The European Accessibility Act and online shops: what applies and what to fix first

What the Act covers

The European Accessibility Act sets accessibility requirements for certain products and services, including e-commerce services provided to consumers. Member states implemented the Act through national laws, which have applied since 28 June 2025. National authorities are responsible for market surveillance and enforcement.

For online shops, the Act covers the website or app through which consumers buy products or services, including product information, search, account creation, checkout, payment, customer support channels and information about the accessibility of the service.

Who is exempt

Microenterprises providing services, generally businesses with fewer than ten employees and limited annual turnover or balance sheet totals, are exempt from the service requirements. Businesses may also rely on a disproportionate burden or fundamental alteration assessment in limited cases, but this must be documented and justified rather than assumed.

Many businesses outside the EU are also affected if they sell to consumers in the EU. Exemptions and details vary by national implementation, so companies should confirm their position for each market.

Usually in scope

Consumer-facing online shops and e-commerce apps operating in EU markets.

Usually exempt

Microenterprises providing services, subject to national rules.

Case by case

Disproportionate burden or fundamental alteration claims, which must be documented.

The standard behind the requirements

The Act sets functional accessibility requirements rather than prescribing one technical checklist in the law itself. In practice, the harmonised European standard for ICT accessibility, which incorporates the Web Content Accessibility Guidelines at level AA, is the most common reference point for websites and apps.

That means the familiar principles apply: content should be perceivable, operable, understandable and robust. Images need meaningful text alternatives, pages must work with a keyboard, colour contrast must be sufficient, forms need clear labels and error messages, and assistive technologies must be able to interpret the interface.

The shop journeys to fix first

Accessibility work should start with journeys that block purchases. Checkout is the most important: every field needs a visible label, errors must be clearly described and associated with the right field, keyboard users must reach every control and payment widgets must be accessible. A beautiful product page is of little value if a customer cannot complete payment.

Product listing and search are next. Filters, sorting controls, variant selectors and add-to-basket buttons are often custom components with poor keyboard support or unclear labels. Product images need text alternatives that describe relevant information, and important details should not appear only in images.

Account creation, login, cookie consent banners, chat widgets and customer service forms also deserve early attention, because they frequently block access before customers reach the products.

Third-party tools and content workflows

Online shops depend on themes, plugins, payment providers, review widgets, chat tools and marketing popups. Each can introduce accessibility barriers. Businesses remain responsible for the service they provide, so accessibility should be part of supplier selection and contract requirements.

Content workflows matter as much as code. Product teams add new images, descriptions, banners and campaign landing pages every week. Without guidance and checks for alternative text, heading structure, link text and contrast, an accessible launch quickly becomes inaccessible.

Accessibility statements and ongoing monitoring

Businesses in scope must provide information about how their service meets accessibility requirements. A useful statement explains the service’s accessibility status, known limitations, contact options for accessibility problems and how requests are handled. It should reflect reality rather than claim full compliance without evidence.

Automated testing tools find some issues quickly, but many barriers require manual testing with keyboards, screen readers and zoom. A practical programme combines automated checks in development, manual audits of key journeys, user feedback and regular reviews after major changes.

Accessibility improvements also tend to improve conversion, search visibility and usability for everyone. Clear forms, readable product information and reliable navigation benefit all customers, not only people using assistive technologies.

This article is not legal advice. Businesses should confirm their obligations under the national laws of the markets where they sell.

Where this sits in what we do

This article covers one decision inside a wider engagement. The solution page sets out how that engagement runs, what it includes and what it costs to find out.

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