European Accessibility Act for E-Commerce Websites: What Stores Must Do

Since 28 June 2025, online stores and other consumer-facing digital services sold to people in the EU must meet the accessibility requirements of the European Accessibility Act (EAA), Directive (EU) 2019/882. In practice that means your website, mobile app and checkout must be perceivable, operable, understandable and robust for disabled users, which most businesses demonstrate by meeting WCAG 2.1 or 2.2 Level AA. Microenterprises that provide services (fewer than 10 staff and no more than EUR 2 million annual turnover or balance sheet) are exempt from the service requirements, but almost every other store selling to EU consumers is in scope, including sellers based outside the EU.

This guide explains who the EAA applies to, how the technical standards fit together, what you must publish, how enforcement works, and a remediation plan you can run on a WooCommerce or Shopify store.

This article is general information, not legal advice. National laws implementing the directive differ, so confirm your position with a qualified adviser in the member states you sell to.

What the European Accessibility Act Is

The EAA is an EU directive adopted in 2019 to harmonise accessibility requirements for a defined list of products and services across the single market. Because it is a directive rather than a regulation, each member state had to transpose it into national law. Germany, for example, did so through the Barrierefreiheitsstärkungsgesetz (BFSG). The full text is on EUR-Lex, and the European Commission's EAA page summarises the products and services it covers.

Member states had to apply their national measures from 28 June 2025. That date is the one that matters for websites and apps: services provided to consumers from then on must meet the accessibility requirements, subject to limited transitional arrangements (for example, service contracts agreed before that date can continue unchanged until they expire, but no later than 28 June 2030).

Services covered by the act

The EAA covers specific services, not every website. The ones most relevant to small and mid-size businesses are:

• E-commerce services, defined 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.
• Consumer banking services.
• E-books and the dedicated software used to read them.
• Electronic communications services, access to audiovisual media services, and elements of passenger transport services such as websites, apps, e-ticketing and real-time travel information.

The e-commerce definition is broad. It is not limited to retailers of physical goods: any site where a consumer can conclude a contract online, such as booking and paying for a course, subscribing to a service or buying digital downloads, can fall within it. Purely B2B stores that do not sell to consumers are generally outside the service obligations, though mixed B2B/B2C shops should assume they are covered.

Who Is in Scope, and the Microenterprise Exemption

The microenterprise exemption for services

The directive defines a microenterprise as an enterprise that employs fewer than 10 persons and has an annual turnover not exceeding EUR 2 million or an annual balance sheet total not exceeding EUR 2 million. Microenterprises that provide services are exempt from the service accessibility requirements and the related obligations.

Three points are easy to miss:

1. 1Both limbs matter. You need fewer than 10 staff and turnover or balance sheet at or below EUR 2 million. A two-person store turning over EUR 3 million and with a balance sheet above EUR 2 million does not qualify.
2. 2It covers services, not products. A microenterprise that manufactures or imports in-scope products (for example, e-readers) still has product obligations, with lighter documentation rules.
3. 3Growth ends the exemption. If you are scaling, plan for compliance now instead of retrofitting later. Accessibility built into a theme costs far less than a rebuild.

Disproportionate burden and fundamental alteration

Businesses above the microenterprise threshold can claim that a specific requirement would impose a disproportionate burden or fundamentally alter the service. This is a narrow, documented assessment, not a general opt-out. You must record the assessment, review it periodically, and inform the relevant national authority when you rely on it. Cost savings alone are rarely a convincing basis.

Non-EU sellers serving EU consumers

The EAA attaches to services provided to consumers in the EU, not to where the business is incorporated. A UK, US or other non-EU store that actively sells to EU consumers, for instance by shipping to EU addresses, pricing in euros or running EU-targeted campaigns, should treat itself as in scope for those sales. UK businesses should note that the EAA is EU law: it does not apply to UK-only sales, but it does apply to UK stores selling into the EU.

Technical Requirements: EN 301 549 and WCAG

The directive itself sets functional accessibility requirements in Annex I, written in legal language. To turn those into testable criteria, the EU relies on harmonised standards. Meeting a harmonised standard cited in the Official Journal gives a presumption of conformity.

How the standards map to each other

According to AccessibleEU, until the Commission cites EN 301 549 V4.1.1 in the Official Journal, V3.2.1 remains the legal reference. For a store starting remediation today, the practical target is WCAG 2.2 Level AA: it includes everything in WCAG 2.1 AA, so meeting it satisfies the current reference and prepares you for the next one.

WCAG 2.2 additions that affect stores

The W3C's What's New in WCAG 2.2 lists the new criteria. Those most likely to catch an online store at Level A and AA are:

• 2.4.11 Focus Not Obscured (Minimum): sticky headers, cookie banners and chat widgets must not completely hide the element that has keyboard focus.
• 2.5.7 Dragging Movements: price-range sliders and drag-to-reorder interfaces need a single-pointer alternative, such as input fields or buttons.
• 2.5.8 Target Size (Minimum): interactive targets should be at least 24 by 24 CSS pixels or have enough spacing. Quantity steppers, swatches and pagination links often fail.
• 3.2.6 Consistent Help: if you offer help (contact link, chat, phone), keep it in the same relative place across pages.
• 3.3.7 Redundant Entry: do not force customers to retype information they already gave in the same process, such as the shipping address when billing is the same.
• 3.3.8 Accessible Authentication (Minimum): login must not rely on a cognitive test alone. Allow password managers and paste, and avoid puzzle CAPTCHAs without an alternative.

Accessibility Information You Must Publish

The EAA requires service providers to explain how their service meets the accessibility requirements. Under Article 13 and Annex V, this information goes in your general terms and conditions or an equivalent document, and must itself be available in accessible formats. It should include:

• a general description of the service in accessible formats;
• descriptions and explanations needed to understand how the service operates;
• a description of how the service meets the relevant accessibility requirements.

Most stores meet this with a dedicated accessibility statement page linked from the footer and referenced in the terms. A useful statement covers:

1. 1The standard you target (for example, WCAG 2.2 Level AA) and the date of your last assessment.
2. 2How you assessed it: internal review, external audit, or both.
3. 3Known limitations and workarounds, such as a third-party review widget that is not fully accessible, and when you expect a fix.
4. 4Accessibility features customers can rely on, such as keyboard navigation and captions.
5. 5A contact route for accessibility feedback, and the national enforcement body a customer can complain to.

The W3C's accessibility statement guidance and generator is a solid starting template. Keep the statement honest: a claim of full conformance that an auditor can disprove in five minutes creates more risk than a statement listing known issues and a timeline.

Enforcement Varies by Member State

Each member state designates its own market surveillance authorities and sets its own penalties, which the directive requires to be effective, proportionate and dissuasive. That produces real variation:

• Some countries assigned enforcement to existing consumer or equality bodies; others created new units.
• Penalty ranges, complaint routes and the role of consumer associations in bringing actions differ.
• Some national laws give consumers or associations the right to take action in court or before administrative bodies.

For a store selling across the EU, the practical approach is to meet one high standard (WCAG 2.2 AA) everywhere rather than tracking the minimum in each country, then check national specifics only where you have significant sales or an establishment. The AccessibleEU resource centre, run for the Commission, publishes guidance and national information.

A Remediation Plan for WooCommerce and Shopify Stores

Accessibility problems in e-commerce cluster in the same places: the theme, navigation, product media, forms and checkout. Work through them in this order.

Step 1: Audit a representative page set

Test the home page, a category page with filters, a product page with variants, the cart, every checkout step, account login and registration, search results, and the contact form. Use an automated scanner (such as axe DevTools or WAVE) to catch obvious failures, then test manually: automated tools detect only part of WCAG, and cannot judge whether alt text is meaningful or whether the checkout is usable by keyboard.

Step 2: Fix the theme first

Theme-level fixes repair every page at once.

• WooCommerce: check that your theme and page builder output semantic HTML (real headings, lists, buttons and landmarks). Block themes and well-maintained classic themes are usually easier to fix than heavily nested page-builder layouts. Audit plugins that inject front-end markup, such as sliders, popups, mega menus and review widgets.
• Shopify: start from an up-to-date Online Store 2.0 theme and test it before customising. Review every app that adds storefront UI (reviews, upsells, wishlists, chat); each one can introduce inaccessible modals or controls outside your theme code.

Step 3: Keyboard and focus

• Every interactive element (menus, swatches, quantity controls, filters, modals, cart drawers) must work with Tab, Shift+Tab, Enter, Space and arrow keys where expected.
• Focus must be visible. Never remove outlines with outline: none without providing a clear replacement using :focus-visible.
• Modals and slide-out carts must move focus into the dialog, trap it while open, close on Escape, and return focus to the trigger.
• Add a "Skip to content" link and make sure sticky headers do not hide focused elements (2.4.11).

Step 4: Images, alt text and media

• Product images need alt text that describes what matters to a buyer: "Navy linen shirt, front view, button-down collar" rather than "IMG_2041" or the product title repeated on every image.
• Decorative images should have empty alt attributes so screen readers skip them.
• Product videos need captions; video with important visual information may need audio description or a text alternative.
• Size guides and specification tables should be real HTML tables, not images of tables.

Step 5: Colour and contrast

Body text needs a contrast ratio of at least 4.5:1 against its background, and large text 3:1. User interface components and meaningful graphics (input borders, focus indicators, icons) need 3:1. Sale prices shown only in red, out-of-stock variants signalled only by colour, and pale placeholder text used as the only label are frequent failures.

Step 6: Forms and error handling

• Every field needs a visible, programmatically associated label. Placeholders are not labels.
• Mark required fields in text, not only with colour or an asterisk without explanation.
• Errors must be identified in text, next to the field, and announced to screen readers. Tell customers how to fix the problem ("Enter a postcode in the format 10115").
• Use correct autocomplete attributes (name, email, street-address, postal-code, cc-number) so browsers and assistive technologies can fill fields.

Step 7: Checkout and payment

Checkout is where an inaccessible store loses both compliance and revenue. Test the entire flow by keyboard and with a screen reader (NVDA or VoiceOver) including coupon entry, shipping method selection, payment fields, 3-D Secure challenges and the confirmation page. Hosted payment fields and wallets come from your payment provider, so ask the provider for its accessibility conformance information. Avoid session timeouts without warning, and allow customers to extend time. For broader checkout usability, see our checkout optimization guide.

Step 8: Document, publish and maintain

Record what you tested and fixed, publish the accessibility statement, and add accessibility checks to your release process. New apps, theme updates and marketing popups regularly reintroduce problems, so include an accessibility pass in your website maintenance plan and retest after significant changes.

Quick checklist

Choosing a Platform with Accessibility in Mind

Neither WooCommerce nor Shopify is accessible or inaccessible by default: the result depends on the theme, apps and content you add. WooCommerce gives full control over markup, which helps when you need to fix deep issues but also means you own the result. Shopify limits what you can change in checkout, which reduces the scope for breaking it but also means you rely on Shopify and app developers for fixes in areas you cannot edit. If you are still choosing, weigh this alongside cost and SEO in the Shopify vs WooCommerce comparison, and include accessibility acceptance criteria in any build brief, as covered in the WooCommerce store setup checklist.

Accessibility overlays and widgets that promise one-line compliance do not change the underlying code a screen reader or keyboard user depends on. Treat them as, at most, a preference tool, never as your compliance strategy.

Getting Your Store Ready

The EAA turned accessibility from good practice into a legal requirement for most stores selling to EU consumers. The work is manageable when it is approached as a structured audit and fix cycle focused on theme, forms and checkout, followed by an honest accessibility statement and ongoing checks. If you want a WooCommerce or Shopify store audited against WCAG 2.2 AA and remediated without disrupting sales, see our e-commerce solutions or get in touch to scope the work.