The European Accessibility Act for online shops: the practical 2026 guide
The European Accessibility Act (Directive (EU) 2019/882) has applied since 28 June 2025. A year in, market surveillance authorities across the EU are moving from awareness to enforcement — and most online shops still don't comply. This guide answers the four questions we get most, without legalese.
1. Does it apply to me?
Almost certainly yes, if both of these are true:
- You sell products or services to consumers in any EU country (e-commerce is explicitly in scope — it doesn't matter where your company is based, what matters is where your customers are).
- You are not a micro-enterprise: 10 or more employees, or annual turnover above €2 million.
Marketplaces, booking engines, banking, transport ticketing, e-books and consumer electronics interfaces are all named in the Act. If you're a micro-enterprise you're exempt from the services obligations — but your bigger clients and partners may still demand accessibility contractually.
2. What do I actually have to do?
The Act points to standard EN 301 549, which for websites effectively means WCAG 2.1 level AA. In plain terms, your shop must be usable by someone who:
- navigates with a keyboard only (no mouse) — including your entire checkout;
- uses a screen reader — so images need meaningful text alternatives, buttons need real names, forms need labels;
- has low vision — sufficient colour contrast, text that scales to 200%, no information conveyed by colour alone;
- needs time and clarity — no keyboard traps, sensible focus order, error messages that say what went wrong.
Plus one document: a published accessibility statement describing how your service meets the requirements. No certificate or external seal is legally required for private companies — the obligation is that your site actually complies and that you say so honestly.
3. What happens if I ignore it?
| Risk | Reality in 2026 |
|---|---|
| Fines | Set per member state. Spain's regime reaches six figures for serious cases (an airline was famously fined €90,000 under earlier accessibility rules). Germany (BFSG) allows fines up to €100,000; France up to €50,000 per non-compliant service. Germany, France and the Nordics have active surveillance programmes. |
| Corrective orders | Authorities can require you to fix the service or, ultimately, restrict it in their market. |
| Complaints | Any consumer or disability organisation can file one — that's typically what triggers an inspection. |
| Lost B2B deals | Increasingly, large buyers require EAA conformance from suppliers by contract. |
4. What should I do first? (the pragmatic order)
- Scan your site — an automated audit finds a large share of the failures in minutes and tells you how exposed you are. (Ours is free for your homepage.)
- Audit the key journeys manually — home → product → cart → checkout → account, with keyboard and screen reader. This is where automated tools can't see and where the legal risk concentrates. See our fixed prices for a full online-shop audit.
- Fix by severity — critical and serious issues first; most shops clear them with days of developer work, not months.
- Publish your accessibility statement — written from real results, not aspirations.
- Monitor monthly — every theme update, new banner or plugin can break conformance. Continuous checks keep the statement true.
One warning: skip the "instant compliance" overlay widgets. The largest vendor was fined $1M by the FTC and hundreds of overlay customers have been sued anyway. Here's the full breakdown.
Want the concrete, page-by-page version of step 3? See our online shop accessibility checklist for 2026. For step 4, our accessibility statement template and example gives you the exact structure to publish.
If you're a web agency and your clients keep asking about this, our white-label audit programme for agencies lets you sell the whole service under your own brand.
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