The European Accessibility Act and online stores: what applies since June 2025

Since 28 June 2025 the EAA covers online stores selling to EU consumers. Who is in scope, the micro-enterprise exemption, EN 301 549, WCAG and required info.

FixReports editorial team10 min read

Since 28 June 2025, the European Accessibility Act (Directive (EU) 2019/882) has applied to e-commerce services provided to consumers in the EU, which covers most online stores that sell to EU shoppers. In-scope stores must make their website and apps accessible, pass on product accessibility information that suppliers provide, keep login and payment functions accessible, and publish information explaining how the service meets the requirements. Micro-enterprises that provide services are exempt. Each member state enforces the rules through its own national law, so authorities and penalties differ by country.

Key points

  • E-commerce services are listed in Article 2(2)(f) of the directive, and the rules apply to services provided to consumers after 28 June 2025 (Directive (EU) 2019/882 (opens in a new tab)).
  • Micro-enterprises providing services (fewer than 10 employees, and annual turnover or balance sheet total of EUR 2 million or less) are exempt from the service requirements (Articles 3(23) and 4(5)).
  • EN 301 549 V4.1.1, adopted on 24 August 2026, was written to support the EAA and aligns its web clause with WCAG 2.2 (ETSI (opens in a new tab)).
  • Service providers must put accessibility information in their general terms and conditions or an equivalent document (Article 13(2) and Annex V).
  • Penalties are national: up to EUR 60,000 on indictment in Ireland (opens in a new tab), and fines of up to EUR 100,000 in Germany (opens in a new tab) for offering a non-compliant service.

This is a summary of the directive and two national laws as of 22 October 2026, not legal advice. Check decisions with a lawyer who knows the law of the countries you sell into.

Does the European Accessibility Act apply to online stores?

Yes, if the store sells to consumers in the EU and is not a micro-enterprise.

Article 3(30) of the directive defines e-commerce services as services provided at a distance, through websites and mobile device-based services, at the individual request of a consumer with a view to concluding a consumer contract. Recital 43 says the e-commerce obligations apply to the online sale of any product or service. That covers your storefront, any shopping app, and the path from product page to completed order.

Three limits define the scope:

  • Consumers only. A consumer is a natural person buying for purposes outside their trade, business, craft or profession (Article 3(22)). A store that only sells to businesses is outside the e-commerce rules.
  • Dates. Member states had to adopt their laws by 28 June 2022 and apply them from 28 June 2025 (Article 31).
  • Some content is excluded. Article 2(4) excludes pre-recorded audio and video and office files published before 28 June 2025, archived content not updated after that date, and third-party content that the business neither funds, develops nor controls.

Which online stores are exempt?

Micro-enterprises that provide services are exempt from the service accessibility requirements and the related obligations (Article 4(5)).

A micro-enterprise employs fewer than 10 people and has an annual turnover or an annual balance sheet total not exceeding EUR 2 million (Article 3(23)). Recital 53 says businesses must genuinely meet Commission Recommendation 2003/361/EC and the case law aimed at preventing circumvention, so check how the definition applies if your store is part of a larger group.

Other relief exists, but it comes with paperwork:

ReliefConditionWhat you must doSource
Micro-enterprise exemptionFewer than 10 staff and EUR 2 million or less in turnover or balance sheetNothing under the service rulesArt. 4(5), 3(23)
Fundamental alterationCompliance would change the basic nature of the serviceDocument the assessment, keep it for five years and inform the authorityArt. 14(1)-(3), 14(8)
Disproportionate burdenCosts outweigh benefits under the Annex VI criteriaSame as above, and renew the assessment at least every five yearsArt. 14(2)-(8), Annex VI
Transitional periodServices using products lawfully used before 28 June 2025; contracts agreed before that dateApplies until 28 June 2030 at the latestArt. 32(1)

Outside funding received to improve accessibility rules out a disproportionate burden claim (Article 14(6)). Article 32 refers to products used to provide a service and to existing contracts, so check with counsel before relying on it for a storefront.

How do EN 301 549 and WCAG fit in?

EN 301 549 is the European ICT accessibility standard, and its web clause (clause 9) is built on WCAG.

Under Article 15, a service that conforms to a harmonised standard cited in the Official Journal of the EU is presumed to meet the requirements that standard covers. EN 301 549 V4.1.1 (2026-09) was prepared under the Commission's standardisation request C(2022) 6456 to support the EAA. Its foreword says the presumption applies once the standard is cited in the Official Journal under the directive. As of 22 October 2026 we could not confirm that citation, so check before relying on it. The previous version, V3.2.1 (2021), was prepared for the Web Accessibility Directive covering public sector websites.

For a web store, the relevant parts are:

  • Clause 9 (Web). In V4.1.1, conforming with WCAG 2.2 Level AA is equivalent to conforming with clauses 9.1 to 9.4 plus the conformance requirements in clause 9.6.
  • WCAG 2.2. The W3C Recommendation (opens in a new tab) (current version dated 12 December 2024) is identical to ISO/IEC 40500:2025, according to the standard.
  • The directive itself. Annex I, Section III(c) requires websites and mobile apps to be accessible "in a consistent and adequate way" using the same four principles WCAG is organised around.

WCAG 2.2 Level AA is therefore the practical test target for a store, but the directive also covers things a web standard cannot check, such as accessible service information and support (Annex I, Section III(b) and (d)).

What does the EAA require specifically for e-commerce?

Annex I sets general requirements for all services (Section III) and three extra ones for e-commerce (Section IV(g)).

RequirementWhere it shows up in a storeSource
Accessible website and mobile appTheme, templates, apps that add UIAnnex I, III(c)
Information about how the service works, in accessible formatsShipping, returns and help pagesAnnex I, III(b)
Support services that give accessibility information, where you offer themCustomer service, chat, phoneAnnex I, III(d)
Product accessibility information, when the responsible economic operator provides itProduct pagesAnnex I, IV(g)(i)
Accessible identification, security and payment functionsLogin, account, checkoutAnnex I, IV(g)(ii)
Identification methods, electronic signatures and payment services that meet the same principlesPayment and verification stepsAnnex I, IV(g)(iii)

The product information point is easy to miss: if a manufacturer supplies accessibility information for a product, your listing should pass it on.

What accessibility information must an online store publish?

You must publish information explaining how your service meets the accessibility requirements, in your general terms and conditions or an equivalent document.

Article 13(2) requires service providers to prepare this information under Annex V, make it public in written and oral format in a way that is accessible to persons with disabilities, and keep it for as long as the service runs. Annex V says the information should include, where applicable:

  1. A general description of the service in accessible formats.
  2. The descriptions and explanations needed to understand how the service operates.
  3. A description of how the service meets the relevant Annex I requirements.

Annex V also asks you to show how your delivery process and monitoring keep the service compliant. One practical approach is an accessibility page, linked from the footer and referenced in your terms, that states:

  • the standard you test against (for example WCAG 2.2 Level AA or EN 301 549);
  • how browsing, cart, checkout and payment work with assistive technology;
  • known issues and the alternative way to complete each affected task;
  • how customers can get accessibility help, including a non-written channel;
  • when you last reviewed the site and how often you re-test.

If your service does not comply, Article 13(4) requires corrective action and requires you to inform the competent authorities of the member states where the service is provided.

Who enforces the EAA and what are the penalties?

Each member state designates its own authorities and sets its own penalties, so enforcement varies by country.

Member states must check services, follow up complaints and verify corrective action (Article 23), and let consumers or organisations acting for them take action under national law (Article 29). Penalties must be effective, proportionate and dissuasive, and reflect the seriousness of the non-compliance and the number of people affected (Article 30).

Two national examples, as of 22 October 2026:

CountryNational lawAuthority for e-commerceMaximum penalty
IrelandS.I. No. 636 of 2023 (opens in a new tab)Competition and Consumer Protection CommissionClass A fine or 6 months' imprisonment on summary conviction; up to EUR 60,000 or 18 months on indictment
GermanyBarrierefreiheitsstärkungsgesetz (BFSG § 37 (opens in a new tab))MLBF, a joint authority of the federal states, fully responsible since 26 September 2025 (Bavarian Trade Supervisory Office (opens in a new tab))Fine of up to EUR 100,000 for offering or providing a non-compliant service

Other member states use different authorities and amounts, so check each country you sell into.

Does the EAA apply if your store is based outside the EU?

The directive's definitions do not limit the rules to EU-based businesses.

Article 3(4) defines a service provider as any person who provides a service on the Union market or offers it to consumers in the Union. Obligations are owed to the authorities of the member states where the service is provided (Articles 13(4) and 14(8)). If you deliberately sell to EU consumers from the UK, the US, Turkey or elsewhere, plan as if the rules apply and confirm your position with a lawyer.

What should Shopify and WooCommerce stores check first?

Start with the parts of the store you control, because that is where most fixes will land.

Shopify

Shopify's accessibility statement (opens in a new tab) (last updated 7 July 2025) lists Checkout as tested against WCAG 2.2 A/AA and notes that merchants have complete control over their theme code. That leaves you responsible for:

  1. Theme templates: home, collection, product, cart and search pages.
  2. Apps that add interface elements, such as review widgets, pop-ups and chat.
  3. Content: image alt text, link text, headings and colour contrast.
  4. An accessibility information page linked from the footer and your terms of service.

WooCommerce

WooCommerce says version 10.0 (14 July 2025) is fully conformant with WCAG 2.2 Level AA (opens in a new tab) when used with core WordPress or an accessibility-ready theme. Its tips for store owners (opens in a new tab) suggest an accessibility-ready theme, testing extensions before installing them, and checking that you can search, add to cart and check out without a mouse. Themes, page builders and checkout plugins can undo that baseline, so test the store as customers see it.

A free scan shows which automated checks fail on your pages, and the EAA Readiness Report maps those failures to EN 301 549 clause 9 and drafts the accessibility information described above for your review. Automated checks cannot confirm compliance on their own, so add manual testing with a keyboard and a screen reader.

Frequently asked questions

When did the European Accessibility Act start applying to online stores?

It has applied since 28 June 2025. Member states had to adopt national laws by 28 June 2022 and apply them from 28 June 2025 under Article 31 of Directive (EU) 2019/882.

Is my small online store exempt from the EAA?

It is exempt from the service requirements if it is a micro-enterprise: fewer than 10 employees and an annual turnover or balance sheet total of EUR 2 million or less. Above that size the rules apply, subject to documented fundamental alteration or disproportionate burden assessments.

Which WCAG version does the EAA require?

The directive itself does not name a WCAG version. EN 301 549 V4.1.1, written to support the EAA, aligns its web requirements with WCAG 2.2 Level AA, which makes WCAG 2.2 AA the practical target for an online store.

What is the accessibility information an online store must provide?

It is a description of how your service meets the accessibility requirements, published in your general terms and conditions or an equivalent document. Annex V says it should describe the service in accessible formats, explain how the service operates and describe how each relevant requirement is met.

Does the EAA apply to stores outside the EU?

The directive covers anyone who provides a service on the EU market or offers it to consumers in the EU, and its definitions do not require an EU establishment. Non-EU stores that sell to EU consumers should get legal advice on how the national laws apply to them.

Sources

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