EAA and national accessibility law: who is affected and what you must do

What the EAA brings

The European Accessibility Act (EAA, Directive 2019/882) requires that products and services on the EU market be accessible to people with disabilities. Your national transposition law has been in force since 28 June 2025. For online stores, the key point is that the law regulates e-commerce services — that is, online sales of goods and services to consumers.

Who the law applies to

The law applies to businesses that provide e-commerce services to consumers (B2C). An exemption exists for microenterprises — companies that meet BOTH conditions simultaneously: fewer than 10 employees AND annual turnover or balance sheet total not exceeding EUR 2 million.

Note: meeting only one condition is not enough. A company with 8 employees and a turnover of EUR 5 million is not a microenterprise — it meets the employee count condition but exceeds the turnover limit. The law applies to it in full.

When the law applies

The national transposition law is in force from 28 June 2025. This applies to both new and existing online stores.

Transitional provisions may apply to contracts concluded before 28 June 2025. However, for the operation of an online store as such — accepting new orders, displaying products, communicating with customers — the law applies from 28 June 2025. We recommend verifying the specific assessment with a lawyer.

What an online store must comply with

The law requires that an online store be accessible. The technical requirements are based on the harmonised standard EN 301 549, which incorporates WCAG 2.1 AA (the international web accessibility standard from W3C). Key areas:

• The entire purchase flow: product search, filtering, product pages, shopping cart, order, payment, user account
• Image alt texts, sufficient colour contrast, keyboard operability, accessible forms

Check your national transposition law for specific requirements regarding accessibility statements or terms-of-service disclosures. Requirements vary by country.

What are the penalties

Violations of the law may result in penalties. The supervisory authority is your national market surveillance body. The level of fines depends on your national legislation and the severity of the infringement.

• Penalties vary by member state — consult your national transposition law for exact figures
• Enforcement practice is still developing, but ignoring the law is not advisable

The actual risk depends on the severity of the violation and your approach to remediation. The law is new and enforcement practice is still developing — however, we do not recommend ignoring it.

How to get started

The first step is to find out what state your online store is in. Automated checks detect approximately 30–50% of WCAG rules — for a complete picture, a manual audit is then necessary. Start with a free automated scan and identify the most serious issues.