European Accessibility Act: What Websites and Online Shops Must Do Now

Since 28 June 2025, the European Accessibility Act has required many online shops, booking services, banking apps and other consumer-facing digital services in the EU to be accessible to people with disabilities. If you sell to consumers online in Europe, there is a good chance it affects your website or app.

Accessibility is not only a legal question. An accessible online shop is easier for everyone to use: older customers, people on small phone screens, people in bright sunlight, and anyone using a keyboard or voice control. This guide explains what the European Accessibility Act covers, who is exempt, what "accessible" means in practice, and the steps to take now.

This article is general information, not legal advice.

What is the European Accessibility Act?

The European Accessibility Act (EAA) is Directive (EU) 2019/882, which you can read on EUR-Lex. As a directive, it was transposed into national law by each EU member state, so the exact rules, enforcement bodies and penalties are set at country level. Germany, for example, implemented it through its Barrierefreiheitsstärkungsgesetz (BFSG).

The national measures apply from 28 June 2025. Unlike the earlier Web Accessibility Directive, which covers public sector websites, the EAA focuses on private businesses offering certain products and services to consumers.

Which websites and services are covered?

The EAA covers a defined list of products and services. For websites and apps, the most relevant services are:

• E-commerce services: selling products or services to consumers online, through a website or mobile app.
• Consumer banking services: online banking, payment services, credit agreements and similar.
• Elements of passenger transport services: websites, apps, e-tickets and real-time travel information for air, bus, rail and waterborne transport.
• Electronic communications services and services providing access to audiovisual media.
• E-books and dedicated e-reading software.

It also covers products such as computers, smartphones, e-readers, ATMs, ticketing machines and check-in kiosks.

If your website only presents information about your business, without letting consumers buy or book anything, it may fall outside the e-commerce category. But the line is not always obvious, so check how your national law defines it.

The EAA is about services provided to consumers in the EU market, so it is generally understood to apply to businesses outside the EU that sell to EU consumers too. If you run an online shop from the Middle East or the US and ship to customers in France or Germany, plan as if it applies, and confirm with local advice in your key markets.

Exemptions, transitional periods and disproportionate burden

There is an important exemption for very small service providers. Under the Directive, a microenterprise is a business that employs fewer than 10 people and has an annual turnover or annual balance sheet total not exceeding 2 million euros. Microenterprises that provide services are exempt from the service accessibility requirements.

A few cautions:

• The exemption covers services. Microenterprises that manufacture or sell covered products have lighter obligations but are not fully exempt.
• Your size can change. If you grow past the threshold, the requirements apply.
• Even if you are exempt, customers with disabilities still need to use your shop, and accessibility improvements usually improve conversions for everyone.

The Directive includes some transitional measures. Service contracts agreed before 28 June 2025 can continue unchanged until they expire, but for no longer than five years from that date. Service providers can also continue using products they were lawfully using before that date until 28 June 2030. These are not a general grace period for websites, so do not assume your existing site is covered.

Businesses can also rely on an exception where meeting a requirement would fundamentally alter the service or impose a disproportionate burden. This must be assessed and documented, renewed at least every five years for services, and in some cases notified to the authorities. It is meant for genuine edge cases, not as a way to skip accessibility altogether.

What does "accessible" mean in practice?

The EAA sets out functional requirements: websites and apps must be perceivable, operable, understandable and robust. In practice, the benchmark most businesses use is the European standard EN 301 549, which incorporates WCAG 2.1 Level AA for web content. The harmonised standard for the EAA has been under development, so check the current status. Building to WCAG 2.2 AA is a sensible target for new projects.

Common issues that make online shops inaccessible:

• Images without text alternatives, especially product photos and icon-only buttons.
• Low color contrast between text and background.
• Forms without proper labels, and error messages that are not announced or explained.
• Checkout flows that cannot be completed with a keyboard alone.
• Pop-ups and cookie banners that trap focus or cannot be closed with a keyboard.
• Missing focus indicators, so keyboard users cannot see where they are.
• Videos without captions.
• Text that breaks when users zoom to 200% or increase font size.
• Time limits on carts or sessions with no way to extend them.

Accessibility overlays, the widgets that add a toolbar to your site, do not fix these problems on their own. Real accessibility comes from the underlying code and content.

The accessibility statement

Service providers must publish information on how their service meets the accessibility requirements, in their general terms and conditions or an equivalent document. Many businesses do this through an accessibility statement linked from the footer.

A useful statement includes:

1. Which standard you aim to meet, for example WCAG 2.1 AA.
2. A general description of the service and how it supports accessibility.
3. Known limitations and alternatives, such as phone or email ordering.
4. A contact method for reporting accessibility problems.
5. The date it was last reviewed.

Keep it honest. Claiming full compliance when obvious barriers remain creates more risk, not less.

A practical EAA action plan

1. Confirm whether you are covered: your services, your size, and the countries you sell to.
2. Run an audit: combine automated testing tools with manual checks using a keyboard and a screen reader. Automated tools catch only part of the issues.
3. Fix the critical journeys first: product search, product pages, cart, checkout, account login and contact.
4. Update your design system: colors, focus styles, form components and buttons, so new pages are accessible by default.
5. Train whoever adds content to write alt text, use real headings and caption videos.
6. Check third-party tools such as payment widgets, chat tools and cookie banners. Ask vendors for their accessibility information.
7. Publish your accessibility statement and a way to report problems.
8. Re-test after every major release.

Accessibility also supports search visibility, because clear headings, descriptive links and text alternatives help search engines understand your pages. If you are also optimizing speed, see our guide to Core Web Vitals for European e-commerce. Selling in the US too? Our ADA website accessibility guide covers the American side.

How HEXACODES can help

HEXACODES builds websites and online stores with accessible, semantic code, keyboard-friendly interactions and sensible color contrast from the start, and we can audit and fix existing sites. Because we build custom rather than piling plugins on templates, we can address problems at the source.

If you need a new site, a full business website starting at $30/month can be built with accessibility in mind. For an audit or a remediation plan, contact us.

Frequently asked questions

Does the European Accessibility Act apply to my online shop?

If you sell products or services to consumers in the EU through a website or app, the EAA's e-commerce rules likely apply, unless you qualify as a microenterprise providing services. Each member state has its own implementing law, so check the rules in the countries where you sell. When in doubt, get local legal advice.

Which standard should my website meet for the EAA?

The EAA sets functional requirements rather than naming a single web standard. In practice, EN 301 549, which incorporates WCAG 2.1 Level AA for web content, is the common benchmark. Aiming for WCAG 2.2 AA on new builds keeps you on the safe side.

Can an accessibility widget or overlay make my site compliant?

Not on its own. Overlays cannot reliably fix problems like unlabeled forms, inaccessible checkouts or poor content structure, and some can interfere with assistive technology. Real compliance comes from accessible code, content and testing with real assistive tools.