The European Accessibility Act is now in force — does it apply to your online store?
Since June 28, 2025, the European Accessibility Act (EAA) — Directive (EU) 2019/882 — has applied to e-commerce services offered to consumers in the EU. Unlike the ADA in the United States, where requirements have largely been shaped by lawsuits, the EAA is explicit: online shops are named in the law itself. Here's who it covers, what it actually requires of your website, and how to find out where your store stands.
1. Who is covered — including sellers outside the EU
The EAA applies to businesses that sell to consumers in the EU, not just businesses located there. If your store ships to EU customers, accepts orders from them, or targets them with pricing in euros or EU delivery options, your e-commerce service is likely in scope — whether the company behind it sits in Berlin, London, Seoul, or Texas. Enforcement against foreign sellers is still an open question in practice, but the legal obligation is written to follow the customer, not the seller.
2. The small-business exemption (read this before panicking)
The EAA exempts microenterprises providing services: businesses with fewer than 10 employees and an annual turnover (or balance-sheet total) not exceeding €2 million. If that's you, your online store may fall outside the EAA's service obligations. Two honest caveats: you must meet both limits, and the exemption doesn't protect you from other laws (like the ADA if you sell to US customers) or from simply losing customers who can't use your site. When in doubt, confirm your status with counsel.
3. What the EAA actually requires of your website
The EAA itself describes functional requirements — perceivable, operable, understandable, robust — and in practice conformity is assessed against the European standard EN 301 549, which for websites points to WCAG 2.1 level AA. That's the same standard cited in US demand letters, and the same short list of failures dominates in the wild:
- Product images with no alt text
- Checkout and signup fields with no labels
- Text and buttons with too little color contrast
- Links and icon buttons with no readable name
- Missing page language and broken heading structure
E-commerce sites also have EAA-specific information duties — like providing accessibility information about the products you sell where applicable — but the website itself is the foundation everything else sits on.
4. What enforcement looks like
Unlike the US model of private lawsuits, the EAA is enforced by national market-surveillance authorities in each EU member state, with penalties set country by country — fines in some member states can reach tens of thousands of euros or more. Consumers and disability organizations can file complaints that trigger investigations. The practical takeaway for a small store: you're less likely to get a surprise lawyer's letter and more likely to get a regulator's notice with a deadline to fix things — which makes knowing your current state ahead of time far cheaper than reacting.
5. The same trap applies: no overlay widget will save you
The "one-click compliance" overlay widgets sold aggressively around every accessibility deadline don't change the underlying code of your site and don't satisfy WCAG conformance. In the US, the FTC fined a leading overlay vendor $1,000,000 over deceptive compliance claims. European regulators assess the actual accessibility of your service, not the presence of a widget. There is no legal shield you can install — in any jurisdiction.
6. A sensible path for a small store
- Check whether you're in scope — do you sell to EU consumers, and are you above the microenterprise thresholds?
- Audit your store against WCAG 2.1 AA — so you know exactly which issues exist, how severe they are, and where they live in your code.
- Fix the real issues — most stores concentrate their failures in a handful of template-level problems a developer can clear quickly.
- Publish an accessibility statement and keep records — a dated audit plus dated fixes shows the good-faith, documented effort regulators ask about.
- Re-check when your site changes — new themes, apps, and products reintroduce old issues.
Find out where your store stands — free
We run a developer-grade scan of your store against WCAG 2.1 A/AA (the standard behind both the EAA and US demand letters) and email you a plain-English summary of what's wrong and how severe it is. No signup, no card.
The full report — every issue, the exact code, step-by-step fixes, and a draft accessibility statement — is a one-time $149 if you want it.
Also worth reading: I got an ADA website accessibility demand letter — what do I do?
This article is general information, not legal advice. Automated testing identifies a subset of accessibility barriers and does not certify conformance with the European Accessibility Act, the ADA, or any other law. Scope, exemptions, and penalties vary by member state — for questions about your specific obligations, consult a qualified attorney.