What the European Accessibility Act means for a small online shop

Last updated 2026-09-16

What Directive (EU) 2019/882 asks of an online shop, who is exempt, what enforcement has looked like so far, and what to do first. Facts checked 2026-09-13; nothing here is legal advice.

What it is

The European Accessibility Act (EAA) is Directive (EU) 2019/882. It sets accessibility requirements for a list of products and services sold to consumers in the EU, and "e-commerce services" are on the list. Each member state wrote it into national law, and the requirements have applied since 28 June 2025. A directive is enforced by national authorities under national rules, so the exact penalties, the complaint route and the tone of enforcement differ by country.

For a website, the requirements are given technical shape by the harmonised standard EN 301 549, whose web clauses are the WCAG 2.1 level A and AA success criteria. In practice: an online shop that meets WCAG 2.1 AA is meeting the technical standard the Act points at. WCAG 2.2 added a few criteria that the current EN 301 549 (V3.2.1) does not yet list.

Does it apply to you?

• You sell to consumers in the EU. Where the business is based does not matter; where the customers are does. A shop outside the EU selling to EU consumers is in scope.
• Microenterprise exemption for services. A service provider with fewer than 10 staff and an annual turnover or balance sheet of at most €2 million is exempt from the requirements for services. Most one-person and small shops fall under this. The exemption is for the service (the shop); it does not cover products the Act lists, which is a separate question for hardware sellers.
• Transition. Service contracts agreed before 28 June 2025 may run unchanged until 28 June 2030. This is about existing contracts, not about a website that was built before the date; the website is a service provided today.
• Business-to-business only shops are not "services to consumers" and are outside the Act; the Web Accessibility Directive (public bodies) is a different law.

Whether the exemption applies to a particular business, and what a national authority would make of a borderline case, is a legal question for a lawyer in that member state. This page describes the text.

What an in-scope shop has to do

1. Make the service accessible as the Annex I requirements describe: information about the service perceivable and operable, the site usable with assistive technology, and the identification, payment and checkout functions accessible. EN 301 549 is how that is measured.
2. Publish how you meet the requirements. The Act asks service providers to explain, in their general terms and conditions or an equivalent document, how the service meets the accessibility requirements (Annex V). In practice that is an accessibility statement: what standard you aim at, what you know does not yet meet it, and how to contact you. Our report includes a draft statement to adapt.
3. Keep it that way. The obligation is continuous. A new theme, a new app or a new checkout can undo it.

The Act allows a "disproportionate burden" defence and a "fundamental alteration" exception, both of which the provider must assess and document itself, and which an authority can ask to see.

Enforcement so far

As of April 2026 no fine had been issued under the Act. The first court decisions have arrived: on 4 June 2026 a ruling against Carrefour ordered the company to fix its website and app within six months, with a penalty of €500 per day of delay and €10,000 in damages (Silktide's report, source below). Enforcement is complaint-driven in most member states: a consumer or a disability organisation reports the site to the national authority, which asks the provider to fix it. Fines come later and vary by country.

Two things follow for a small shop. First, the likely first contact is a letter asking for a fix, so having a statement and a plan already public changes the conversation. Second, the list of things that get complained about is short and predictable: images without alt text, buttons with no name, fields with no label, low contrast, and pages a keyboard cannot get through. Those are the same barriers US lawsuits cite; see ADA website lawsuit trends.

What to do first

1. Decide whether you are exempt (staff and turnover, above). If you are, you can still be asked about accessibility by customers and marketplaces, and the fixes are cheap; but the legal obligation is not there.
2. Find the barriers. A free automated checker finds roughly a third of the criteria; the rest needs someone to Tab through the site and read it with a screen reader, or an agent-assisted review like ours.
3. Fix in litigation order: alt text, names, labels, contrast, keyboard. The Shopify and WooCommerce pages give the code.
4. Publish an accessibility statement and a contact address. Say what is not fixed yet and when it will be.
5. Re-check after every theme or app change.

Words to avoid

Do not write "EAA compliant" or "WCAG certified" on the site or on a badge. Compliance is a legal determination made by a court or regulator, not a scanner, and no vendor can certify it. In the United States the FTC ordered an accessibility-widget vendor to pay $1 million in 2025 over claims that its product made sites automatically compliant. Say what you tested, what you fixed, and what remains.

When you want it done for you

Access Report crawls your site (10 pages for $49, up to 50 including cart and checkout for $129), runs the automated checks on every page, has an isolated language-model session judge the things automated tools cannot (keyboard order, focus, whether alt text actually describes the image, form errors, dialog traps, the find → cart → checkout flow), and gives you every barrier ranked by litigation category with the page, the element and a fix. HTML and PDF within 48 hours. Read the sample report first; it was produced against this site.

Access Report, from $49 See a sample report

Sources

• Directive (EU) 2019/882 (European Accessibility Act), text: eur-lex.europa.eu/eli/dir/2019/882/oj. Application date, microenterprise definition, Annex I and V, and the 2030 transition are from the text.
• Silktide, on the Carrefour ruling of 4 June 2026: silktide.com/blog/second-eaa-ruling-4-june-2026 (read 2026-09-13).
• US FTC final order against accessiBe, April 2025: ftc.gov.
• EN 301 549 V3.2.1 (2021-03), ETSI. Our report maps each finding to its clause.