The European Accessibility Act for e-commerce: what online stores need to know

The European Accessibility Act (EAA, Directive (EU) 2019/882) harmonises accessibility requirements for a list of products and services sold in the EU. E-commerce services are explicitly in scope. Member States had to apply the national rules from 28 June 2025.

This page is general information, not legal advice. Your obligations depend on the national law of each country you sell to and on your specific situation. Check with a qualified adviser.

Who is concerned?

The EAA applies to economic operators providing e-commerce services to consumers in the EU. The directive defines e-commerce services broadly as services provided at a distance, by electronic means, at the individual request of a consumer, with a view to concluding a consumer contract.

Micro-enterprises providing services are exempt: businesses with fewer than 10 employees and an annual turnover or balance sheet total not exceeding €2 million. The exemption applies to services, not to products. Several countries have added guidance on how to apply it — check the national transposition.

What does "accessible" mean for an online store?

Annex I of the directive lists functional requirements. For e-commerce services, the directive highlights in particular:

• providing information about the accessibility of the products and services being sold, when supplied by the manufacturer;
• making identification, security and payment functions perceivable, operable, understandable and robust when they are delivered as part of the service;
• making websites and mobile apps accessible in a consistent and adequate way.

In practice, the harmonised European standard EN 301 549 — which incorporates WCAG success criteria for web content — is the reference most organisations use to demonstrate conformity. WCAG 2.1 level AA is the level referenced by the current version of EN 301 549; many teams already target WCAG 2.2 AA.

Why the checkout matters most

A catalogue that cannot be browsed is a problem; a checkout that cannot be completed is a lost sale and the clearest possible barrier. The Contentsquare Foundation's 2025 e-commerce readiness snapshot audited 250 pages of the 50 most-visited e-commerce sites in France, Germany, Italy, Spain and the UK and reported that 94% had inaccessible checkout journeys and 84% of checkout pages failed to properly label buttons and form fields.

The most frequent checkout barriers we see are:

1. Add-to-cart or checkout controls built with <div> elements that do not work with a keyboard.
2. Cart drawers that open without moving focus and without dialog semantics.
3. Form fields without labels, or with placeholders used as labels.
4. Error messages that appear visually but are not announced or linked to their fields.
5. Missing autocomplete attributes on name, email and address fields.
6. Low colour contrast on prices, promotions and disabled-looking buttons.

Enforcement

Each Member State designates market surveillance authorities. National reports and press coverage since mid-2025 show that authorities in several countries have started to act, from formal notices to consumer complaints procedures. Penalties are set nationally.

A realistic compliance approach

1. Audit the key journeys once with experts (automated tools alone cannot establish conformity).
2. Fix template-level issues first: one component fix often removes dozens of occurrences.
3. Publish an accessibility statement explaining how your service meets the requirements.
4. Monitor continuously so that the next theme update, app install or checkout change does not silently undo the work.
5. Document your efforts: history, reports and fixes over time.

Automated monitoring covers step 4 and supports step 5. It does not replace step 1.