Does the European Accessibility Act apply to my online store?

The European Accessibility Act (EAA) may apply if your business provides an ecommerce service to consumers in the European Union. It expressly includes ecommerce services, and EU countries have applied their national measures since 28 June 2025. But scope is not determined by a website simply being visible in Europe.

You need to consider what service you provide, whether you serve EU consumers, the size of the business, possible exemptions, and the law of the relevant member state. A free automated scan can reveal useful technical issues, but it cannot answer those legal questions for you.

The EAA is Directive (EU) 2019/882 (opens in a new tab). It establishes common accessibility requirements for selected products and services, including consumer banking, ebooks, electronic communications, parts of passenger transport and ecommerce.

The Directive defines an ecommerce service as a service provided at a distance, through websites or mobile-device services, by electronic means and at a consumer’s individual request, with a view to concluding a consumer contract. In ordinary terms, an online store’s buying journey is the relevant service—not every informational website on the internet.

The European Commission’s overview (opens in a new tab) confirms that ecommerce platforms are among the services covered and that the EAA took effect in June 2025.

The EAA is a directive. Each EU country implements and enforces it through national law, so details and procedures can differ.

Your office address is not the only useful test. The Directive is concerned with covered services provided to consumers in the EU. A non-EU seller deliberately offering such a service to EU consumers should not assume that being established elsewhere removes the issue.

At the same time, a site being technically reachable from an EU country does not by itself show that the business is providing an ecommerce service there. Sales territories, delivery options, currencies, languages, marketing and actual customer relationships can all be relevant. Cross-border scope is a point to confirm with an adviser familiar with the member states in which you operate.

The EAA exempts microenterprises that provide covered services from its accessibility requirements and related obligations. EU materials describe a microenterprise as employing fewer than 10 people and having annual turnover or an annual balance-sheet total not exceeding €2 million. The Council of the EU’s EAA summary (opens in a new tab) uses those thresholds.

This is important for small stores, but it should not become a guess based only on headcount. Business relationships and financial thresholds need to be assessed correctly, and national rules should be checked. The exemption concerns microenterprises providing services; the Directive treats microenterprises dealing with covered products differently.

Even where an exemption applies, improving accessibility can still reduce abandoned purchases, support more customers and prevent expensive rework later.

Article 14 says the requirements apply only to the extent that compliance would not fundamentally alter the basic nature of a product or service or impose a disproportionate burden. These are assessed provisions, not general opt-outs.

An economic operator relying on them must carry out an assessment using the Directive’s criteria. Documentation and renewal duties can apply, including reassessment when a service changes or at least every five years for service providers relying on disproportionate burden. The correct response is therefore not “this looks expensive, so we are exempt”.

The EAA’s ecommerce requirements include accessible identification, security and payment functions when delivered as part of the service. They also address accessibility information about products and services when the responsible operator provides it.

For a store owner, the practical scope is wider than the homepage. A customer must be able to understand products, navigate choices, complete forms, identify and correct errors, authenticate, pay and receive confirmation.

• Product images need useful alternatives where the image conveys information.
• Navigation, filters, product options, the cart and checkout need keyboard access.
• Text and controls need sufficient contrast and usable resizing.
• Forms need clear labels, instructions and error messages.
• Status changes and confirmations need to be available to assistive technology.
• Third-party apps and payment components need review as part of the journey.

Use this as a starting conversation with your legal and accessibility advisers, not as a substitute for their assessment.

1. 1Confirm whether you offer an ecommerce service to consumers in one or more EU countries.
2. 2Identify the national laws that implement the EAA in those countries.
3. 3Check the microenterprise definition and any other relevant scope provisions using accurate business data.
4. 4Map the complete customer journey, including third-party services.
5. 5Test representative pages automatically, then test critical tasks manually.
6. 6Record barriers, owners, priorities and target dates rather than treating the scan as a certificate.
7. 7Prepare accurate public information about accessibility and a feedback route.

Start with a high-traffic product or category page. Run a free one-page accessibility scan (opens in a new tab) to find common machine-detectable issues. Then use a keyboard to complete the buying journey and review the cart, authentication and payment steps manually.

AccessPeek is a first-pass tool. The W3C explains (opens in a new tab) that evaluation tools cannot check every accessibility aspect and that human judgement is required. A score cannot establish WCAG conformance or legal compliance.

For national starting points, see the AccessPeek guides for Germany, France and Ireland. Obtain qualified advice for decisions about legal scope, exemptions or enforcement.