The European Accessibility Act for e-commerce: what changed on 28 June 2025
In short
The European Accessibility Act (EAA) is Directive (EU) 2019/882. It has applied to products and services placed on the market by private businesses since 28 June 2025, and it names e-commerce explicitly. If you sell online to consumers in the EU — even from outside it — you are very likely covered. Key points:
- the practical technical target for a website is EN 301 549, which incorporates WCAG 2.1 level AA;
- you must publish accessibility information about your service;
- fines and enforcement authorities are set country by country, because each Member State transposes the directive into its own law;
- a narrow micro-enterprise exemption exists for services (fewer than 10 people and turnover/balance sheet ≤ €2M);
- "one-click" accessibility overlays do not make you compliant.
The European Accessibility Act is not a single national law you can look up in one place. It is a European directive that each of the 27 Member States has written into its own national law — with the same core obligation everywhere, but its own fine scale and its own regulator in each country. This guide explains what the EAA requires of an online store, who it covers, and where to look for the rules that apply to the specific markets you sell into.
What the EAA is: Directive (EU) 2019/882
The European Accessibility Act is Directive (EU) 2019/882 of 17 April 2019 on the accessibility requirements for products and services. Because it is a directive, it does not apply directly: each Member State had to transpose it into national law. That is why the same obligation is called the décret / ordonnance in France, decreto legislativo 82/2022 in Italy, Ley 11/2023 in Spain and the BFSG in Germany. The substance is shared; the enforcement details are national.
The directive covers a defined list of products (computers, smartphones, payment terminals, ticketing machines, e-readers…) and services. Among the services, e-commerce is named explicitly — defined as the sale of products or services to consumers through a website or mobile application. If your business does that, the EAA applies to your online store.
The deadline: 28 June 2025
The EAA has applied to products and services placed on the market from 28 June 2025. There is no separate "grace period" for e-commerce websites: a store operating today is expected to meet the requirements now. A limited transitional arrangement exists for certain self-service terminals already in use and for some service contracts signed before the date, but it does not give a general reprieve to an ordinary online shop.
Who is covered — and the micro-enterprise exemption
The EAA targets economic operators — manufacturers, importers, distributors and service providers — that place covered products or services on the EU market. For e-commerce, that means the great majority of online stores selling to EU consumers.
There is one real carve-out. Micro-enterprises that provide services — fewer than 10 people and an annual turnover or balance-sheet total not exceeding €2 million — are exempt from the service obligations. Two cautions:
- the exemption is for services; a micro-enterprise that places products on the market still has product obligations;
- most established online stores and SaaS businesses exceed one of the two thresholds, so the exemption is narrower in practice than it first appears.
When in doubt, an audit gives you a factual answer on the state of your site regardless of status — and the accessibility work is worth doing even where the law does not strictly compel it.
The technical standard: EN 301 549 / WCAG 2.1 AA
The EAA sets functional accessibility requirements rather than a line-by-line checklist. In practice, digital accessibility is assessed against the harmonised European standard EN 301 549, which for the web incorporates the Web Content Accessibility Guidelines (WCAG) 2.1, level AA. Following the harmonised standards published in the Official Journal of the EU opens a presumption of conformity with the requirements.
Concretely, that means: sufficient colour contrast, text alternatives for images, full keyboard operability, properly labelled forms, a page structure that assistive technology can read, and content that reflows without loss when zoomed. For e-commerce specifically, the directive stresses the accessibility of identification, security and payment functions — the checkout is exactly where a barrier costs you a sale and exposes you to a complaint. A site already built to WCAG 2.1 AA satisfies the core of the obligation.
The mandatory document: accessibility information
Beyond making the site technically accessible, a service provider must publish information about the accessibility of its service: a description of how the service meets the applicable requirements, in an accessible format. This is the single most verifiable part of the law — an inspector does not need to audit dozens of technical criteria to note that the document is missing. It is the easiest breach to establish, and the cheapest to avoid.
Fines and authorities are set country by country
This is the point most "EAA fine" articles get wrong: there is no single EU-wide penalty. Each Member State sets its own sanctions and designates its own supervisory authority. The amounts and the regulator therefore depend on the market you are being assessed in. A few examples we cover in detail:
| Country | National law | Fine range (example) |
|---|---|---|
| Italy | D.Lgs. 82/2022 (authority: AgID) | €5,000 – €40,000 |
| Spain | Ley 11/2023 | see country guide |
| Germany | BFSG (Barrierefreiheitsstärkungsgesetz) | see country guide |
| Sweden | EAA transposition (in force) | up to SEK 10M |
| Norway | Already mandatory (WCAG 2.0 AA) | see country guide |
Beyond the headline fine, the most immediate lever is often operational: a regulator can require compliance and, in serious cases, order that a non-compliant service stop being supplied. For an online store, a checkout obstructed on a national market usually weighs more heavily than the size of the penalty itself.
The mistake to avoid: "one-click" accessibility overlays
Widgets such as accessiBe or UserWay promise automatic compliance through a single line of code. They do not make a site compliant. Their real effectiveness is disputed by disability organisations; in the United States, the FTC fined accessiBe one million dollars in 2025 over compliance claims found misleading. Above all, an overlay does not fix your site's source code and does not produce the accessibility information the EAA requires.
The defensible path is the opposite: audit the site, fix what can be fixed, and publish honest accessibility information that documents the real state and the action plan.
How to comply, in practice
- Audit. An automated technical scan (WCAG 2.1 AA) catches part of the non-conformities — contrast, image alternatives, structure, forms. It does not replace a full manual audit, but it establishes a factual, quantified baseline.
- Fix the priority items — often few in number and inexpensive (colour contrast, form labels, keyboard navigation, focus visibility).
- Publish the accessibility information, with an accurate conformance status and the avenues of recourse, in the form your market expects.
- Keep it up to date: compliance degrades with every release. A periodic re-scan keeps you from drifting back out of conformity.
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Frequently asked questions
Is the European Accessibility Act a single EU-wide law?
No. The EAA is Directive (EU) 2019/882. A directive sets a common obligation but is transposed by each Member State into its own national law — the décret/ordonnance in France, decreto legislativo 82/2022 in Italy, Ley 11/2023 in Spain, the BFSG in Germany, and so on. The core requirements are shared, but the fine scale and the supervisory authority differ from country to country.
Does the EAA apply to my online store?
Very likely, if you sell products or services to consumers in the EU through a website or app — e-commerce is named explicitly among the covered services. It applies regardless of where your company is registered: what matters is the market you serve. The main exception is micro-enterprises providing services (fewer than 10 people and turnover/balance sheet ≤ €2M), though most established stores exceed one of those thresholds.
What does the EAA require technically?
In practice, WCAG 2.1 level AA, via the harmonised European standard EN 301 549. Following the harmonised standards opens a presumption of conformity. That means sufficient colour contrast, text alternatives for images, keyboard operability, labelled forms, a structure readable by assistive technology, and content that reflows on zoom — with particular attention to the accessibility of identification, security and payment functions.
How big are the EAA fines?
There is no single EU fine — each country sets its own. As an example, Italy (D.Lgs. 82/2022, art. 24) sets administrative fines of €5,000 to €40,000, enforced by AgID. Other countries have their own scales and regulators. Beyond the fine, an authority can require compliance and, in serious cases, order that a non-compliant service stop being supplied. See the country guide for the market you sell into for precise figures.
Do accessibility overlays make me EAA-compliant?
No. An overlay adds a widget whose effectiveness is disputed, does not fix the source code, and does not produce the accessibility information the EAA requires. The compliant approach is to audit the site, fix the non-conformities and publish honest accessibility information.
What is the accessibility statement I have to publish?
The EAA requires a service provider to publish information describing how its service meets the accessibility requirements, in an accessible format. It is the most easily verifiable obligation, so a missing statement is the simplest breach to establish. The exact required form varies by national transposition; publishing an accurate statement — describing the real state and the plan for anything not yet compliant — is safer than a boilerplate that overclaims.