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Does the European Accessibility Act apply to your online store?

Published · 5 min read

Since 28 June 2025, the European Accessibility Act (EAA) has applied to many online stores that sell to consumers in the European Union. If you run a small Shopify or WooCommerce store, you have probably heard about it from an app vendor, a newsletter or a customer. This article explains what the EAA is, who it covers, the exemption for the smallest businesses, and where the Web Content Accessibility Guidelines (WCAG) come in. It is general information to help you ask the right questions, not an answer to whether it applies to you.

What the EAA is

The EAA is Directive (EU) 2019/882 on the accessibility requirements for products and services. A directive does not apply directly: each member state writes it into its own national law. The Directive required member states to apply those national rules from 28 June 2025 (Article 31(2)).

The goal is a common set of accessibility requirements across the EU for a list of products and services, so that people with disabilities can use them and businesses do not face 27 different sets of rules. Online shopping is one of the services on that list.

Who it covers

The Directive applies to "e-commerce services" provided to consumers after 28 June 2025 (Article 2(2)(f)). Article 3(30) defines e-commerce services as services provided at a distance, through websites and mobile apps, at the individual request of a consumer, with a view to concluding a consumer contract. In plain terms: if consumers in the EU can browse your store and buy from it, your store is the kind of service the Directive is about.

Being based outside the EU does not, by itself, take a store out of scope. The Directive defines a "service provider" as anyone who provides a service on the EU market or offers it to consumers in the EU (Article 3(4)). How that is enforced against a business outside the EU is a question for a lawyer in the countries you sell to.

The European Commission's EAA page lists e-commerce among the services covered and links to the national rules.

The microenterprise exemption

The Directive exempts the smallest service providers. Article 4(5) says that microenterprises providing services are exempt from the accessibility requirements and the related obligations.

A microenterprise, under Article 3(23), is a business that:

  • employs fewer than 10 people, and
  • has an annual turnover of no more than €2 million, or an annual balance sheet total of no more than €2 million.

So a store with, say, six people and €1.5 million in yearly sales would usually fall under the exemption for its e-commerce service. A store with 12 people would not, whatever its turnover. How staff and turnover are counted (for example across linked companies) matters, and national law can add detail, so check your own numbers with an adviser.

Even if you are exempt, many of your customers still rely on a keyboard, a screen reader or zoom. Fixing the barriers they hit is good for sales, whatever the law requires.

Transitional periods

Article 32 requires member states to provide for a transitional period in their national law. Until 28 June 2030, service providers may keep using products they already used lawfully to provide similar services before 28 June 2025. Service contracts agreed before 28 June 2025 may continue without alteration until they expire, but no longer than five years from that date. These are narrow rules about existing products and contracts, not a general delay for online stores; ask a lawyer how they apply to you.

What "accessible" means in practice

The Directive describes accessibility requirements in general terms (Annex I). In practice, the detailed reference is a European standard, EN 301 549, which builds on WCAG for web content.

  • The version currently cited as the legal reference is EN 301 549 V3.2.1 (2021), which is based on WCAG 2.1 level AA. The European Commission's AccessibleEU centre said in September 2026 that this remains the reference until a newer version is cited in the EU's Official Journal.
  • A new version, EN 301 549 V4.1.1 (2026-09), has been published by ETSI and updates the web requirements to align with WCAG 2.2.

WCAG 2.2 keeps the WCAG 2.1 level A and AA success criteria, except 4.1.1 Parsing, which W3C removed as obsolete, and adds six new ones at levels A and AA, for example about focus not being hidden (2.4.11), target size (2.5.8) and accessible authentication (3.3.8). In practice, testing against WCAG 2.2 AA therefore covers 2.1 AA as well, and prepares you for the newer standard. It does not mean the EAA "requires WCAG 2.2" today.

National rules differ

Because the EAA is a directive, each country has its own law, its own authority that checks it, and its own penalties. The details change over time, so this article does not list them. Start from the Commission page above, check the rules of the countries where most of your customers live, and ask a lawyer about your obligations.

A practical way to start

If the EAA applies to your business, or you simply want fewer customers stuck at checkout, a reasonable order of work is:

  1. Find out where you stand. An automated scan shows many common issues on your key pages in minutes. It does not show everything, and a scan is not an audit: some criteria need a person to check.
  2. Get a person to test what tools can't. A manual audit checks keyboard journeys, screen readers, zoom and forms against every WCAG 2.2 A and AA criterion.
  3. Fix in your theme. Fix the issues in your store's own code, not with a script on top of it, and check the fixes on a preview before they go live.
  4. Keep a dated record. Note what you tested, when, and what you fixed. If the EAA applies to your business, this record of your accessibility work is useful to have.
  5. Keep checking. New apps, products and theme updates bring new issues. Regular scans catch the ones automated tests can find.

Sources

This article is general information, not legal advice. For your obligations, talk to a lawyer.