The European Accessibility Act mandates that all e-commerce services must be accessible to persons with disabilities by June 28, 2025. This affects any business selling online to EU consumers, regardless of where the company is located. Let’s quickly go over the key bullet points and then we’ll get into the details.
Disclaimer: This post is our interpretation of the EAA and does not constitute legal advice. Consult your counsel on EAA compliance.
Quick Summary
Key Requirements at a Glance:
- Who must comply: Any business selling online to EU consumers (except microenterprises with <10 employees and <€2M revenue)
- Deadline: June 28, 2025 for full compliance
- Scope: Websites, mobile apps, and all online sales processes
- Core principle: Services must be “perceivable, operable, understandable and robust”
- Documentation: Must publish accessibility statements explaining compliance
- Enforcement: EU countries will monitor compliance and impose “effective, proportionate and dissuasive” penalties
Three Critical E-commerce Requirements:
- Make your entire e-commerce platform accessible: Websites and mobile apps must be “perceivable, operable, understandable and robust” (this covers everything from browsing to checkout)
- Preserve and provide accessibility information: Pass along manufacturer accessibility details about products you sell, and provide accessible information about your service (Section IV(g)(i) and Section III(b))
- Offer accessible customer support: Help desks, call centers, and support services must provide information about accessibility features using accessible communication methods (Section III(d))
Business Impact:
- Legal risk: Non-compliance brings enforcement action and penalties starting June 2025
- Market opportunity: Access to 87 million Europeans with disabilities represents significant purchasing power
- Operational changes: updating development, design, and content processes to include accessibility, staff training, and ongoing accessibility monitoring
- Documentation burden: Must maintain accessibility assessments and statements throughout service operation
Ecommerce Details
The European Accessibility Act requires e-commerce services to be accessible to persons with disabilities by June 28, 2025.
As Recital 42 states: “Given the increased relevance of e-commerce services and their high technological nature, it is important to have harmonised requirements for their accessibility.”
This means if you sell anything online to EU consumers—whether you’re based in Europe or elsewhere—your website and mobile app must work for people with disabilities. The law recognizes that online shopping has become essential, and everyone deserves equal access to digital commerce.
In the following sections, we’ll put into plain English what the pertinent ecommerce language from the EAA means.
Definition and Scope
Article 3(30) defines e-commerce services as “services provided at a distance, through websites and mobile device-based services by electronic means and at the individual request of a consumer with a view to concluding a consumer contract.”
In practical terms, this covers virtually any online sales platform. Whether you’re selling physical products, digital downloads, subscriptions, or booking services, if customers can buy from you online, you’re likely covered.
Recital 42 clarifies the key terms: “‘at a distance’ means that the service is provided without the parties being simultaneously present; ‘by electronic means’ means that the service is initially sent and received at its destination by means of electronic equipment for the processing (including digital compression) and storage of data, and transmitted, conveyed and received in its entirety by wire, by radio, by optical means or by other electromagnetic means; ‘at the individual request of a consumer’ means that the service is provided on individual request.”
This legal language essentially describes modern e-commerce: customers browse your website or app, select products, and complete purchases without meeting you face-to-face. The “individual request” part means the service responds to what each customer wants, rather than broadcasting the same content to everyone.
Article 2(2)(f) includes “e-commerce services” within the directive’s scope. Recital 43 establishes broad coverage: “The e-commerce services accessibility obligations of this Directive should apply to the online sale of any product or service and should therefore also apply to the sale of a product or service covered in its own right under this Directive.”
The EAA directive takes a comprehensive approach—it doesn’t matter what you’re selling online. Whether it’s clothing, electronics, software, or services, the accessibility rules apply to the online selling process itself.
Who Must Comply
Article 3(4) defines service providers as “any natural or legal person who provides a service on the Union market or makes offers to provide such a service to consumers in the Union.”
This definition is intentionally broad. If you sell to EU customers, you must comply—regardless of where your company is located. A US-based retailer shipping to Germany must follow the same rules as a German company.
Article 13(1) establishes the core obligation: “Service providers shall ensure that they design and provide services in accordance with the accessibility requirements of this Directive.”
This places responsibility squarely on business owners. You can’t simply hope your website happens to be accessible—you must actively ensure it meets the requirements from the design phase forward.
Exemptions
Article 4(5) exempts microenterprises: “Microenterprises providing services shall be exempt from complying with the accessibility requirements referred to in paragraph 3 of this Article and any obligations relating to the compliance with those requirements.”
Article 3(23) defines microenterprises as “an enterprise which employs fewer than 10 persons and which has an annual turnover not exceeding EUR 2 million or an annual balance sheet total not exceeding EUR 2 million.”
This exemption recognizes that very small businesses may lack resources for full compliance. If you have fewer than 10 employees and revenue under €2 million, you’re off the hook for most requirements—though compliance could still benefit your business.
Article 14(1) provides additional relief: “The accessibility requirements referred to in Article 4 shall apply only to the extent that compliance: (a) does not require a significant change in a product or service that results in the fundamental alteration of its basic nature; and (b) does not result in the imposition of a disproportionate burden on the economic operators concerned.”
Even larger businesses get some flexibility. If making your service accessible would fundamentally change what you offer, or if the costs are genuinely excessive relative to your resources, you may have grounds for partial exemption. However, you must document these claims thoroughly.
General Service Requirements
Section III of Annex I states: “The provision of services in order to maximise their foreseeable use by persons with disabilities, shall be achieved by:”
This section lays the foundation for accessible e-commerce. The goal isn’t just technical compliance—it’s ensuring people with disabilities can actually use your service effectively.
Information Requirements
Point (b) requires “providing information about the functioning of the service, and where products are used in the provision of the service, its link to these products as well as information about their accessibility characteristics and interoperability with assistive devices and facilities” through seven specific methods including:
“(i) making the information available via more than one sensory channel; (ii) presenting the information in an understandable way; (iii) presenting the information to users in ways they can perceive; (iv) making the information content available in text formats that can be used to generate alternative assistive formats to be presented in different ways by the users and via more than one sensory channel”
These requirements address how you communicate with customers. Information must be available through multiple senses—not just visually. Think audio descriptions for images, captions for videos, and text alternatives for visual elements. The content must also work with assistive technologies like screen readers.
Website and Mobile Application Requirements
Point (c) mandates “making websites, including the related online applications, and mobile device-based services, including mobile applications, accessible in a consistent and adequate way by making them perceivable, operable, understandable and robust.”
This is where most compliance work happens. Your website and mobile app must follow the “POUR” principles: Perceivable (users can see or hear content), Operable (users can navigate and interact), Understandable (content makes sense), and Robust (works with assistive technologies).
The easiest way for your website or app to meet POUR is by conforming with WCAG 2.1 AA or WCAG 2.2 AA.
Support Services
Point (d) requires “where available, support services (help desks, call centres, technical support, relay services and training services) providing information on the accessibility of the service and its compatibility with assistive technologies, in accessible modes of communication.”
If you offer customer support, your representatives must know about accessibility features and be able to communicate through accessible channels. This might mean offering text chat for customers who can’t use voice calls, or training staff to assist users of screen readers.
Specific E-commerce Requirements
Section IV(g) of Annex I establishes three requirements for “E-Commerce services:”
These go beyond general accessibility to address the unique challenges of online commerce. Each requirement tackles a specific barrier that could prevent people with disabilities from completing purchases.
Accessibility Information Preservation
“(i) providing the information concerning accessibility of the products and services being sold when this information is provided by the responsible economic operator”
If manufacturers provide accessibility information about their products, you must pass it along to customers. Don’t bury or delete details about whether a device works with screen readers or if a service offers audio descriptions.
Core Service Functionality
“(ii) ensuring the accessibility of the functionality for identification, security and payment when delivered as part of a service instead of a product by making it perceivable, operable, understandable and robust”
The checkout process must be fully accessible. This includes account creation, login systems, security features like two-factor authentication, and payment processing. These critical functions often create the biggest barriers for users with disabilities.
Transaction Process Accessibility
“(iii) providing identification methods, electronic signatures, and payment services which are perceivable, operable, understandable and robust.”
Every step of completing a purchase must work for people with disabilities. This covers everything from verifying identity to signing digital agreements to entering payment information.
Documentation Requirements
Article 13(2) states: “Service providers shall prepare the necessary information in accordance with Annex V and shall explain how the services meet the applicable accessibility requirements. The information shall be made available to the public in written and oral format, including in a manner which is accessible to persons with disabilities.”
You must create an accessibility statement explaining how your service works for people with disabilities. This isn’t just a legal formality—it helps customers understand what accessibility features are available and how to use them.
Annex V requires service providers to include information “in the general terms and conditions, or equivalent document” containing:
“(a) a general description of the service in accessible formats; (b) descriptions and explanations necessary for the understanding of the operation of the service; (c) a description of how the relevant accessibility requirements set out in Annex I are met by the service.”
Your accessibility statement should be easy to find and understand. Include it in your terms of service or create a dedicated accessibility page. Explain in plain language how people with disabilities can use your service and what assistive technologies you support.
Article 13(2) adds: “Service providers shall keep that information for as long as the service is in operation.”
Keep your accessibility documentation current. As you update your website or add features, update your accessibility statement accordingly.
Assessment and Monitoring
Article 14(2) requires: “Economic operators shall carry out an assessment of whether compliance with the accessibility requirements referred to in Article 4 would introduce a fundamental alteration or, based on the relevant criteria set out in Annex VI, impose a disproportionate burden.”
If you believe full compliance would be unreasonable, you must document why. This isn’t an easy escape route—you need solid evidence that the requirements would fundamentally change your business or create excessive costs.
Article 14(3) mandates documentation: “Economic operators shall document the assessment referred to in paragraph 2. Economic operators shall keep all relevant results for a period of five years to be calculated from the last making available of a product on the market or after a service was last provided.”
Keep detailed records of your compliance efforts and any burden assessments. Regulators may request this documentation, and you’ll need it if questions arise about your compliance status.
Article 14(5) establishes renewal requirements: “Service providers relying on point (b) of paragraph 1 shall, with regard to each category or type of service, renew their assessment of whether the burden is disproportionate: (a) when the service offered is altered; or (b) when requested to do so by the authorities responsible for checking compliance of services; and (c) in any event, at least every five years.”
Accessibility compliance isn’t a one-time task. You must regularly reassess your situation, especially when you change your services or when authorities request updates.
Compliance Timeline
Article 31(2) sets the deadline: “They shall apply those measures from 28 June 2025.”
This is a hard deadline. Come June 28, 2025, enforcement begins, and non-compliant businesses face penalties.
Article 32(1) provides transitional provisions: “Member States shall provide for a transitional period ending on 28 June 2030 during which service providers may continue to provide their services using products which were lawfully used by them to provide similar services before that date.”
You get some breathing room for existing systems, but only until 2030. Plan your technology upgrades with accessibility in mind.
Enforcement
Article 29(1) requires Member States to “ensure that adequate and effective means exist to ensure compliance with this Directive.”
Article 30(2) mandates that penalties “shall be effective, proportionate and dissuasive. Those penalties shall also be accompanied by effective remedial action in case of non-compliance of the economic operator.”
Enforcement will vary by country, but expect meaningful penalties that reflect the seriousness of accessibility violations. The focus will be on getting businesses to fix problems, not just paying fines.
Article 23(1) requires Member States to “establish, implement and periodically update adequate procedures in order to: (a) check the compliance of services with the requirements of this Directive, including the assessment referred to in Article 14” and “(b) follow up complaints or reports on issues relating to non-compliance of services with the accessibility requirements of this Directive.”
Expect regular monitoring and complaint systems. Customers who encounter accessibility problems will have clear channels to report issues, and authorities will follow up on these reports.
Implementation Steps
To meet the directive’s requirements, e-commerce providers should:
- Evaluate current platforms against Section III and IV(g) requirements—audit your website and mobile app for accessibility barriers
- Implement accessibility features making services “perceivable, operable, understandable and robust”—follow established standards like WCAG 2.1 AA or WCAG 2.2 AA
- Prepare documentation per Annex V requirements—create clear accessibility statements
- Conduct disproportionate burden assessments if applicable—document any compliance challenges
- Establish ongoing monitoring and complaint procedures per Article 23—create systems to catch and fix accessibility problems
The directive’s comprehensive framework ensures that e-commerce services become accessible to the 87 million Europeans with disabilities while harmonizing requirements across Member States for improved cross-border trade. By starting compliance efforts now, businesses can avoid last-minute scrambles and build more inclusive, user-friendly services that benefit all customers.
Help with EAA Compliance
Accessible.org can help you with EAA compliance.
- Accessible.org provides accessibility services to help e-commerce businesses meet EAA requirements.
- Just send us a message and we’ll reply right away
- Our WCAG Course trains your staff on the Web Content Accessibility Guidelines (WCAG)
- Accessibility Tracker is a digital accessibility project management platform that tracks issues and progress and has AI tools inside the dashboard to help with fixes
Legal Disclaimer: This post represents our interpretation and analysis of the European Accessibility Act (EAA) and related accessibility requirements and obligations but does not constitute legal advice. While we strive for accuracy, Directives and their interpretation may vary by EU member state and change over time. Consult with legal counsel regarding your specific situation.
