The EU Accessibility Act (officially Directive 2019/882, locally implemented in Croatia as the Zakon o pristupačnosti) became enforceable on June 28, 2025. 2026 is the year the audits, complaints, and fines actually arrive. If you sell goods or services online to consumers in the EU, this affects you, and most Croatian business websites are not ready.

This is what every business owner and developer in Croatia needs to know in plain terms — what the law requires, who it applies to, what happens if you ignore it, and what it actually costs to comply.

What changed and why now

The Accessibility Act is the EU's attempt to standardise digital accessibility across member states. Previous national laws covered public-sector sites; the new directive extends comparable obligations to private-sector businesses that sell to consumers online. It became applicable on June 28, 2025, after a six-year transition period.

Croatia transposed the directive into national law via the Zakon o pristupačnosti web stranica i mobilnih aplikacija subjekata javnog sektora and supporting acts that extend coverage to private businesses meeting the EU thresholds. Enforcement in Croatia falls under the Povjerenik za informiranje and sector-specific regulators depending on the business type.

The first wave of formal complaints and inspections is rolling out through 2026. The pattern in other EU countries that started enforcement earlier (Germany, France, Ireland) is clear: regulators give a warning and a remediation window for first complaints, then fines for repeat or ignored violations. The fines themselves are not catastrophic, but the reputational damage and the urgency of forced remediation are.

Who the Act actually applies to

The directive applies to businesses providing covered goods or services to EU consumers. The covered services include:

  • E-commerce websites (selling goods or services online).
  • Online banking and consumer financial services.
  • E-books and reading software.
  • Audiovisual media services and access to them.
  • Passenger transport booking (web and app).
  • Telephone and emergency services.
  • Computer hardware and operating systems for general consumers.

For Croatian business owners, the critical line is e-commerce: if your site takes online bookings or payments from EU consumers, you are in scope. That includes:

  • Tourism booking sites (boat tours, accommodation, restaurants taking deposits).
  • Online shops of any size above the microenterprise threshold.
  • Membership and subscription services.
  • Service businesses with online quote-and-pay flows.

There is a microenterprise exemption for businesses with fewer than 10 employees and either annual turnover or balance sheet under €2 million, but only for services — microenterprises selling physical products are still in scope. Many Croatian tourism and hospitality businesses qualify for the service-side exemption, but the moment you grow past 10 employees, the exemption disappears.

B2B-only sites (you only sell to other businesses, no consumer-facing transactions) are largely out of scope. Information-only sites with no transactions are also out of scope, though Croatian public-sector accessibility law already covers government and government-adjacent sites.

If you are unsure whether your site is in scope, the simple test: does an EU consumer ever click "buy" or "book" on it? If yes, plan to comply.

What the Act actually requires

The technical standard is WCAG 2.1 Level AA (Web Content Accessibility Guidelines, version 2.1, conformance level AA). This is not a vague guideline — it is a specific list of 50 success criteria across four principles: perceivable, operable, understandable, robust.

The core operational requirements:

  • Keyboard accessible. Every interaction works with Tab, Enter, Esc, arrow keys. No mouse-only widgets.
  • Sufficient colour contrast. 4.5:1 for body text, 3:1 for large text, against the actual background.
  • Text alternatives for every non-decorative image.
  • Form labels properly associated with inputs.
  • Visible focus indicators on every interactive element.
  • Language declared in the HTML root and on any inline foreign-language passages.
  • Resizable text up to 200% without breaking layout.
  • Logical heading hierarchy (one H1, then H2/H3 sections).
  • No content that flashes more than 3 times per second.
  • Time limits adjustable (or not used at all where avoidable).
  • Error messages programmatic and clear, not colour-only.
  • Predictable navigation and consistent identification across pages.
  • Status messages announced to screen readers without forcing focus.
  • Audio and video have captions, transcripts, or audio descriptions where applicable.

This list is not exhaustive but covers 80% of what most business sites need to do. The full WCAG 2.1 AA checklist runs about three pages.

The accessibility statement

Beyond the technical compliance, the Act requires a published accessibility statement on every covered site. The statement must include:

  • A declaration of conformance status (full, partial, or non-conforming).
  • A specific list of any non-accessible content and the reason for non-compliance.
  • A contact mechanism for users to report accessibility issues.
  • A reference to the enforcement procedure if the response is unsatisfactory.

In Croatia, the contact route directs to the Povjerenik za informiranje. The accessibility statement must be linked from the footer of every page and be itself accessible (which sounds tautological but is a real failure mode — many statements are PDFs that are not screen-reader friendly).

There are template statements available in Croatian and English from the EU and from the Croatian regulator. Use them as a starting point and customise.

What inspections and fines look like

The enforcement reality in Croatia, based on the public-sector precedent and early private-sector cases:

  • Complaints route through the Povjerenik za informiranje (or sector-specific regulators for finance and telecoms).
  • First-stage response is usually a notice with a 30–60 day remediation window.
  • Second-stage response if the site is still non-compliant: fines and a public listing in compliance reports.
  • Fine ranges are set in the implementing law and are typically in the low thousands of euros for first offences, scaling up for repeat or ignored violations.

The financial fines themselves are not the main risk. The real costs are:

  • Reputational damage from being publicly named as non-compliant.
  • Forced rapid remediation at premium rates because you have a 30-day clock.
  • Lost customers while the remediation work is in flight (some businesses pull live functionality rather than ship a quick fix).

For most businesses, voluntary pre-emptive compliance is dramatically cheaper than reactive remediation under regulatory pressure.

Common failure modes I see in audits

When I audit Croatian business sites for WCAG 2.1 AA, the same failures appear over and over:

  • Custom carousels and image galleries that do not respond to keyboard input. Tab into the carousel, get stuck.
  • Modal dialogs without focus management. The modal opens, the focus stays on the page behind it. Screen readers continue reading the wrong content.
  • Custom dropdown selects that look like the native one but lack ARIA attributes. Sighted users cannot tell the difference; screen readers cannot use them at all.
  • Form errors shown in red text only. Colour-only signalling fails a basic WCAG criterion.
  • Missing form labels — placeholder text used as a label, which disappears the moment the user types.
  • Insufficient contrast on light grey body text or light text on busy backgrounds. 4.5:1 is genuinely demanding; many trendy minimal designs fail.
  • Auto-playing video with sound on the homepage. Accessibility barrier and a UX disaster.
  • Hover-only menus on navigation. Touch users and keyboard users cannot reach the submenu.
  • PDFs as the only document format for important content (menus, terms). Many PDFs are not accessible.
  • Language attribute missing or wrong on multilingual sites. The Croatian page declared as lang="en".

Each of these is a few hours of fix work in isolation. Across an entire site they add up to a significant remediation project.

Retrofit cost versus build-it-in cost

The cost difference between accessibility built into a site from day one and accessibility retrofitted onto an existing site is dramatic and consistent. From real client engagements:

  • Built in from day one: roughly 5–10% added to the build cost. Mostly design decisions (contrast, focus styles, motion preferences) and a slightly slower implementation pace as components are tested for keyboard and screen-reader behaviour.
  • Retrofitted onto an existing site: typically 40–80% of the cost of the original build. You are touching every component, every form, every page template. Some platforms (looking at you, page builders — covered in Wix and Squarespace vs Custom) are not even fully fixable without a rebuild.

The numbers are not subtle. If you are commissioning a new site in 2026, accessibility from day one is the only economically sensible choice. If you have an existing site that is not compliant, the retrofit is real work — and the longer you wait, the more pages and patterns there are to fix.

What good accessibility actually looks like

A properly accessible Croatian business site has these properties:

  • Tab through every interactive element. Visible focus on each. The order matches the visual layout.
  • All images have descriptive alt text. Decorative images have empty alt (alt="").
  • Every form input has a visible, persistent label.
  • Colour contrast passes 4.5:1 for body text everywhere.
  • Headings flow H1 → H2 → H3 logically with no skipped levels.
  • A skip-to-content link appears at the top of every page.
  • The language is declared correctly per locale (<html lang="hr">, <html lang="en">).
  • An accessibility statement is linked from the footer and itself accessible.
  • The site works with the screen reader announcing the right things in the right order.

None of this is exotic. All of it is testable in an afternoon for any single page. The work is doing it consistently across an entire site.

The intersection with SEO

Accessibility and SEO overlap more than most owners realise. Semantic HTML, proper headings, alt text, descriptive link text, fast loading, and clear language structure are all good for both screen readers and Google. A site built well for accessibility tends to also rank well, and vice versa.

The implication: if you are already taking SEO seriously, accessibility is a smaller incremental effort. The full SEO baseline that already overlaps significantly with accessibility is in my realistic SEO checklist — particularly the on-page and accessibility sections.

Where to start tomorrow

A pragmatic six-step plan for a Croatian business owner who reads this and realises their site is not compliant:

  1. Run a WCAG audit. Use Lighthouse's accessibility audit for a quick first pass. Use axe DevTools or WAVE for a more thorough check. Get the list of issues.
  2. Triage. Group by severity: keyboard traps and missing labels are critical; minor contrast issues are important but secondary.
  3. Fix the critical issues first. Keyboard traps, missing labels, missing alt text, focus visibility. These are usually the highest-impact and the easiest to fix.
  4. Publish an honest accessibility statement. Use the Croatian regulator's template. State the compliance level honestly, even if it is "partial."
  5. Plan the rest. A four-to-eight week remediation window for typical small business sites is realistic. Build a checklist, work through it.
  6. Make accessibility part of your launch checklist forever. Every new page, every new feature, gets keyboard tested and contrast-checked before going live.

This is not a one-time project. It is a continuous practice, like SEO or security. Built into the workflow once, it stays cheap forever.

Work with me

If you run a Croatian business and are not sure whether your site complies — or you want a pre-emptive audit before anyone files a complaint — I do accessibility audits and remediation engagements. Email info@tonibarisic.com or use the contact form. For local context on hiring, see Hiring a Web Developer in Split, Croatia. For the broader SEO and quality baseline that overlaps significantly with accessibility, my realistic SEO checklist and Why I Build Custom Websites Instead of Using Templates are the companion pieces.