The European Accessibility Act for online stores
The European Accessibility Act has applied since 28 June 2025. An online store that sells to EU consumers is an "e-commerce service" under the Act, whatever it sells.
What the EAA is
The European Accessibility Act is Directive (EU) 2019/882. Each member state enforces it through national law, such as Germany's Barrierefreiheitsstärkungsgesetz (BFSG). It requires a list of products and services to be accessible to people with disabilities, from 28 June 2025.
Is your store in scope
The Act lists e-commerce services: selling goods or services to consumers through a website or app. B2B-only sites are not covered by that category. The Act is built around services offered to consumers in the EU, and enforcement against sellers based outside the EU is up to national authorities.
| Item | Detail |
|---|---|
| Applies from | 28 June 2025 |
| Covers | Online stores and shopping apps selling to EU consumers |
| Microenterprise exemption | Service providers with fewer than 10 people and annual turnover or balance sheet total of no more than €2 million |
| Transition | Service contracts concluded before 28 June 2025 may continue unchanged until 28 June 2030 |
| Technical standard | Conformity with EN 301 549 gives a presumption of conformity; for web content that means WCAG 2.1 AA |
| Penalties | Set by each member state. Germany's BFSG allows fines up to €100,000 and can order a service to stop |
The microenterprise exemption covers services only, not manufacturers of covered products. The 2030 transition covers existing contracts. It is not a grace period for new visitors or new orders.
What compliance means technically
The Act sets functional requirements, such as information that can be perceived and interfaces that can be operated. The harmonised standard EN 301 549 maps them to WCAG success criteria, so meeting WCAG 2.1 AA covers web content. That is the same bar used in US ADA lawsuits, so one round of remediation covers both markets. See the WCAG 2.1 AA checklist.
Annex V also requires service providers to explain how the service meets the accessibility requirements in their general terms and conditions or an equivalent document. Online stores usually publish this as an accessibility statement.
What happens if you do nothing
Market surveillance authorities in each member state enforce the EAA, and consumers can complain. Fines vary by country; Germany's BFSG goes up to €100,000. German retailers also worry about warning letters (Abmahnungen) sent by competitors' lawyers, which are quick and cheap to send.
EAA compliance checklist
- Check whether the microenterprise exemption applies: headcount, turnover, consumer-facing
- Test home, collection, product, cart and checkout pages against WCAG 2.1 AA
- Fix alt text, button and form names, keyboard access, pop-ups and contrast
- Check every EU language version and declare the page language correctly
- Publish an accessibility statement and a feedback channel
- Keep test reports and remediation logs, and retest after launches and redesigns
Questions
We only sell to the US. Does the EAA matter?
A site that does not sell to EU consumers is outside the EAA. US ADA cases use WCAG 2.1 AA too, so the technical work is largely the same.
Can we use the 2030 transition to delay?
The transition covers service contracts concluded before 28 June 2025. It does not cover new visitors or new orders, so it is not a grace period for the whole store.
Where can I follow EAA updates?
The directive is on EUR-Lex. National rules and enforcement notices come from each member state, for example Germany's BFSG. We update this page when something important changes.
Does fixing for the ADA also cover the EAA?
Technically, yes. Both point to WCAG 2.1 AA. The differences are mainly in disclosure and enforcement.
Sources
- EUR-Lex: Directive (EU) 2019/882 (European Accessibility Act)
- e-include: The European Accessibility Act, who it applies to and what it asks for
- t3n: Barrierefreiheitsstärkungsgesetz, Bußgelder im E-Commerce vermeiden
- W3C: Web Content Accessibility Guidelines (WCAG) 2.1
This article summarises technical requirements and public data. It is not legal advice; for legal obligations and lawsuits, consult a qualified attorney.