Luxury Hotels the EU Accessibility Act: How to Make Your Website Compliant


Luxury hotel websites are no different from any other when it comes to the European Union's (EU) new accessibility rules. Here’s what you need to know now about the EU update and how to turn compliance into a guest-winning advantage.

The European Accessibility Act (EAA) began to apply on 28 June 2025. From that date, any new, consumer-facing digital service in the EU (including hotel websites and booking engines) must be accessible for people with disabilities. Existing websites and contracts get a transitional period to 28 June 2030, but only for services/products already in use before the 2025 cut-off (and some contracts can run up to five years). After that, everything needs to meet the standard.

Let's get the legal, technical stuff out of the way: what “standard” are we talking about? In practice, the EU points hotels to EN 301 549: the harmonised ICT accessibility standard, which, for web content, maps to WCAG 2.1 Level AA (with EU-specific extras). WCAG 2.2 is the new best practice bar and is expected to be incorporated in future EN 301 549 updates, so plan for it now to stay ahead.

Does this really apply to luxury hotels? Yes. If you sell rooms or services online to EU consumers, your e-commerce service is in scope. That includes your brand website and/or app, booking engine, payment flows and any pre-arrival forms or PDFs you publish.

The non-negotiables for your website and booking journey

  • Structure & navigation: Use semantic HTML, logical headings (H1–H3), visible focus states, and “skip to content” links. All interactive elements must be keyboard operable—no mouse required.
  • Visuals & contrast: Meet minimum contrast ratios, avoid text baked into images, and provide descriptive alt text for imagery (especially rooms, amenities, menus, spa). Luxury photography is great; it still needs alt text.
  • Forms that convert for everyone: Labels must be programmatic, errors explained in text, and help offered inline. Date pickers, guest selectors, and add-ons need clear ARIA where appropriate and full keyboard support.
  • Media & PDFs: Provide captions for video, transcripts for audio, and ensure downloadable menus/brochures are accessible (or publish as HTML). Under EU rules, downloadable docs count.
  • Booking engine parity: Many failures hide in third-party widgets—rate calendars, room selectors, upsells, and payments. Bake accessibility requirements into vendor contracts and test with real assistive tech 
  • CAPTCHAs & authentication: Offer accessible alternatives (e.g., non-visual challenges or device attestation). Don’t lock out guests at sign-in.
  • Language & readability: Plain, concise copy helps everyone, including international guests and screen-reader users. Avoid “image-only” menus or spa price lists.

A quick, defensible roadmap (that fits luxury timelines)

Month 1: Audit & risk triage. Run an EN 301 549/WCAG 2.1 AA audit across web + app + booking engine. Prioritise blockers: keyboard traps, non-labelled inputs, contrast fails, and inaccessible date pickers/payment steps. Publish an accessibility statement outlining scope and a fix timeline.

Months 2–3: Remediate the core funnel. Fix nav, forms, media, and error handling. Swap inaccessible widgets; add contractual accessibility clauses with your booking engine and PSP. Retest with assistive tech and users.

Months 4–6: Level up to WCAG 2.2. Address new success criteria like Focus Appearance, Dragging Movements (offer alternatives), and Target Size. This future-proofs you against the next EN 301 549 update.

Ongoing: Governance. Add accessibility checks to every release, train content teams, and schedule quarterly audits. Accessibility is a process, not a project.

Why this matters commercially

Beyond legal exposure, accessible journeys convert better - fewer abandoned bookings, improved SEO and broader reach (ageing travellers, low-vision users on mobile in bright conditions, non-native speakers). Luxury is detail; accessibility is detail at scale.

If you’ve launched or redesigned since 28 June 2025, you must already be accessible; if not, the 2030 clock is ticking for legacy experiences. Start with the booking flow, bring vendors with you and aim for WCAG 2.2 now to stay ahead.

Realistically this is a project for web agencies in conjunction with their hotel partners. Aró Digital is ready for accessibility - contact us to find out more

 Author: Richard Blowes