighthouse (built into Chrome and Edge) — in the Audits tab, select Accessibility and run the audit. The tool automatically detects missing alt attributes, low contrast, missing form labels, and navigation issues.
WAVE Web Accessibility Evaluation Tool (wavethinkers.github.io) — a browser plugin that shows errors directly on the page as icons. Quickly identifies which elements need fixing.
Automated verification detects only part of accessibility problems. It won't check the meaning of alt text, logical element order, or form readability for screen reader users.
What not to do — accessibility pitfalls
The market offers solutions promising "one-click accessibility" — plugins and overlays that add contrast change or text enlargement buttons. Such solutions do not meet the Act's requirements and can mislead users.
Problems with accessibility overlays:
- They don't fix the site structure, only add a visual layer
- They often don't work with screen readers
- They can worsen the site experience for some users
- They don't eliminate barriers, they just mask them
Similarly risky is publishing a "fully accessible site" declaration on your page without conducting an audit. If not everything is truly accessible, such a statement could expose the business to accusations of misleading customers.
Why it's worth acting sooner rather than later
Even if you currently fall under the micro-entrepreneur exemption, your situation may change. Your business may grow — employing more than 10 people means you exceed the micro-entrepreneur threshold and lose the exemption. At that point, it's worth having a site that already meets basic standards.
Voluntarily implementing good accessibility practices early also reduces costs. Fixing an existing site is more expensive than building an accessible site from the start. This especially applies to elements hard to change later: form templates, navigation structure, color schemes in brand identity.
What to do in advance:
- Establish company colors compliant with 4.5:1 contrast for main text
- Choose website templates with built-in accessibility
- Create forms with clear labels and helpful messages
- Add alt text to all images from day one
Do it yourself in 2 hours — a practical action plan
You have limited time but want to improve your site's accessibility? Here are 10 checks you can do yourself in about 2 hours:
- Open the mobile version of your site — try tapping every button with your finger without accidentally clicking a neighbor
- Disable images in your browser and check if you understand the page content
- Navigate the entire site using only the Tab key — can you reach the contact form?
- Enter text in a form field and delete it with Backspace — can you see what you're typing?
- Open the site in dark mode — is text still readable?
- Run a Lighthouse accessibility audit — how many errors do you see?
- Right-click each image and choose "Inspect" — does it have an alt attribute?
- Check if "Call" and "Write" buttons work when activated with the Enter key
- Open the site on your phone in bright sunlight outside — can you see the content?
- Ask someone for their first impression — does the site look professional and clear?
After these 10 checks, you'll know which elements need the most urgent fixing. Record your results and pass them to whoever manages your site — preferably as a list with item numbers to fix.
What accessibility looks like when a system handles it
A site built on accessible principles works differently than a typical site "fixed after the fact." A system that considers accessibility from the start automatically checks elements when publishing each new page.
- 01Page template
- →02automatic contrast verification on publish
- →03accessibility report for new content
- →04list of elements requiring manual verification
In practice, this means each new page on the site undergoes basic automated verification: checking color contrast, presence of alt attributes, form label presence. This catches errors at the publishing stage, not months later when a user reports a problem.
Such a site is also easier to maintain — the template enforces good practices rather than requiring constant fixes. For a business owner, this means less time managing the site and less risk that new pages will have accessibility issues.
See how accessible sites and stores work in practice — check out Websites and stores with built-in accessibility principles, learn about the UI/UX design approach that incorporates accessibility from the first design stage, or explore Online Stores with accessible order forms. For better visibility in Google, check SEO and maps, and if you want to increase inquiries, UX and conversion helps optimize forms for better results. If you run a restaurant, check the article about accessibility of a restaurant website and ordering for practical examples. Learn also how automation affects GDPR in daily business operations. If you're interested in why customers don't leave inquiries, read the analysis of Warsaw company websites. Discover the four automation thresholds that help you start at the right moment.
Frequently asked questions
Am I running a business covered by the Accessibility Act?
If you're a micro-entrepreneur (up to 10 employees) and run a business card site or simple service website with a contact form — most likely not. The Act exempts services offered by micro-entrepreneurs. If you run a full online store with orders and payments, check with a lawyer or DPO whether your business qualifies for the exemption.
Do I need to audit my site for accessibility?
If you don't run an electronic commerce service as a micro-entrepreneur, you have no legal obligation. However, consider a voluntary audit because accessibility elements improve usability for all customers.
What is 4.5:1 contrast and how do I check it?
This is the ratio of text brightness to background brightness. You can check it with online tools (e.g., WebAIM Contrast Checker) or browser plugins. In practice: dark text on light background or light on dark usually meets the standard, gray on white — does not.
Does an "one-click accessibility" overlay meet the Act's requirements?
No. Visual overlays (enlargement buttons, contrast changes) don't eliminate barriers for screen reader users. The Act requires fundamental changes to site structure, not cosmetic additions.
How much does adapting a site for accessibility cost?
It depends on the initial state. Simple fixes (contrast, alt, form labels) can be done as part of regular content updates. Comprehensive audit and rebuilding interactive elements costs similarly to other design work — specific estimates depend on the specific site.
When does a micro-business website lose its exemption?
When the business stops being a micro-entrepreneur (more than 10 employees or revenue exceeding statutory thresholds) or when the nature of activity changes (e.g., you add a full online store with orders). Monitor these thresholds and prepare your site for potential changes.