Who it applies to · company sites, brochure sites, blogs, portfolios, service pages
Ordinary websites
The act does not cover "websites" as such. It covers services from art. 3(2), and a website is a way of providing them. So the answer to "is my website covered" depends on what can be done on it, not on how it looks. Below: the line, examples on both sides of it, and what is worth doing whatever the answer.
The line: can a contract be concluded
"e‑commerce services – services offered or provided at a distance through websites and mobile devices, by electronic means and at the individual request of a consumer, with a view to concluding a contract;" (our translation)
If a consumer can conclude a contract on your website — buy, book, order, sign up with payment, purchase access — you provide an e‑commerce service and the act covers you in full: art. 12 (information and the four principles), art. 18 (identification, security, payment), art. 32 (conformity assessment and information in the terms), art. 37 (complaints), art. 73 (fines). If a consumer can only read, watch and get in touch — there is no e‑commerce service.
covered Examples
- a clinic's site with online appointment booking and prepayment,
- a restaurant's site with food ordering,
- a language school's site with course sign‑up and payment,
- a photographer's site with a print shop,
- a blog with a paid newsletter or membership,
- an event site selling tickets,
- a SaaS site with account registration and a paid plan for individuals,
- a developer's site with online apartment reservation.
out of scope Examples
- a company brochure site with a description, address and phone,
- a blog without payments,
- a designer's portfolio with a "write to me" form,
- a clinic's site with a phone number for appointments,
- a product page "where to buy" pointing to other people's shops,
- an event information page without ticket sales,
- a B2B‑only platform with company verification,
- intranets and internal pages.
Three notes on the line. First, a contact form is not the conclusion of a contract — but a "request a quote and pay a deposit" form is. Second, "with a view to concluding a contract" includes free contracts (e.g. a free account with terms), although the authorities will first look where the money is. Third, if you embed someone else's sales widget (a booking system, tickets, payments) on an information page, the e‑commerce service is provided by whoever concludes the contract with the consumer — check the widget's terms for who that is. If it is you — the widget is part of your service and art. 4(2)(b) (content not under your control) does not save you, because you chose it and can change it.
A micro‑enterprise with a covered website
If you conclude contracts online but employ fewer than 10 people and have a turnover or balance sheet total of up to €2 million, art. 4(1) excludes your services from the act. Two caveats: the status is checked every year against the numbers, and partners (marketplaces, payment operators, public purchasers) increasingly require WCAG by contract. An exemption with an asterisk.
Why "out of scope" does not mean "no risk"
- Websites grow. A brochure site today, a shop next year. Accessibility built in from the start costs a fraction of a later rebuild — especially since the templates, themes and plugins the site was built on will stay with it.
- Customers leave quietly. A person who cannot read your offer at 200 % zoom or in dark mode does not complain. They choose a competitor.
- Search engines see what a screen reader sees. Headings, image alternatives, page titles, descriptive links, fast loading — the accessibility checklist and the SEO checklist mostly overlap.
- Contracts and tenders. Public purchasers require WCAG 2.1 AA from website and system contractors; a supplier whose own site is inaccessible loses credibility in the first conversation.
- Reputation. An inaccessible website of a company that works with people — a clinic, a school, a law firm, a foundation — is a visible contradiction.
The minimum for every website — ten things that cover most of it
Language and title
<html lang="en">and a unique<title>on every page. Without it a screen reader reads Polish text with English pronunciation. (WCAG 3.1.1, 2.4.2)Headings as structure
One
h1, thenh2,h3without skipping. Headings are the table of contents for someone who cannot see the layout. (1.3.1, 2.4.6)Alternative text
Every image that carries content has an
altdescribing what it conveys; a decorative one hasalt="". Logo: the company name, not "logo". (1.1.1)Contrast 4.5:1
Text to background at least 4.5:1 (large text 3:1). Grey on white in most templates does not meet it. (1.4.3)
Keyboard
Everything can be operated with Tab and Enter; you can see where the focus is. A drop‑down menu that works only on hover is a trap. (2.1.1, 2.4.7)
Links that say something
Not "click here" but "download the price list (PDF, 200 KB)". A screen reader can list the links on their own. (2.4.4)
Forms with labels
Every field has a
<label for>; a placeholder is not a label. Errors described in text, not by colour alone. (1.3.1, 3.3.1, 3.3.2)Zoom and phone
The site works at 200 % zoom and 320 px width without horizontal scrolling. (1.4.4, 1.4.10)
No traps
Nothing flashes, nothing plays sound by itself, nothing closes by itself after a timeout. Video has captions. (1.2.2, 1.4.2, 2.2.2, 2.3.1)
Contact and accessibility information
Even outside the act: a short "Accessibility" page with what works, what does not, and an address for reports. Ours is a template.
Typical templates and systems
Most company websites in Poland run on WordPress, Wix, Squarespace, Webflow or Shopify. None of them is "accessible out of the box" — accessibility depends on the theme, plugins and the content you type in. Overlay plugins ("accessibility overlays") that promise compliance with one script do not fix the code, and organisations of blind people publicly ask that they not be used: they often make screen readers work worse. Our checker measures the page as the user sees it, so an overlay does not improve the score.
Not sure which side of the line you are on? Run the check — the report marks whether e‑commerce signals were detected (basket, payment, account) and shows what needs fixing regardless of the answer. Check a site
