EAA Compliance for E-Commerce: What Online Stores Must Do in 2026

Updated 2026-08-255 min readCopy link

The European Accessibility Act is now in force across the EU. If you sell products or services online to EU customers, it almost certainly applies to your store — regardless of where you are based. Here is what the law requires, what enforcement looks like, and a practical checklist.

Does the EAA apply to my online store?

The European Accessibility Act (Directive (EU) 2019/882) has applied since June 28, 2025. It covers "e-commerce services" explicitly — meaning any service that lets consumers conclude contracts online. That includes:

• Webshops of every size — there is no small-business exemption for e-commerce (unlike microenterprises providing other services)
• SaaS checkout flows and subscription sign-ups
• Booking systems — travel, tickets, appointments
• Banking and payment services offered to consumers

You do not need to be based in the EU. If you offer products or services to consumers in EU member states, the EAA reaches you — similar to how GDPR works.

Who is exempt?

The exemptions are narrow:

• Microenterprises (fewer than 10 employees AND under €2 million turnover) are exempt — but only for services other than e-commerce. If you run an online store, read the fine print with national authorities: several member states interpret the microenterprise exemption differently for e-commerce.
• Pre-existing self-service terminals and legacy content have transition periods that largely expired in mid-2025.
• Disproportionate burden defence exists but requires documented assessment — "we didn't know" is not one.

What does the law actually require?

The EAA requires e-commerce services to be "perceivable, operable, understandable and robust" — the four POUR principles from WCAG. In practice, member states reference EN 301 549, which incorporates WCAG 2.1 Level AA as its web benchmark. Concretely, that means things like:

What happens if you don't comply?

Enforcement is national, so penalties vary by member state — but the direction is consistent:

• Fines range from roughly €4,000 (some member states' lower tiers) up to €100,000+ for continued non-compliance in countries like France and Germany.
• Market surveillance authorities can order corrective action and, ultimately, removal of the service from the market.
• Consumer complaints and disability organisations actively test large webshops and file reports — this is how most cases start.
• In Germany, the BFSG adds Abmahnung (cease-and-desist) exposure through competition law, on top of regulatory fines.

Beyond legal risk: inaccessible stores lose customers outright. The EU's 87 million people with disabilities represent hundreds of billions of euros in annual spending power, and their friends and families buy too.

E-commerce EAA checklist: what to fix first

You cannot retrofit an entire catalogue overnight. Prioritise by risk and effort:

1. Publish an accessibility statement. Lowest effort, highest visibility. Link it from your homepage footer. Describe conformance status and provide a feedback channel.
2. Audit your checkout flow end-to-end with the keyboard only. Unplug the mouse. Can you complete a purchase? Every unreachable step is both an EAA problem and abandoned revenue.
3. Add alt text to product images. Start with best-sellers and category pages.
4. Fix form labels and error messages. Every input needs a programmatic label; errors must be announced to screen readers.
5. Check colour contrast on buttons, links, and text over images — especially sale badges and CTAs.
6. Ensure focus visibility. Remove any CSS that hides the focus outline without replacing it.
7. Test with a screen reader (NVDA on Windows, VoiceOver on Mac) on your top three pages.
8. Set up ongoing monitoring. Accessibility regresses with every theme update and new app/plugin. Daily scanning catches regressions before customers do.

Platform-specific notes

The EAA applies identically regardless of platform — Shopify, WooCommerce, Magento, Wix, custom builds all fall under it:

• Shopify: themes vary widely in accessibility quality. Apps injecting widgets (chat, upsells) are the most common source of keyboard traps.
• WooCommerce/WordPress: plugin output is the usual offender — audit anything that renders forms or modals.
• Custom builds: you own everything, which is good news — nothing stands between you and the fix.

FAQ

Does the EAA apply to B2B-only shops?

The EAA targets consumer-facing services. A pure B2B store falls outside its scope — though many B2B buyers require supplier accessibility documentation anyway, and public-sector procurement mandates EN 301 549 directly.

I'm outside the EU. Does it still apply?

If you offer goods or services to consumers in the EU, yes. Enforcement against non-EU sellers typically starts with marketplaces and payment providers, but national authorities can and do act directly.

Is WCAG 2.2 required?

The legal benchmark is EN 301 549 / WCAG 2.1 AA today. Some member states signal movement toward WCAG 2.2. Building to 2.2 AA now avoids rework later.

What about my mobile app?

If your app lets consumers conclude contracts, it's covered too — same requirements, adapted to mobile platforms (also defined in EN 301 549).

This guide is general information about technical compliance signals, not legal advice. For binding answers about your specific obligations, consult a lawyer familiar with your member state's transposition law.

Related guides: EAA guide for website owners · NIS2 checklist for SaaS · Shopify GDPR guide