Website accessibility and the European Accessibility Act

Website accessibility means people with visual, hearing, motor or cognitive impairments can use the site, including through screen readers and a keyboard. The European Accessibility Act (EAA) is EU Directive 2019/882, under which certain products and services, including online retail (e-commerce), must meet accessibility requirements. The requirements apply to services provided to consumers after 28 June 2025.

This is not legal advice: below is what the sources say, with links. National laws of EU countries differ, so you need a lawyer for sales to a specific country.

Who it applies to

• E-commerce services. The directive defines them as services provided at a distance through websites and mobile apps, at the individual request of a consumer, with a view to concluding a consumer contract. They are named directly in the list of services the directive covers (Directive 2019/882, art. 2, 3).
• Consumers. The directive speaks of services provided to consumers. A store that sells only to businesses (B2B) does not appear to fall under this part, judging by the text, but check with a lawyer.
• Deadlines. EU countries had to adopt national laws by 28 June 2022 and apply them from 28 June 2025 (art. 31). Service contracts concluded before 28 June 2025 may continue unchanged until they expire, but no longer than five years from that date (art. 32).
• Microenterprises. Service providers that are microenterprises are exempt from the accessibility requirements for services (art. 4(5)). A microenterprise has fewer than 10 employees and an annual turnover or balance sheet of no more than 2 million euros (art. 3). The exemption covers services, not goods, and applies only to those who really meet the criteria of Commission Recommendation 2003/361/EC (recital 124). The Irish regulator CCPC, in its guidelines for microenterprises, likewise writes that the requirements do not apply to microenterprises that provide services (CCPC).

What if the store is in Ukraine

The text of the directive has no separate rule for providers outside the EU. The CCPC guidelines say the law applies to any business that wants to provide the relevant products and services in the EU, "regardless of where that business is located"; the guidelines do not separately address microenterprises from outside the EU that sell to consumers in Ireland (CCPC). There is no official clarification from the European Commission specifically about Ukrainian stores, so:

• a store that sells only in Ukraine is not covered by the EAA (it is EU law);
• a store that actively sells to consumers in the EU should check the national law of the country it sells to, and whether it falls under the microenterprise exemption.

What exactly an online store must do

Annex I of the directive requires for e-commerce, among other things:

• that websites and mobile apps are made accessible in a consistent and adequate way: perceivable, operable, understandable and robust;
• that information on the accessibility of the goods and services sold is provided, when it is supplied by the responsible party;
• that identification, security and payment functions (login, checkout, payment) are equally accessible (Directive 2019/882, annex I, section IV).

The directive does not list technical checks; these requirements are tied to standards.

Standards: WCAG and EN 301 549

• WCAG 2.2 is a W3C recommendation dated 12 December 2024. Conformance levels: A, AA, AAA; principles: perceivable, operable, understandable, robust (W3C).
• EN 301 549 is the European ICT accessibility standard. Version 3.2.1 (March 2021) is based on WCAG 2.1 (ETSI).
• According to a legal review, version 4.1.1 was published on 2 September 2026, updates the requirements to WCAG 2.2 levels A and AA, and is meant to give a presumption of conformity with the EAA requirements. That effect arises only after citation in the Official Journal of the EU, and the review reports no such citation (Davis Wright Tremaine, September 2026). Check the current status in the Official Journal.

The practical line: the law does not say "do AA", but WCAG AA is the common benchmark in the standards it refers to. This is my interpretation, not a conclusion of the directive.

What to check on a store's site

By the four WCAG principles:

• Perceivable: alt text for product images, text contrast, captions in video.
• Operable: the whole path from catalog to payment can be completed with a keyboard; it is visible where the focus is.
• Understandable: labels on form fields, clear error messages, see usability and mobile UX.
• Robust: works with screen readers; filters, search, cart, payment widgets.

Fines

The directive names no amounts: EU countries set the penalties themselves, which must be effective, proportionate and dissuasive, taking into account the gravity of the violation and the number of people affected (art. 30). Amounts for specific countries are set by national law.

Common mistakes

• thinking the directive is only about large retail: it covers e-commerce services in general, with an exemption for microenterprises;
• fixing only the homepage and leaving checkout inaccessible;
• trusting an overlay widget without checking how it really works with a keyboard and a screen reader (this is practical advice);
• not knowing which EU country concerns you most.

FAQ

What is the European Accessibility Act? EU Directive 2019/882 on accessibility requirements for certain products and services, including e-commerce, in force for services after 28 June 2025.

Does the EAA apply to online stores? Yes, e-commerce is named directly in the list of services, but there is an exemption for microenterprises.

Who is a microenterprise under the EAA? Fewer than 10 employees and turnover or balance sheet up to 2 million euros.

Does the EAA apply to a Ukrainian store? If you sell to consumers in the EU, it is worth checking: under the Irish regulator's guidelines, the law applies regardless of where the business is located. If you sell only in Ukraine, no.

Which conformance is needed: WCAG 2.1 or 2.2? The current EN 301 549 (3.2.1) is based on WCAG 2.1, the new 4.1.1 on WCAG 2.2, but the presumption of conformity depends on its citation in the Official Journal.

Related terms

• Usability
• The mobile version of a store
• Checkout
• Heuristic evaluation (expert review)

Sources

• Directive (EU) 2019/882 (European Accessibility Act), art. 2, 3, 4, 30, 31, 32, annex I — eur-lex.europa.eu/eli/dir/2019/882/oj
• CCPC (Ireland), EAA guidelines for microenterprises — ccpc.ie/business/enforcement/accessibility/european-accessibility-act-guidelines-for-microenterprises
• European Commission, European Accessibility Act (overview) — commission.europa.eu/strategy-and-policy/policies/justice-and-fundamental-rights/disability/union-equality-strategy-rights-persons-disabilities-2021-2030/european-accessibility-act_en
• W3C, WCAG 2.2 — w3.org/TR/WCAG22
• ETSI, EN 301 549 V3.2.1 (2021-03) — etsi.org/deliver/etsi_en/301500_301599/301549/03.02.01_60/en_301549v030201p.pdf
• Davis Wright Tremaine, European Accessibility Act ICT standards update (09.2026) — dwt.com/insights/2026/09/european-accessibility-act-ict-standards-update