The European Accessibility Act and online stores: what sellers need to know
Last reviewed October 26, 2026 · 11 min read
Short answer. The European Accessibility Act has applied since 28 June 2025. It covers e-commerce services offered to consumers in the EU, uses EN 301 549 (which references WCAG 2.1 AA) as its technical baseline, and includes limited exemptions for microenterprises providing services. Check the national law where you sell.
What the Act is
The European Accessibility Act is Directive (EU) 2019/882. It sets accessibility requirements for certain products and services, including e-commerce services that let a consumer conclude a contract through a website or app. EU Member States apply the measures from 28 June 2025, so the rules are enforced through each country's national law.
What it asks of an online store
The Act's requirements are met by following harmonised standards. For websites that is EN 301 549, which in its current version (v3.2.1) incorporates WCAG 2.1 Level AA. In practice, that means the same kinds of fixes a US business would make: text alternatives, contrast, keyboard operation, labeled forms, error identification and a checkout that works with assistive technology.
Who is in scope
- Businesses that sell products or services online to consumers in the EU.
- Businesses established outside the EU that offer such services to EU consumers should check with counsel whether their store is in scope under the national law of the countries they serve.
- B2B-only stores are generally outside the consumer e-commerce definition, but only if the shop is clearly structured as business-to-business.
Exemptions
The Directive exempts microenterprises that provide services from the accessibility requirements. A microenterprise is a business with fewer than 10 employees and annual turnover or balance sheet total of no more than 2 million euros. Other limits exist, such as where compliance would require a fundamental change to the service or impose a disproportionate burden, and Member States apply the details. Do not assume an exemption without checking the national law.
Beyond websites: what else the Act covers
The Act is not only about online stores. It sets accessibility requirements for a defined list of products and services, which matters if your business sells more than one kind of thing.
- Services: e-commerce, consumer banking services, passenger transport service websites and apps, electronic communications services, and services that give access to audiovisual media.
- Products: self-service terminals such as payment terminals and ticket machines, e-readers, e-books, computers and operating systems, smartphones, and some consumer devices used for communication.
If you only run a store, the e-commerce provisions are the ones that matter. If you also sell e-books or offer a booking service, other rules may apply.
What a service provider must do
For a store, the Act asks for three kinds of action.
- Design and deliver the service so people with disabilities can use it. In practice, this is the WCAG-based work described in this guide.
- Tell customers about accessibility. The service provider must provide information on how the service meets the requirements, for example in the terms and conditions or a clear statement.
- Fix and report problems. If the service stops meeting the requirements, the provider must take corrective action and may have to inform the national authority.
The Act describes the goals in terms of the four WCAG principles: content and interfaces must be perceivable, operable, understandable and robust. It also calls out supporting steps such as identification, authentication and payment, which for a store means login and checkout must be usable.
Why national laws matter
The Act is a Directive, so each EU country wrote it into its own law. Dates, enforcement bodies, complaint routes and penalties are set nationally and differ. Germany's law, the Barrierefreiheitsstärkungsgesetz (BFSG), is one example; other countries have their own. Before assuming how strict enforcement will be, check the law of each country where you actively sell.
Does it apply to me? A short walk-through
| Question | If yes | If no |
|---|---|---|
| Do you sell to consumers (not only businesses) in the EU? | Continue. | The consumer e-commerce rules are unlikely to apply. B2B-only shops are generally outside them, but only if the shop is clearly B2B. |
| Do you actively target EU buyers (local language, euro pricing, EU shipping)? | You are more likely to be in scope. Ask counsel. | Scope is less clear if you simply ship worldwide on request. Ask counsel. |
| Are you a microenterprise (fewer than 10 staff and turnover or balance sheet up to 2 million euros)? | Providers of services are exempt from the accessibility requirements. Confirm in each country's law. | The requirements apply unless another exception fits. |
| Do you sell only through a marketplace? | The marketplace has its own duties. Your own storefront, if any, is still yours to check. | Your store must meet the requirements itself. |
Mapping the requirement to your store
| Part of your store | What to check | Guide |
|---|---|---|
| Product pages | Alt text, headings, variant selection, price changes announced | Alt text, headings |
| Cart and checkout | Labels, errors, keyboard use, payment buttons | Forms, checkout checklist |
| Account and login | Login that does not depend on a puzzle, working password managers | Forms |
| Look and layout | Contrast, zoom, spacing, focus | Contrast, zoom, focus |
| Information to customers | An accessibility statement and a contact route | Statement guide |
What to publish for customers
Customers and authorities should be able to see what you do. Put a short accessibility statement in the footer. Say which standard you work towards (WCAG 2.1 AA at least, and ideally 2.2 AA), what you have tested, what you know is not yet fixed and how to reach you. Add a sentence on accessibility to your terms and conditions if your national law expects it.
Standards: 2.1 today, 2.2 tomorrow
The current harmonised standard, EN 301 549 v3.2.1, refers to WCAG 2.1 AA for web content. A newer version of the standard that would reference WCAG 2.2 has been in preparation. Aim for 2.2 AA now: it includes everything in 2.1 AA and avoids a second round of work later.
A 90-day plan for a small store
| Days | Focus | Output |
|---|---|---|
| 1 to 15 | Decide your scope: where you sell, who you sell to and whether an exemption may apply. Check the law in the countries involved. | A one-page scope note |
| 16 to 35 | Scan one page from each template and do a keyboard and zoom pass on checkout. List findings. | A dated list of problems |
| 36 to 70 | Fix by impact: checkout first, then product pages, then everything else. Ask apps for their accessibility information. | A change log |
| 71 to 85 | Rescan, retest by keyboard and with a screen reader, and update the list. | A second dated set of results |
| 86 to 90 | Publish the accessibility statement and set a recheck schedule. | A statement and a calendar |
What a store owner should expect from an audit
An audit for the European Accessibility Act is not a special kind of test. It is an accessibility evaluation against the standard the Act points to, with the results written up so that a regulator, a customer or your own team can follow them. A useful audit has five parts.
- Scope. Which countries you sell to, which parts of the service are covered, and which pages and journeys were tested. For a store this nearly always includes the home page, a category page, a product page, search, the cart, checkout, the customer account and the contact page.
- Method. Whether the testers used automated tools, a keyboard, a screen reader and a phone, and which browsers and devices.
- Findings. Each problem listed with the page, the success criterion it relates to, how serious it is and how to fix it.
- Conclusion. An honest summary of what meets the standard, what does not and what was not tested.
- Date and version. Accessibility changes with every release, so a report is only a snapshot.
If you buy an audit, ask to see a sample report first. A report that lists only pass or fail with no pages or dates tells you very little.
Third-party apps and embedded tools
Most online stores are assembled from parts: a platform, a theme, a payment provider, a review widget, a chat window, a cookie banner and a handful of marketing apps. Customers do not see those boundaries. If the review widget cannot be used with a keyboard, the product page it sits on is harder to use.
The service provider, which is you, is generally the party answerable for the service as customers experience it. That makes it worth checking the parts you chose.
- Ask each vendor whether they publish an accessibility conformance report or statement, and read it.
- Test the app on a real page with only the keyboard.
- Prefer providers who answer clearly and name a contact.
- Keep a list of the apps you use, so a replacement can be considered if a vendor does not improve.
Common problems on small European storefronts
The problems below appear again and again on small and mid-sized stores. None is exotic, and most can be fixed by a store owner or a developer in a few hours once they are identified.
| Problem | Why it matters to a customer | Where to read more |
|---|---|---|
| Product images with no description or with a file name as the description | A blind shopper cannot tell products apart | Alt text |
| Size and color pickers built from clickable boxes with no labels | Keyboard and screen reader users cannot choose a variant | Link and button names |
| Cookie banners that trap the keyboard or sit on top of the page | The shopper cannot reach the page behind it | Keyboard focus |
| Checkout errors shown only in red | Color-blind shoppers do not see what went wrong | Form labels and errors |
| Light grey text on white for prices and delivery notes | Low-vision shoppers cannot read the details that decide a purchase | Color contrast |
| Small close buttons on popups and mini carts | Touch users miss them | Target size |
Working with a developer or agency
If someone else builds your store, put accessibility in the brief. Ask which standard they will build to, ask them to include keyboard and screen reader checks in their testing, and agree what they hand over at the end: a short test record and a list of known issues. The agency QA workflow guide describes what a reasonable process looks like from their side.
Practical steps
- Decide whether you sell to consumers in the EU, and in which countries.
- Scan your key pages (home, category, product, cart, checkout, account, contact) and note the findings by WCAG criterion.
- Fix by impact and by template, and recheck.
- Publish an accessibility statement with a working contact route; several Member States expect one. See the accessibility statement guide.
- Ask your platform and app vendors for their accessibility conformance information. For platform specifics see the accessibility on Shopify, WooCommerce and WordPress and Wix guide guides.
Clir maps its findings to WCAG and shows EN 301 549 context alongside criteria in the 2.1 AA baseline. That is informational: it describes how a criterion relates to a framework and does not establish that a store meets the Act.
Common questions
Does the EAA apply to a store based in the United States?
It can, if the store offers services to consumers in the EU. Scope depends on national law and the facts, so ask a qualified attorney.
Is the EAA the same as the ADA?
No. They are separate laws with different scopes and enforcement. They overlap in practice because both are commonly measured against WCAG.
Does the EAA require WCAG 2.2?
Not today. The current harmonised standard refers to WCAG 2.1 AA. Building to 2.2 AA covers it and prepares for later versions.
Do websites need CE marking?
No. CE marking applies to products covered by the Act, not to services such as an online store.
What are the penalties?
They are set by each Member State, so they differ by country. Check the national law where you sell.
Is an accessibility statement required?
The Directive requires service providers to provide information on how the service meets the requirements. A clear accessibility statement is the usual way to do that, and some countries expect it. See the statement guide.
Can a scan tell me whether I meet the EAA?
No. A scan finds the issues automation can detect on the pages tested. Meeting the Act depends on the whole service and on national law, so combine scanning with hand testing and legal advice.
Do I need an EU representative or a local lawyer?
That depends on your business and on national law. If you sell into the EU from outside it, ask a lawyer familiar with the countries you target. This guide is general information and not legal advice.
Does the Act apply to a store that only sells business to business?
The service provisions are about services offered to consumers, so a store that sells only to businesses is generally outside them. If consumers can also buy, assume they apply and confirm with counsel.
What are the European Accessibility Act website requirements?
Services such as online stores must be accessible, which in practice means meeting EN 301 549, referring to WCAG 2.1 Level AA, and publishing information about accessibility. National laws set the details.
Does the European Accessibility Act apply to websites outside the EU?
It can apply if you offer covered services to consumers in the EU. Where you are based is less important than whom you sell to. Ask a lawyer familiar with the countries you target.
How do I run a European Accessibility Act audit or website test?
Scan the main pages, test checkout by keyboard and with a screen reader, map findings to WCAG criteria and record dates. The section above describes what a useful audit contains.
Is there an official European Accessibility Act website?
The European Commission publishes information about the Directive, and EUR-Lex has the legal text. Each Member State also publishes its own law and guidance. See the sources below.
Does the European Accessibility Act apply to Shopify stores?
It can, because it applies to the service you offer and not to the platform. A Shopify store selling to EU consumers should check scope, then test its theme, apps and checkout. See the Shopify guide.
What is the European Accessibility Act 2025 deadline for websites?
The Directive's requirements apply from 28 June 2025, with transitional provisions for some existing services and contracts. Confirm the details in your national law.
This guide is general information, not legal advice. Laws and deadlines change; check the linked sources and ask a qualified attorney about your own situation.
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