The European Accessibility Act: what e-commerce stores need to know
The European Accessibility Act (EAA) set a compliance deadline of June 28, 2025. That date has passed. If your store sells to customers in the EU, the law has applied to you for about a year now. This post covers what the EAA actually requires, who it applies to, and what the technical standard means in practice for a typical e-commerce site.
We are not lawyers and this is not legal advice. What we can offer is an accurate description of the technical requirements, since those are the part we work with directly.
What the EAA is
The European Accessibility Act is Directive 2019/882. Its stated goal is to harmonize accessibility requirements across EU member states so that disabled people can use the same products and services across borders, and so that businesses do not have to comply with 27 different national accessibility rules.
Each EU member state was required to transpose the Directive into national law by June 28, 2022, then give businesses three years to comply. The June 28, 2025 compliance deadline followed that schedule. From that date, the accessibility requirements are enforceable under each country's implementing legislation, with national enforcement bodies designated to handle complaints and investigations.
What it covers
The Directive applies to both products (hardware, software, payment terminals, self-service kiosks) and services. The service category most relevant to e-commerce is "consumer e-commerce services," which means online retail: any service that lets consumers place orders, pay, and receive confirmation over a digital channel. That covers direct-to-consumer Shopify stores, WooCommerce stores, and custom platforms alike.
The requirement is that the e-commerce service itself must be accessible. That means the product browsing experience, the cart, the checkout flow, and the order confirmation. If a screen reader user cannot complete a purchase on your site because form fields have no labels and buttons have no names, that is a compliance gap under the EAA, not just a US ADA concern.
Does it apply to US-based sellers?
Yes, if you sell to EU consumers. The EAA applies based on where customers are, not where the business is registered. A Shopify store based in California that ships to Germany and France is offering a consumer e-commerce service in Germany and France. It falls under the scope of both countries' implementing laws.
The practical question is enforcement reach. National enforcement bodies in EU member states primarily monitor businesses operating in their jurisdiction, and cross-border enforcement against a US entity that has no EU presence is harder than action against a local business. But "harder to enforce" is not the same as "does not apply," and that balance shifts as enforcement infrastructure matures.
Separate from enforcement, the EAA creates an independent reason to address the same issues your US accessibility posture already points to. The standards overlap: WCAG 2.1 AA on both sides of the Atlantic.
Microenterprise exemption
The EAA includes a partial exemption for microenterprises, defined as businesses with fewer than 10 employees and annual turnover or total balance sheet not exceeding two million euros. For those businesses, the service-level requirements do not apply.
The exemption has limits worth noting. It applies to services, not to physical products. If a microenterprise sells a hardware product covered by the EAA, the product requirements still apply. And the exemption is based on the operator's size, not the scale of EU sales, so a larger business cannot claim it based on low EU revenue.
Most e-commerce stores pursuing significant international sales are not microenterprises in the EAA sense. If you are genuinely below the threshold, the service requirements do not apply, though the underlying accessibility work often makes business sense anyway.
What the technical standard requires
The EAA mandates compliance with EN 301 549, the European standard for ICT accessibility. For web content specifically, EN 301 549 references WCAG 2.1 Level AA. That is the same standard that US federal agencies must meet under Section 508, and the standard most courts have pointed to in ADA web cases.
At the level of what this means for a product page or checkout flow, WCAG 2.1 AA requires roughly the following for the issues we most commonly see in e-commerce scans:
- Images that convey information need alt text that describes what they show. A product image without alt text is a WCAG 1.1.1 failure.
- Form fields need programmatic labels attached to their inputs. A floating placeholder that disappears when the user types is not a WCAG label. The input needs a visible label element with a matching for/id, or an aria-label attribute. This is WCAG 1.3.1 and 4.1.2.
- Interactive controls (buttons, links) need a name that describes their purpose. A button with no text and no aria-label is invisible to a screen reader and fails keyboard navigation for sighted keyboard users. This is WCAG 4.1.2.
- Text must meet a contrast ratio of at least 4.5:1 against its background for normal body text, or 3:1 for large text (18px bold or 24px regular). This is WCAG 1.4.3.
- The site must be navigable by keyboard alone, with visible focus indicators on every interactive element. WCAG 2.1.1 and 2.4.7.
These are not abstract standards. They are the specific failures most commonly cited in accessibility audits and litigation under both the ADA and EAA frameworks, and they are directly testable with automated tools and a few minutes of keyboard navigation.
How the EAA differs from the US ADA
The core technical requirement is similar. Both frameworks point to WCAG 2.1 AA as the practical benchmark for web content. The structural differences are in the enforcement model.
US ADA web cases are primarily driven by private plaintiff litigation. There is no federal agency that routinely audits e-commerce sites. The pressure comes from law firms filing complaints.
The EAA is a regulatory framework. Enforcement is through national bodies that can investigate complaints, conduct audits, and impose penalties under their implementing legislation. The penalties vary by country; each member state sets its own fine structure. The enforcement model is more similar to GDPR than to US civil rights litigation.
In practice, this means the EAA creates a more systematic long-term obligation than the US litigation environment, even though the US litigation environment currently produces more visible short-term consequences for individual businesses.
The service accessibility statement requirement
The EAA includes a requirement that service providers make information available about how their service meets accessibility requirements, including known limitations and contact information for users to report accessibility problems. This is similar to the accessibility statement requirement under the EU Web Accessibility Directive that applies to public sector websites.
For e-commerce sites, this typically means a publicly accessible page that identifies the accessibility standard you are targeting, what has been tested, any known gaps, and how users can contact you if they encounter a barrier.
What to do with this
The practical starting point is the same whether your primary concern is EAA compliance, US ADA exposure, or just having a store that works for all your customers: find out what is broken. The issues that generate enforcement attention under both frameworks are the same ones that block real shoppers from completing purchases.
The five most common failures we see in e-commerce scans are image alt text, unlabeled buttons, unlabeled form fields, color contrast failures, and links with no descriptive text. These account for the majority of findings in both automated scans and manual audits. Fixing them does not require a site rebuild. Most are HTML-level changes a developer can apply in a focused sprint once the findings are documented.
If you want to see where your site stands, our free homepage scan returns the critical and serious issues in about 60 seconds. No account required.