The European Accessibility Act: does it apply to your website or shop, and what to do

The European Accessibility Act is Directive (EU) 2019/882. A directive does not bind companies directly: each EU member state had to pass its own law by 28 June 2022, and those national laws apply from 28 June 2025. In Germany the law is the Barrierefreiheitsstärkungsgesetz (BFSG). In France the technical reference for web accessibility is the RGAA, the national accessibility framework. Poland has passed its own accessibility act for products and services. Wording and authorities differ by country, but the substance comes from the same directive, so the questions below are the same everywhere.

The directive lists the services it covers. For most companies the relevant entry is “e-commerce services”, defined as services provided at a distance, through websites and mobile device-based services, by electronic means and at the individual request of a consumer, with a view to concluding a consumer contract. In plain words: if private customers can buy from you online, the act applies to that shop. The other named services are electronic communications, access to audiovisual media, parts of passenger transport (websites, apps, electronic tickets), consumer banking, and e-books with their reading software.

It does not cover every company website: an informational site with no way to conclude a contract with consumers is not an e-commerce service under the act, although other rules may apply. It also excludes some content: pre-recorded video and office documents published before 28 June 2025, third-party content you neither fund nor control, and archived content no longer updated after that date.

Work through these in order and write down the answers. They are the questions a lawyer or an authority will ask first.

1. Do you sell to consumers? The directive is about services to consumers, meaning natural persons buying outside their trade or profession. A shop that only serves registered business customers is in a different position from one that lets anyone order. Many industrial suppliers run both: a B2B portal and a public shop for spare parts or accessories. The public shop is the one to look at.
2. Are you a microenterprise? The directive defines a microenterprise as an enterprise with fewer than 10 persons employed and an annual turnover not exceeding EUR 2 million or an annual balance sheet total not exceeding EUR 2 million. Microenterprises providing services are exempt from the service requirements and the related compliance obligations. Products are treated differently, so a microenterprise that manufactures covered products should check the product rules separately.
3. Would compliance be a disproportionate burden or a fundamental alteration of the service? The directive applies its requirements only to that extent, but this is not a free pass: the company must assess it against the directive’s criteria, document the assessment, keep it for five years and show it to the authority on request.

The directive does not list colour values or code rules. Annex I asks service providers to make websites, including the related online applications and mobile applications, accessible “in a consistent and adequate way by making them perceivable, operable, understandable and robust”. These are the four principles of the Web Content Accessibility Guidelines (WCAG). The European standard EN 301 549 turns them into testable requirements and, for web content, incorporates WCAG 2.1 at level AA. In practice, “meets WCAG 2.1 AA” is what auditors, authorities and procurement departments across the EU ask for, and it is the reference your developer will work against.

For e-commerce, Annex I adds three points: pass on the accessibility information about the products you sell where the manufacturer provides it; make identification, security and payment functions perceivable, operable, understandable and robust; and offer identification methods, electronic signatures and payment services that meet the same four principles. The checkout, the login and the payment step must work for everyone, not only the product pages.

The directive also asks for information. A service provider must explain, in a form the public can obtain, how the service meets the accessibility requirements, keep that information current for as long as the service is offered, and have procedures that keep the service compliant when it changes. On a website this is usually an accessibility statement: what the site covers, what is known not to work yet, and how to report a problem.

The chart is an illustrative example, not a measurement: the kinds of problems a first audit of a shop typically turns up, with made-up counts for ten pages of a purchase path.

In this example 107 findings fall into seven groups, and the first two make up 69 of them (42 + 27); both are fixed in content and in the theme’s colour settings rather than in code. The keyboard and form problems are fewer but more serious, because one unreachable button can make the checkout impossible to complete.

A full audit by a specialist is the thorough route. Before that, a day of structured checking by your own team finds the obvious problems and tells you what size of job you have. Test the pages that lead to a purchase, not the home page alone.

Then fix in this order: blocking problems in the purchase path first (keyboard traps, an unusable payment step, unlabelled forms), then content problems that affect many pages (alternative text, contrast, headings), then the long tail. Put the rules into the way the site is maintained: alt text is written when an image is uploaded, colour combinations are fixed in the design system, and new templates are tested with the keyboard before they go live. A website built with these rules from the start costs little more than one built without them; retrofitting an online shop with a heavily customised theme is where the real cost sits. If you are unsure where your shop stands, tell us what it runs on and we will say what a technical review would cover.