The European Accessibility Act: what online shops and service businesses need to do
Since 28 June 2025, the European Accessibility Act requires online shops and several other digital services sold to consumers in the EU to be accessible to people with disabilities. Here is who is covered, what is required, which standard to follow and how to get started. General information, not legal advice.
Last checked 28 October 2026.
What the EAA is
The European Accessibility Act is Directive (EU) 2019/882. It sets common accessibility requirements for a list of products and services across the EU, so that people with disabilities can use them and businesses face similar rules in every EU country.
As a directive, it works through national law. Each EU country had to adopt its own law by 28 June 2022 and apply it from 28 June 2025. Each country also names its own authorities and sets its own penalties, so the details can differ slightly from country to country.
The products covered include computers and their operating systems, smartphones, e-readers, and self-service terminals such as ATMs, ticket and check-in machines. This page is about the services, which is where most small businesses come in.
Which services are covered
The EAA covers these services when they are provided to consumers:
- E-commerce services: services provided at a distance through websites and mobile apps, at the request of a consumer, with a view to concluding a consumer contract. In practice, this covers online shops that sell to consumers.
- Consumer banking services, such as payment accounts, payment services, consumer credit and electronic money.
- E-books and the software used to read them.
- Electronic communication services, such as phone and messaging services.
- Services that give access to audiovisual media, such as streaming apps and TV guides.
- Parts of air, bus, rail and waterborne passenger transport services, such as websites, apps, e-tickets and travel information.
The EAA is about consumers. If you only sell to other businesses, the e-commerce part generally does not apply to you. If you sell to both, the parts of your website that consumers use are in scope.
Who must comply, including businesses outside the EU
The directive defines a service provider as anyone who provides a service on the EU market or offers to provide it to consumers in the EU. Where the business is based is not the test. A shop in the UK, the US or Australia that offers its products to consumers in EU countries should assume the EAA applies to those sales.
The authorities that enforce the EAA are those of the countries where the service is provided. If you sell to consumers in several EU countries, you may hear from more than one of them.
The microenterprise exemption
A microenterprise has fewer than 10 employees and an annual turnover or annual balance sheet total of no more than €2 million. Microenterprises that provide services are exempt from the service accessibility requirements and the obligations that come with them. The exemption is for services only; microenterprises that make, import or distribute the covered products have lighter duties but are not exempt in the same way.
Check both numbers carefully and look again as you grow. Even if you are exempt in the EU, the rules in the UK, the US and Australia have no such exemption, and an accessible shop is easier for every customer to use.
Disproportionate burden
Businesses that are not microenterprises can rely on an exception only to the extent that meeting a requirement would be a disproportionate burden or would fundamentally change the service. You must assess this against the criteria in the directive, document the assessment, renew it when the service changes, when an authority asks, and at least every five years, and notify the relevant authorities. EU guidance says that a lack of priority, time or knowledge is not a legitimate reason.
What the EAA requires of a website or app
For services, the requirements in Annex I of the directive include making websites and mobile apps accessible in a way that is perceivable, operable, understandable and robust: the four principles of WCAG. For e-commerce services they add three specific points:
- Give the accessibility information about the products you sell when the manufacturer or other responsible business provides it.
- Make the identification, security and payment functions of your service accessible.
- Use identification methods, electronic signatures, security and payment services that are perceivable, operable, understandable and robust.
Service providers must also:
- Prepare information on how the service meets the requirements, following Annex V, and make it available to the public in written and oral form, in an accessible way. It belongs in your general terms and conditions or an equivalent document. Many businesses publish it as an accessibility statement.
- Have procedures that keep the service accessible as it changes.
- Fix problems when the service does not conform, and inform the competent authorities of the countries where the service is provided, with details of the problem and what has been done.
- Give an authority the information it asks for to show that the service conforms, and cooperate with it.
What is not covered
- Pre-recorded video and audio published before 28 June 2025.
- Office files, such as PDF or Word documents, published before 28 June 2025.
- Online maps, as long as essential information for navigation is given in an accessible way.
- Content from third parties that you do not fund, develop or control, such as customer reviews.
- Archived content that is not updated or edited after 28 June 2025.
Contracts for services agreed before 28 June 2025 may continue unchanged until they end, but no longer than five years from that date. Products that a service provider already used before that date may be used until 28 June 2030. None of this delays new or updated web pages.
Which standard to follow: EN 301 549 and WCAG
The EAA describes what must be achieved, not how. Service providers may follow harmonised standards whose references are published in the Official Journal of the EU; following them gives a presumption that you meet the requirements they cover.
The European standard for accessible ICT is EN 301 549. Version 3.2.1 from 2021 uses WCAG 2.1 level AA for web content and is the version most guidance has referred to so far. Version 4.1.1, published on 2 September 2026, is the first written with the EAA in mind and moves web content to WCAG 2.2 level AA. It gives a presumption of conformity once the Commission cites it in the Official Journal, which is expected around the end of 2026.
For new work, aim for WCAG 2.2 level AA. It contains the WCAG 2.1 criteria, except one obsolete criterion that was removed, plus six new ones at levels A and AA, such as larger tap targets and help that is easy to find.
How the EAA is enforced
Each EU country must have procedures to check that services comply, follow up complaints and reports, and check that problems are fixed. Consumers can take action under national law, and public bodies or associations with a legitimate interest can act for them or support them.
Penalties are set by each country. The directive requires them to be effective, proportionate and dissuasive, and to be accompanied by effective action to fix the problem. Amounts and procedures differ between countries, so check the national law where you sell.
What to do now: a practical checklist
- Work out whether you are covered: do you sell to consumers in the EU, and are you a microenterprise?
- Run an automated check of your key pages: home, category, product, search, contact, sign-up and every page of your checkout you can reach.
- Fix critical and serious problems first. Many come from one template, such as your header or product page, so one fix can solve them on every page.
- Test by hand what tools cannot judge: use your shop with the keyboard only, zoom to 200 percent, try a screen reader, and read your image descriptions.
- Check the parts you buy in, such as your payment page, cookie banner, chat and booking widgets. Payment and identification are named in the EAA.
- Publish your accessibility information: a statement linked from every page and from your terms and conditions, with a way for customers to report problems.
- Keep it up: re-check after changes, keep dated reports, and answer accessibility feedback quickly.
How our accessibility checker helps
Our website accessibility checker runs the automated WCAG 2.1 level A and AA tests and the automated WCAG 2.2 test for target size on up to 200 pages per check, sorts the problems by how much they block people and explains each fix in plain words. You can download dated PDF reports and create your accessibility statement from the latest check, naming WCAG 2.1 or 2.2 as your standard. On paid plans your site is re-checked every week or every day, and you get an email when something gets worse.
It does not test what needs a person, it cannot log in or go through your checkout, and it does not give legal advice. Use it to find and fix the common problems quickly, and spend your time and any expert help on the rest.
Questions
Does the EAA apply to my small online shop?
If you sell to consumers in the EU, probably yes, unless your business is a microenterprise: fewer than 10 employees and an annual turnover or balance sheet total of no more than €2 million. Microenterprises are exempt from the requirements for services. Check the national law of the countries you sell to, and remember that other countries’ laws have no such exemption.
My business is in the UK, the US or Australia. Does the EAA apply to me?
It can. The directive covers anyone who offers services to consumers in the EU, wherever the business is based. If you sell to consumers in EU countries, assume your shop must meet the EAA for those customers, unless you qualify as a microenterprise. This is general information; ask a local adviser if you are unsure.
Is WCAG 2.1 AA enough?
For now it matches EN 301 549 version 3.2.1, the version most guidance refers to. The new version 4.1.1 moves to WCAG 2.2 level AA and is expected to be cited in the Official Journal around the end of 2026. WCAG 2.2 adds six criteria at levels A and AA, so it makes sense to aim for 2.2 when you fix things now.
Do I need an accessibility statement?
The EAA does not use that name, but it requires service providers to publish information on how their service meets the accessibility requirements, in their terms and conditions or an equivalent document, in an accessible format. An accessibility statement linked from your footer and your terms is a practical way to do that. See our accessibility statement guide.
What are the penalties?
Each EU country sets its own penalties. The directive only says they must be effective, proportionate and dissuasive, and must come with measures to fix the problem. Authorities consider how serious the problem is and how many people it affects. Amounts and procedures differ, so check the national rules of the countries where you sell.
Sources
- Directive (EU) 2019/882 on the accessibility requirements for products and services (EUR-Lex)
- Directive (EU) 2019/882, full text in HTML (EUR-Lex)
- Services, goods and their digital accessibility (Your Europe, European Union)
- Guidance on legislation (AccessibleEU, European Commission)
- EN 301 549 V4.1.1 published (National Disability Authority, Ireland)
- European Accessibility Act ICT standards update (Davis Wright Tremaine, September 2026)
- Impact of the European Accessibility Act on e-commerce (Taylor Wessing)
- What’s new in WCAG 2.2 (W3C)
General information, not legal advice. Laws and dates change; check the sources or ask an adviser for your situation.