European Accessibility Act: a 30-day plan for online shops
Since 28 June 2025, the European Accessibility Act (EAA) has required most online shops selling to consumers in the EU to be accessible to people with disabilities. In practice, that means meeting WCAG 2.1 level AA across the whole buying journey and publishing how your shop meets the requirements. Enforcement started slowly, but 2026 brought the first court order against a major retailer and steady pressure in Germany. If your shop isn't there yet, you can fix the parts that matter most in about 30 days, as long as you work in the right order.
Here's what the law asks for, what enforcement looks like now, and the plan we'd follow.
Does the European Accessibility Act apply to your online shop?
Almost certainly, if you sell to consumers in the EU. The EAA (Directive (EU) 2019/882) covers e-commerce services, and every member state has written it into national law: the BFSG in Germany, Decreto-Lei 82/2022 in Portugal, and equivalents everywhere else.
- The only blanket exemption is for microenterprises that provide services: fewer than 10 employees and no more than €2 million in annual turnover or balance sheet total. If your shop turns over more than €2M, this exemption doesn't apply to you.
- Being outside the EU doesn't help. A UK or US business selling to EU consumers is in scope for those sales.
- B2B-only shops are a grey area. The Act targets services to consumers. If you only sell to businesses, check your position with a lawyer.
- The transition period is narrow. Until June 2030, it covers products you were already lawfully using to deliver the service before June 2025. It is not a general grace period for websites, and most legal commentary treats online shops as covered since June 2025.
What enforcement looks like in 2026
For the first year, the EAA felt theoretical to many teams. That's changing.
- France: on 4 June 2026, the Tribunal judiciaire de Caen ordered Carrefour to make its website and app fully accessible within six months, with a penalty of €500 for every day it misses the deadline. Carrefour argued it had reached 71% conformity with France's national standard. The court treated accessibility as an obligation of result: 71% is not accessible.
- Germany: fines under the BFSG go up to €100,000. The market surveillance authority for accessibility (MLBF, based in Magdeburg) is reported to be using automated scans to check shops at scale. On top of that, shops have received warning letters (Abmahnungen) from competitors and law firms since summer 2025. Whether those letters are legally valid hasn't been settled in court, but answering one still costs time and legal fees.
- Portugal: ASAE supervises e-commerce under Decreto-Lei 82/2022, and fines for companies run into the tens of thousands of euros.
- Netherlands: the consumer authority (ACM) has sent information requests to e-commerce operators, including ones based outside the EU.
The pattern is clear. Regulators and disability organisations are starting with large, visible retailers, and automated scanning makes it cheap to check everyone else.
What "accessible" means in practice
The EAA sets the outcomes. The harmonised standard, EN 301 549, maps them to WCAG 2.1 level AA for websites and apps. In plain terms, someone who uses a keyboard, a screen reader, zoom or voice control has to be able to find a product, choose a variant, pay and manage their order without getting stuck.
There's also an information duty. You have to explain how your service meets the accessibility requirements, usually in an accessibility statement linked from your footer and referenced in your terms and conditions.
Two things don't count as compliance:
- Overlays and accessibility widgets. A script that adds a toolbar doesn't fix a checkout that a keyboard can't complete. Courts and disability organisations have been clear on this.
- A good Lighthouse score. Automated tools catch only some issues. They can't tell whether your alt text makes sense or whether a screen reader user can actually finish checkout.
The 30-day plan
We'd treat this as four weekly releases, prioritised by where money changes hands. The goal isn't a perfect report. It's a buying journey that works for everyone, plus the habits that keep it working.
Week 1: audit the buying journey
Map the path a customer takes: home, search and category pages, product page, basket, checkout, account, returns. Then test it three ways:
- An automated scan of every template, to catch the mechanical issues (contrast, missing labels, empty buttons).
- A keyboard-only run of a full purchase. No mouse, no trackpad. If you can't complete an order, nothing else on this list matters yet.
- A screen reader pass (VoiceOver or NVDA) on the product page and checkout.
Log every issue against the step it blocks, then rank by severity: blocks a purchase, causes confusion, or cosmetic.
Week 2: fix checkout and forms
Checkout is where accessibility and revenue overlap most directly. The fixes are usually:
- Visible labels on every field, not just placeholder text.
- Error messages that say what's wrong and how to fix it, announced to screen readers, with focus moved to the first error.
- A logical focus order, with no keyboard traps in address lookups, date pickers or payment fields.
- Payment widgets and CAPTCHAs that work with a keyboard and screen reader. These are often third-party, so check your provider's accessibility documentation and push back where it falls short.
- No session timeouts without a warning and a way to extend.
Week 3: product pages, navigation and filters
- Meaningful alt text on product images, and none on decorative ones.
- Variant selectors (size, colour) that are real buttons or inputs, with the selected state announced. Colour swatches need a text name, not just the colour.
- Filters and sorting that work with a keyboard and tell screen reader users when results change.
- Menus, modals and drawers (mini-basket, size guide) that trap focus while open and return it when closed.
- The cookie banner. It's the first thing every visitor meets, and a banner that can't be dismissed with a keyboard blocks the whole site.
- Text contrast of at least 4.5:1, including prices, sale labels and text over images.
Week 4: the statement, and making it stick
- Publish an accessibility statement: which standard you follow, what's known not to work yet and when it'll be fixed, and how customers can report a problem.
- Add automated accessibility checks to your release process, so new issues are caught before they ship.
- Add accessibility to your definition of done and to your design system, so new components start out accessible.
- Brief whoever writes product content on alt text and link wording.
The mistakes we'd avoid
- Treating it as a one-off project. Every release, new app or campaign landing page can break something you fixed. An audit from last spring says little about your site today.
- Fixing only the homepage. Regulators and customers judge the whole journey, and the checkout matters most.
- Forgetting third-party apps. Review widgets, live chat, loyalty pop-ups and payment iframes are part of your service, even if you didn't build them.
- Waiting for the law to settle. The German courts may take time to decide on warning letters, but the Carrefour ruling already shows how judges read the obligation.
There's a commercial upside
Accessibility work is mostly conversion work. Clear labels, helpful errors, readable contrast and forms that work with a keyboard make checkout easier for everyone: people on small phones, in bright sunlight, with a broken trackpad or in a hurry. Fixing these issues lowers your legal risk, and it usually removes friction that was costing you orders anyway.
Questions we hear
Does the European Accessibility Act apply to UK businesses?
Yes, for sales to consumers in the EU. Where your company is based doesn't matter. Where your customers are does.
Is an accessibility overlay enough to comply?
No. Overlays don't change the underlying code, and they often get in the way of the assistive technology people already use.
What standard do we need to meet?
WCAG 2.1 level AA, through the harmonised European standard EN 301 549. Working towards WCAG 2.2 AA is sensible because it adds a few criteria that matter for checkout, such as accessible authentication.
What are the fines?
They're set nationally and vary widely. In Germany they go up to €100,000. In France, Carrefour faces €500 a day if it misses its deadline. In Portugal they run into the tens of thousands of euros. Check the rules for each market you sell into, and get legal advice for anything binding.
Where to start
Accessibility is a good example of why a website should never be finished. It isn't something you fix once. It's something you keep fixing with every release.
Foundation audits accessibility alongside performance, conversion, SEO and GDPR, ships the first fixes within four to six weeks, and leaves you with a prioritised roadmap. After that, accessibility checks are part of every weekly release, not a separate project.
This article explains the European Accessibility Act in practical terms. It isn't legal advice. Check your obligations in each market with a lawyer.
