The European Accessibility Act (EAA) has applied since 28 June 2025, and most consumer-facing online stores are in scope — including businesses outside the EU that sell to EU customers. If you run an e-commerce site and you are not sure whether the law reaches you or what "compliant" actually means, this guide answers both, then gives you a checklist to act on.
Four common cases. The exemption covers services from very small businesses — not products, and not your domestic disability-law obligations.
What the European Accessibility Act is
The EAA is Directive (EU) 2019/882. It was adopted in 2019, EU member states transposed it into national law by 2022, and its requirements apply from 28 June 2025. Its goal is to make a defined set of products and services accessible to people with disabilities across the EU under one common bar, instead of 27 different national rules.
For the web, the relevant category is e-commerce services — defined broadly as selling goods or services to consumers through a website or app. If your store takes orders from EU consumers, that is an e-commerce service, and the EAA expects its consumer-facing flow to be accessible.
The deadline already passed
Unlike a law that is "coming", the EAA is live. 28 June 2025 was not a soft launch — it is the date from which national authorities can act on non-compliant services. New services had to be accessible from that date; some service contracts signed earlier benefit from a transition period running to 2030, but a typical online store has no grace period to rely on. If you are reading this in 2026, the correct mental model is: the obligation is already in force, and the question is exposure, not preparation time.
Does the EAA apply to your online store?
This is where most articles get it wrong, so here is the accurate version, case by case (the panel above summarises it):
- EU business selling to EU consumers — in scope. The most direct case.
- Non-EU business selling into the EU — also in scope. The EAA follows the consumer, not the company's address. A UK or US store that ships to, or takes orders from, EU consumers is covered for that audience. This is the case most often missed.
- UK business with UK customers only — the EAA does not apply. The UK left the EU and is not bound by the directive. Your obligation comes from the Equality Act 2010 (and, for public-sector bodies, the accessibility regulations). Different legal route, same technical standard in practice (WCAG).
- Microenterprise providing services — there is a real exemption. Enterprises with fewer than 10 people and annual turnover or balance sheet at or below EUR 2 million are exempt from the EAA's service obligations. Note the limits: it is an exemption for services (not products), and it does not remove your obligations under national disability law.
The practical takeaway for a small online retailer outside the EU: if you sell into Europe and you are above the microenterprise threshold, treat yourself as in scope. The cheapest way to know where you stand is to measure — run a free WCAG scan on your storefront and see what a real audit returns before you assume anything.
What "compliant" actually means
The EAA itself does not list pixel-level rules. It points to a harmonised technical standard, EN 301 549, and EN 301 549 in turn incorporates the Web Content Accessibility Guidelines (WCAG) at Level AA. The legal floor referenced by the standard is WCAG 2.1 AA; in practice you should target WCAG 2.2 Level AA, which is a superset and the version most tools and auditors now use. We break down what 2.2 added in every new WCAG 2.2 success criterion explained.
So "EAA compliant" for a website is, concretely, "conforms to WCAG 2.2 Level AA on your consumer-facing flows" — the storefront, product pages, cart, checkout, and account area. That is the same target that a proper accessibility audit measures against, which is convenient: one audit covers both the EAA and most other regimes.
Penalties and enforcement
The EAA does not set one EU-wide fine. Each member state designates its own enforcement authorities and penalty regime, so the consequences depend on the country where the complaint lands. Across member states the pattern is: a national authority can investigate, order remediation, and impose financial penalties, and consumers or representative organisations can lodge complaints. There is no US-style cottage industry of opportunistic lawsuits here — the pressure is regulatory and reputational, and increasingly a procurement filter, since public bodies must require accessibility from suppliers. The practical risk is not a surprise lawsuit; it is a complaint, an order to fix, and lost B2B and public-sector deals while you scramble.
A practical compliance checklist
- Confirm scope. Use the four cases above. If you sell into the EU above the microenterprise threshold, you are in.
- Get a dated baseline. Run an automated WCAG 2.2 scan on your key templates — homepage, a product page, the cart, and checkout. Start with a free scan; it returns the full violation list and severity breakdown with no signup.
- Fix Critical and Serious issues first. Missing form labels, keyboard traps, and colour-contrast failures are the highest-impact and the easiest for an authority to verify. Walk the step-by-step audit workflow on the findings.
- Cover the whole purchase flow. The EAA cares about the consumer journey end to end, not just the homepage. Test checkout and account creation with a keyboard only, then with a screen reader.
- Publish an accessibility statement. EN 301 549 and good practice both expect one: your conformance level, known limitations, and a contact route. Use our statement template and examples.
- Keep dated evidence. Re-scan on a regular cadence and keep the reports. A dated trail of "issue found, fix shipped, re-scan green" is exactly what an authority or a corporate buyer asks for.
- Re-scan after every change. Storefronts drift. If you run Shopify, our Shopify accessibility checklist covers the theme-specific traps; scan again after each theme publish.
The EAA is not a reason to panic, but it is in force and it reaches further than most store owners assume — across the Channel and across the Atlantic. The fastest way to replace guesswork with a number is to measure your storefront today: run a free WCAG 2.2 scan on any URL — full violation list, severity breakdown, no signup. For continuous, dated monitoring across multiple sites, see AccessProof plans.
Originally published on access-proof.com.
