Probably yes, if you sell tickets to consumers on a website or in an app and you are not a microenterprise. For event tickets the hook is the Directive’s e-commerce services category; for tickets sold as part of air, bus, rail or waterborne passenger transport it is a separate list of transport elements.
This guide is for owners and product leads of ticketing and event booking businesses. It follows Directive (EU) 2019/882 (the European Accessibility Act, EAA) and, for Germany, the Barrierefreiheitsstärkungsgesetz (BFSG).
Does the EAA apply to ticketing and event booking websites?
It applies if you offer services to consumers at a distance through a website or an app, because Art. 2(2)(f) lists e-commerce services. Art. 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”.
A shop where a consumer picks a concert, a match or a festival and buys a ticket fits that definition. The Directive has applied to services provided to consumers since 28 June 2025 (Art. 2(2)). In Germany the same hook is § 1 Abs. 3 Nr. 5 BFSG, with the definition in § 2 Nr. 26 BFSG.
Is ticketing for passenger transport treated differently from event ticketing?
Yes. Ticketing that is part of air, bus, rail or waterborne passenger transport has its own provision, Art. 2(2)(c), which names websites, mobile services, “electronic tickets and electronic ticketing services” and transport information. Event ticketing has no such list and is covered as an e-commerce service under Art. 2(2)(f).
| Case | Provision (Directive) | Provision (BFSG) |
|---|---|---|
| Online ticket sales by an air, bus, rail or waterborne passenger transport operator | Art. 2(2)(c)(i) to (iv); definitions in Art. 3(43) and (44) | § 1 Abs. 3 Nr. 2 Buchst. a bis d |
| Urban, suburban or regional transport: ticket sold on a website or app | Art. 2(2)(c) lists only terminals (point (v)) for these services; a website that sells tickets to consumers may be an e-commerce service under Art. 2(2)(f), see recital 35 | § 1 Abs. 3 Nr. 2 (only Buchst. e), possibly Nr. 5 |
| Concert, theatre, sport, festival or museum tickets sold to consumers online | Art. 2(2)(f), Art. 3(30) | § 1 Abs. 3 Nr. 5, § 2 Nr. 26 |
| Booking or resale platform selling tickets to consumers | At least Art. 2(2)(f). Whether Art. 2(2)(c) also applies depends on whether you provide the transport service; ask a lawyer | At least § 1 Abs. 3 Nr. 5 |
| Tickets sold only in person, or only to businesses | Not an e-commerce service as defined (Art. 3(30)); the services in Art. 2(2) are those provided to consumers | Not described by § 1 Abs. 3 on its face; for a mixed consumer and business shop, ask a lawyer |
| Microenterprise providing the service | Exempt, Art. 4(5) | Exempt, § 3 Abs. 3 BFSG |
Ticketing machines are a product, not a service: Art. 2(1)(b)(ii) names them and § 1 Abs. 2 Nr. 2 BFSG covers ticket machines. The product duties sit with the manufacturer, importer and distributor (Art. 7, 9 and 10). A transport operator that uses an interactive self-service terminal to provide its service also has it as an element of that service (Art. 2(2)(c)(v)). The microenterprise exemption does not apply to products.
Which digital surfaces of a ticketing business count?
Every website or app step a consumer uses to find an event, choose a ticket and conclude the contract is part of the service. The Directive does not list seat selection or e-ticket delivery as separate items for event tickets, so treat them as steps of the same flow.
- Ticket shop and event pages. Search, filters, dates and prices. Annex I Section IV(g)(i) asks for the accessibility information on the products and services sold, where the responsible economic operator provides it.
- Seat selection. A seat map is a step inside the sale. If a person cannot choose a seat with a keyboard or a screen reader, the sale does not complete.
- Checkout. Annex I Section IV(g)(ii) and (iii) name identification, security, electronic signatures and payment functions, which the Directive requires to be accessible.
- E-ticket delivery. For passenger transport the Directive names electronic tickets and electronic ticketing services (Art. 2(2)(c)(iii), Art. 3(43) and (44)). For event tickets it does not; Art. 2(4)(b) exempts only office file formats published before 28 June 2025, so a ticket PDF issued today is not exempt on that ground. Where the line falls for the delivered file is a question for a lawyer.
- Confirmation and account pages. Order status, changes and refunds are part of the same service.
Art. 2(4)(d) excludes third-party content that is neither funded, developed by nor under the control of the economic operator. An embedded booking widget that you choose and configure needs a case-by-case answer.
Does the microenterprise exemption cover my ticketing business?
It covers you only if you provide services and meet both limits: fewer than 10 persons, and an annual turnover or balance sheet total of EUR 2 million or less. Microenterprises providing services are exempt from the requirements (Art. 4(5), definition in Art. 3(23)); in Germany see § 3 Abs. 3 and § 2 Nr. 17 BFSG.
The exemption is for services only, and it does not exist for products. It is about the enterprise, not the website: a small team that runs a large platform still has to count its staff and its figures. Keep the evidence of those numbers on file.
What should a ticketing business check first?
Check in this order: whether you are in scope, whether you have published the required accessibility information, and whether a person can buy a ticket with a keyboard alone. Art. 13(2) asks service providers for the information in Annex V, made public in written and oral format; in Germany this is § 14 Abs. 1 Nr. 2 BFSG.
- Confirm the country: start with the national act of each country where you offer your service to consumers, not with the language of your site. For a cross-border case, ask a lawyer which acts bind you.
- Tab through search, seat selection, basket and payment without a mouse. WCAG 2.1.1 Keyboard is the test.
- Check any seat-hold countdown against WCAG 2.2.1 Timing Adjustable.
- Check that a seat map does not rely on colour alone (WCAG 1.4.1) and that seats have text names (WCAG 1.1.1).
- Check form labels and error messages at checkout (WCAG 3.3.1, 3.3.2) and the names and roles of custom controls (WCAG 4.1.2).
- Draft the accessibility statement and have it reviewed.
EN 301 549 is the technical yardstick used here; no version is cited in the Official Journal under Directive (EU) 2019/882, so it gives no presumption of conformity under the EAA (Art. 15(1)).
What can automated testing show on a ticket shop, and what can it not?
Automated testing catches roughly 30 to 40 percent of WCAG success criteria, not 30 to 40 percent of a site’s failures. It finds many missing labels, contrast failures and missing names; it cannot judge whether a seat map is usable.
A crawl follows links. It does not pick seats, hold them, or pay, so the steps after seat selection need a person. A grade of 100 means nothing automated was found; it does not mean the shop is accessible.
How does Inkluso help a ticketing business?
Inkluso gives you dated evidence and a draft statement; it does not make a shop accessible. The free scan tests the homepage against WCAG 2.1 AA with axe-core, no signup and no card.
- One-time audit, EUR 149: a crawl of up to 100 pages, every finding mapped to the WCAG criterion, the EN 301 549 clause and the paragraph of the national act you select, a dated PDF, and a keyboard walk (heuristic, outside the grade).
- Accessibility statement: a draft to review before you publish it.
- Monitoring: EUR 49 per month, or EUR 490 per year, for re-scans of up to 100 pages.
We do not claim to find what free tools miss. What you get is the legal mapping, a crawl of up to 100 pages and a report you can act on.
FAQ
Does the European Accessibility Act apply to ticketing websites?
Probably yes, if you sell tickets to consumers online and are not a microenterprise. Event tickets fall under e-commerce services (Art. 2(2)(f) of Directive (EU) 2019/882), and tickets for air, bus, rail and waterborne passenger transport fall under Art. 2(2)(c).
Is a microenterprise ticket seller exempt?
Microenterprises providing services are exempt (Art. 4(5)). A microenterprise has fewer than 10 persons and an annual turnover or balance sheet total of EUR 2 million or less (Art. 3(23)).
Does the EAA cover seat selection and e-ticket delivery?
The Directive does not list seat selection as a separate item. It is a step inside the website or app flow that concludes the sale, so treat it as part of the service. E-ticket delivery is named only for passenger transport (Art. 2(2)(c)(iii)); for event tickets, ask a lawyer how far the service reaches.
Can an automated scan show that my ticket shop meets the EAA?
No. Automated testing catches roughly 30 to 40 percent of WCAG success criteria, and a seat map, a countdown timer or a payment step needs a person to try it.
What does Inkluso offer a ticketing business?
A free scan of the homepage, a one-time audit of up to 100 pages for EUR 149 with a draft accessibility statement, and a dated PDF report. It is orientation and evidence, not a certification.
Sources
- Directive (EU) 2019/882 (European Accessibility Act), EUR-Lex: Art. 2(1)(b), 2(2)(c) and (f), 2(4), 3(23), 3(30), 3(43), 3(44), 4(5), 13(2), 15(1), recital 35, Annex I Section IV(c) and (g): https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019L0882 (accessed 2026-10-20)
- BFSG, § 1 (Zweck und Anwendungsbereich): https://www.gesetze-im-internet.de/bfsg/__1.html (accessed 2026-10-20)
- BFSG, § 2 (Begriffsbestimmungen), Nr. 17 and Nr. 26: https://www.gesetze-im-internet.de/bfsg/__2.html (accessed 2026-10-20)
- BFSG, § 3 (Barrierefreiheit, Verordnungsermächtigung), Abs. 3: https://www.gesetze-im-internet.de/bfsg/__3.html (accessed 2026-10-20)
- BFSG, § 14 (Pflichten des Dienstleistungserbringers): https://www.gesetze-im-internet.de/bfsg/__14.html (accessed 2026-10-20)
- Axe-core® is a trademark of Deque Systems, Inc. in the US and other countries. Inkluso is not affiliated with or endorsed by Deque Systems.
- Axe-core® is a trademark of Deque Systems, Inc. in the US and other countries. Inkluso is not affiliated with or endorsed by Deque Systems.
- Axe-core® is a trademark of Deque Systems, Inc. in the US and other countries. Inkluso is not affiliated with or endorsed by Deque Systems.
- Axe-core® is a trademark of Deque Systems, Inc. in the US and other countries. Inkluso is not affiliated with or endorsed by Deque Systems.
- Axe-core® is a trademark of Deque Systems, Inc. in the US and other countries. Inkluso is not affiliated with or endorsed by Deque Systems.
- Axe-core® is a trademark of Deque Systems, Inc. in the US and other countries. Inkluso is not affiliated with or endorsed by Deque Systems.
- Axe-core® is a trademark of Deque Systems, Inc. in the US and other countries. Inkluso is not affiliated with or endorsed by Deque Systems.
See where your ticket shop stands
The free scan tests the homepage against WCAG 2.1 AA with axe-core and shows the first findings with the matching reference. No signup, no card.
Orientation, not legal advice. An Inkluso report is not a certification. Automated testing catches roughly 30 to 40 percent of WCAG success criteria. The rest needs a human.