The European Accessibility Act for online stores

The European Accessibility Act (EAA) requires e-commerce services offered to consumers in the European Union to be accessible to people with disabilities, and it has applied since 28 June 2025. If your online store sells to EU consumers and you’re not a microenterprise, your store should be perceivable, operable, understandable and robust, and you need to publish information on how it meets the requirements. In practice, that means working toward WCAG Level AA and documenting what you’ve done.

What is the European Accessibility Act?

The EAA is Directive (EU) 2019/882 on the accessibility requirements for products and services, adopted on 17 April 2019. A directive doesn’t bind businesses directly. Each member state had to write it into national law by 28 June 2022 and apply those laws from 28 June 2025 (Article 31).

According to the European Commission, it covers products and services “that have been identified as being most important for persons with disabilities”, including computers and operating systems, smartphones, ATMs, banking services, e-books, transport services and e-commerce.

Does the EAA apply to my online store?

Probably, if you sell to consumers in the EU. Article 2(2) lists “e-commerce services” among the services in scope, and Article 3 defines them as “services provided at a distance, through websites and mobile device-based services by electronic means”, at the consumer’s request, with a view to concluding a consumer contract. An online store that sells to the public fits that description.

Two more things decide whether you’re covered: where you sell, and how big your business is.

Does it apply if my business is outside the EU?

It can. The directive defines a service provider as “any natural or legal person who provides a service on the Union market or makes offers to provide such a service to consumers in the Union” (Article 3(4)). A store based in the US, the UK or elsewhere that offers its products to EU consumers may fall within that definition. How each country enforces its law against sellers based abroad is a question for that country’s law, so get local advice if the EU is an important market for you.

Is there an exemption for small businesses?

Yes, for the smallest. Article 4(5) says “microenterprises providing services shall be exempt from complying with the accessibility requirements”. The directive defines a microenterprise as “an enterprise which employs fewer than 10 persons and which has an annual turnover not exceeding EUR 2 million or an annual balance sheet total not exceeding EUR 2 million” (Article 3(23)).

So a business with 10 or more staff isn’t a microenterprise, whatever its turnover, and small and medium-sized businesses above the threshold are not exempt. Member states must also provide guidelines and tools to help microenterprises apply the rules (Article 4(6)). Even if you’re exempt, the work is worth doing: people with disabilities shop online too, and many fixes make a store easier for everyone to use.

Are there transition periods?

Article 32 has some, but read them carefully. Member states must provide a transitional period ending on 28 June 2030, during which service providers may keep using products they lawfully used to provide similar services before that date. Service contracts agreed before 28 June 2025 may continue unchanged until they expire, but no longer than five years from that date. Member states may also let self-service terminals stay in use for up to 20 years. How these apply to a website is a matter of interpretation and national law, so don’t rely on them without advice.

What does the EAA require from an online store?

The requirements are in Annex I. For all services, Section III includes “making websites, including the related online applications, and mobile device-based services, including mobile applications, accessible in a consistent and adequate way by making them perceivable, operable, understandable and robust”. Those are the same four principles that WCAG is organized around. Where you offer support services such as a help desk, Section III also asks that they provide information on the accessibility of the service and its compatibility with assistive technologies, “in accessible modes of communication.”

For e-commerce, Section IV adds three requirements:

• Provide the accessibility information about the products and services you sell, when the responsible economic operator (for example, the manufacturer) provides it.
• Make identification, security and payment functions accessible when they’re delivered as part of the service.
• Provide identification methods, electronic signatures and payment services that are perceivable, operable, understandable and robust.

Article 13 then sets out your obligations as a service provider. You design and provide your service to meet the requirements, prepare the information described in Annex V, and keep procedures in place so the service stays conformant as it, and the standards, change. If it doesn’t conform, you take corrective action and inform the competent national authorities in the countries where you provide the service.

What information do I have to publish?

Annex V says you include “the information assessing how the service meets the accessibility requirements” in your general terms and conditions, or an equivalent document. Where applicable, it contains:

• a general description of the service in accessible formats;
• the descriptions and explanations needed to understand how the service works;
• a description of how the service meets the relevant accessibility requirements in Annex I.

Article 13(2) adds that the information must be available to the public “in written and oral format, including in a manner which is accessible to persons with disabilities,” and kept for as long as the service runs.

The directive doesn’t use the phrase “accessibility statement”, but a clear statement page, linked from your terms and conditions, is a practical way to publish this information. Our accessibility statement guide includes a template.

Is there an exception if the changes are too costly?

Article 14 allows a narrow exception where meeting a requirement would fundamentally alter the basic nature of the service or impose a “disproportionate burden”. It isn’t a general opt-out. You assess it against the criteria in Annex VI, document the assessment, renew it at least every five years and inform the relevant market surveillance authorities. Microenterprises don’t have to send that notice.

Which standard should an online store follow?

The directive doesn’t name WCAG. Instead, Article 15 says services that conform to harmonised standards “the references of which have been published in the Official Journal of the European Union” are presumed to meet the accessibility requirements, as far as those standards cover them.

The standard that matters is EN 301 549, “Accessibility requirements for ICT products and services”, published jointly by the European standards bodies ETSI, CEN and CENELEC. Its web chapter maps onto WCAG:

• Version 3.2.1 (2021) treats WCAG 2.1 Level AA as equivalent to meeting its web requirements. It was prepared to support the Web Accessibility Directive, which covers public sector websites. Ireland’s National Disability Authority (NDA) describes it as the version that remains in force until the new one is cited.
• Version 4.1.1, published on 2 September 2026, is the first version written for the EAA. Its foreword says its web, document and software requirements “have all been updated to align with the WCAG 2.2 recommendation”, and its Annex ZB maps it to the EAA’s requirements. It gives a presumption of conformity only once it “is cited in the Official Journal of the European Union under that Directive”. At the time of writing, the NDA expected that citation on 16 December 2026.

For a store owner the practical target is the same either way: work toward WCAG 2.2 Level AA. W3C designed WCAG 2.2 to be backward compatible, and its WCAG overview says “content that conforms to WCAG 2.2 also conforms to WCAG 2.1 and WCAG 2.0.” Our WCAG 2.2 explained guide covers what changed. If your current audit tests against WCAG 2.1 AA, that’s a solid start; just say so honestly in your statement.

Who enforces the EAA, and what are the penalties?

Each member state. Article 29 requires “adequate and effective means” to ensure compliance. They include the right of consumers to take action under national law before the courts or the competent administrative bodies. Public bodies, associations and organizations with a legitimate interest can also take action on behalf of, or in support of, a complainant.

Penalties are national too. Article 30 says they must be “effective, proportionate and dissuasive”, come with effective remedial action, and take into account the extent and seriousness of the non-compliance and the number of persons affected. The directive sets no fine amounts. Treat any single figure you see quoted as a claim about one country’s law, and check it against that law.

What does this mean for a Shopify store?

Shopify runs most of the checkout, and it publishes an accessibility conformance report for Shopify Checkout, dated March 2026, against WCAG 2.2 Levels A and AA. It lists some criteria as only partially supported, so it’s worth reading. Almost everything before checkout is yours: your theme and its settings, your product content, your pages and the apps you install.

A practical checklist:

1. Check whether you’re in scope. Do you sell to consumers in the EU? Are you above the microenterprise thresholds?
2. Audit your storefront against WCAG 2.2 Level AA: home page, collection pages, product pages, cart and any custom pages. Combine an automated audit with keyboard, zoom and screen reader tests.
3. Fix the common failures in your theme and content: alt text, contrast in your color schemes, form labels, heading order, and keyboard access to menus and pop-ups. Our Shopify accessibility checklist goes area by area.
4. Review your apps. Review widgets, chat bubbles, pop-ups and cookie banners are part of your store. Test them with a keyboard and ask each developer how they test accessibility.
5. Show product accessibility information where the manufacturer provides it, for example in the product description.
6. Publish your accessibility information: a statement page that describes your store and how it meets the requirements, linked from your footer and from your terms and conditions.
7. Give people a way to report barriers, and answer them.
8. Re-check after changes. Re-test after a theme update, a redesign or a new app, and keep a dated record of what you tested and fixed.

What won’t this guide answer?

National details. Each country’s transposing law can differ on which authorities enforce it, how complaints work, what the penalties are and how it treats sellers based abroad. If you sell into several EU countries, check the rules in your main markets. And no checklist or tool can tell you your store conforms. Only testing against the standard can do that, and your published information should describe what you actually found.

Related guides

• How to write an accessibility statement
• Shopify store accessibility checklist
• WCAG 2.2 explained

Frequently asked questions

When did the European Accessibility Act start to apply?

The national laws that transpose the European Accessibility Act, Directive (EU) 2019/882, apply from 28 June 2025. Member states had to adopt and publish those laws by 28 June 2022.

Does the European Accessibility Act apply to small online stores?

Microenterprises that provide services are exempt from its accessibility requirements. The directive defines a microenterprise as an enterprise with fewer than 10 employees and an annual turnover or annual balance sheet total not exceeding EUR 2 million. Businesses above that size are not exempt.

Does the European Accessibility Act apply to stores based outside the EU?

It can. The directive's definition of a service provider includes anyone who makes offers to provide a service to consumers in the EU. If you sell to EU consumers, check how the national law applies to you in the countries you sell to.

Which WCAG version does the European Accessibility Act use?

The directive doesn't name WCAG. The European standard EN 301 549 links the two. Version 3.2.1 is built on WCAG 2.1 Level AA. Version 4.1.1, published on 2 September 2026 for the EAA, moves to WCAG 2.2 Level AA and gives a presumption of conformity once it is cited in the Official Journal. Aiming for WCAG 2.2 Level AA covers both.

What are the penalties under the European Accessibility Act?

Each EU member state sets its own penalties. The directive only requires them to be effective, proportionate and dissuasive, and to take into account how serious the non-compliance is and how many people are affected. It sets no fine amounts.

Sources

• Directive (EU) 2019/882 on the accessibility requirements for products and services (EUR-Lex)
• European Commission: European Accessibility Act (EAA)
• ETSI EN 301 549 V4.1.1 (2026-09): Accessibility requirements for ICT products and services
• ETSI EN 301 549 V3.2.1 (2021-03): Accessibility requirements for ICT products and services
• National Disability Authority (Ireland): Updated EN 301 549 standard published
• W3C WAI: WCAG 2 Overview
• Web Content Accessibility Guidelines (WCAG) 2.2
• Shopify Accessibility Conformance Report: Shopify Checkout
• European Disability Forum and IAAP: joint statement on accessibility overlays (May 2023)