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European Accessibility Act for online shops: a practical guide

· 5 min read

The European Accessibility Act (EAA) has applied to online shops that sell to consumers in the EU since 28 June 2025 — unless the shop is run by a micro-enterprise. If it applies to you, you need an accessible website and checkout and a published description of how your service meets the requirements. This guide walks through the decision and the work in the order that makes sense for a busy shop owner.

Step 1: find out whether the EAA applies

Before you spend money on anything, answer three questions.

Do you sell to consumers? If your shop is open to private individuals, the answer is yes. A B2B-only portal where buyers need a trade account is generally outside the service requirements.

Is your service e-commerce? Selling goods or services to consumers online is e-commerce in the sense of the EAA. Banking, e-books, passenger transport and electronic communications are other covered sectors.

Are you a micro-enterprise? This is the question most shop owners get wrong. A micro-enterprise has fewer than 10 employees and an annual turnover or balance sheet total of no more than €2 million. In other words, you are covered if you have 10 or more employees — or if you have fewer but both your turnover and your balance sheet exceed €2 million.

Consider a drop-shipping store with 4 employees, €3 million turnover and a €0.4 million balance sheet. High turnover, but the balance sheet is small and the team is tiny: it is a micro-enterprise and exempt. A furniture shop with 6 employees, €5 million turnover and a €2.5 million balance sheet is not.

If you are unsure, our three-question filter has more examples. If any answer is "no", the EAA does not oblige you — although accessibility still helps older customers, mobile shoppers and your search visibility.

Step 2: understand what "accessible" means for a shop

The EAA describes the goal in functional terms: people with disabilities must be able to perceive, operate and understand your service. The technical yardstick is the European standard EN 301 549, whose web chapter follows the W3C's WCAG. Until the new version is cited in the EU's Official Journal, the harmonised version is V3.2.1 (based on WCAG 2.1 AA). Version 4.1.1, based on WCAG 2.2 AA, was published in September 2026 and is expected to be cited in late 2026. Working towards WCAG 2.2 AA now covers both. More in EN 301 549 V4.1.1 and WCAG 2.2.

For a shop, the requirements show up in a few places again and again:

  • Product pages: images need text alternatives, prices and badges need enough contrast, size and colour selectors must work with a keyboard and be large enough to tap.
  • Navigation and search: menus and filters must be usable without a mouse, and focus must stay visible.
  • Cart and checkout: every field needs a label, errors need a clear text explanation, and payment steps must not trap keyboard users.
  • Pop-ups: cookie banners, newsletter sign-ups and chat widgets are frequent sources of keyboard traps and hidden focus.

Step 3: find your issues

Start with an automated scan of a handful of representative pages: home, a category, a product, the cart and each checkout step. Automated tools are fast and objective, and they reliably find things like missing alt attributes, unlabelled fields, buttons without names and low contrast. By various estimates they find roughly a third to a half of all issues, so they are the start, not the end.

Our free check scans one page; the express report covers up to 20 pages. Either way, it is an automated check, not a full audit, and not legal advice. Then do a short manual round: put the mouse away and try to buy something using only Tab, Shift+Tab, Enter, Space and Escape. You will learn more in ten minutes than from any report.

Step 4: fix in the right order

Not every issue is equally urgent. A practical order:

  1. Anything that blocks a purchase — unlabelled checkout fields, a payment button without a name, a modal you cannot close with the keyboard.
  2. Issues on templates — a fix in the product template fixes thousands of pages at once.
  3. Contrast and focus styles — usually a few lines of theme CSS.
  4. Content — alt texts for products, link texts, headings. Train whoever adds products.

Our reports sort issues by severity and include fixing notes for Shopify, WooCommerce, PrestaShop and Shoptet. The list of the 10 most common e-commerce errors shows what to expect.

Step 5: publish the information on accessibility

Article 13 and Annex V of the EAA require you to publish information on how your service meets the accessibility requirements, in your terms and conditions or an equivalent document. It must describe your service, explain how it works and how it meets the requirements — a scan report alone is not enough. Many shops add a dedicated page linked from the footer. Our accessibility statement guide explains the structure, and our questionnaire produces a draft for your lawyer.

Step 6: keep it accessible

Accessibility is not a one-off project. A theme update, a new payment app or a seasonal banner can break what you fixed. Weekly monitoring catches new issues before customers — or authorities — do.

What about enforcement?

Each EU country has its own authority and fines. Germany allows fines up to €100,000 under the BFSG; Czechia up to CZK 10 million; Poland up to 10 times the average monthly salary, capped at 10% of turnover; Romania 5,000 to 15,000 lei. As of October 2026 we are not aware of confirmed EAA fines against online shops. What is happening are inspections — the Czech ČOI checked 47 online shops in Q2 2026 and found breaches in 10 — plus complaints and court cases. Country details: Germany, Poland, Czechia, Romania.

A word on shortcuts

You will see widgets that promise to make your shop accessible with one line of code. They do not change your theme's code, and in 2025 the US Federal Trade Commission finalised an order against one vendor over such claims. Read why accessibility overlays don't work.

Summary

  1. Check whether the EAA applies — many small shops are exempt.
  2. Aim for WCAG 2.2 AA on your key templates.
  3. Scan, then test the checkout with the keyboard.
  4. Fix blockers first, then templates, styles and content.
  5. Publish your accessibility information.
  6. Monitor after every change.

For the full legal background, read our EAA guide. Ready to see where your shop stands? Run a free check.

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