European Accessibility Act 2026: requirements for e-commerce

The European Accessibility Act: what it is and why it concerns your e-commerce business

Since 28 June 2025, the European Accessibility Act (EAA, Directive 2019/882) has moved from theory to enforceable law across the European Union. If you run an online store, mobile app or e-commerce platform, these rules directly concern you.

In practice, the EAA means one thing: digital products and services must be accessible to people with disabilities. This concerns not only public institutions, which have had their own regulations for years, but above all the private sector, including online stores, online banking, streaming platforms and self-service terminals.

As an agency owner, I see many business owners still unaware that their stores may fail requirements already in force. And the penalties? They are real and can be substantial.

This article takes you through everything you need to know: who exactly the EAA covers, technical requirements based on WCAG, and a practical checklist you can start using immediately.

Who does the EAA cover? Duties for e-commerce and digital services

Directive 2019/882 covers a wide range of products and services. It is not limited to large corporations: it concerns every operator that places covered products on the market or provides covered services, regardless of size, except microenterprises with fewer than 10 employees and turnover up to EUR 2 million.

If you run an online store, offer online banking, sell e-books or operate an audiovisual content platform, the EAA concerns you.

Services and products covered by the European Accessibility Act

Polish implementation: the product and service accessibility act

Poland implements the EAA through the Act of 26 April 2024 on ensuring the accessibility of certain products and services by economic operators. These requirements are not a European abstraction: they translate into Polish law, Polish supervisory bodies and Polish penalties.

The market surveillance authority for product accessibility is the President of the Office of Competition and Consumer Protection (UOKiK); for services, it is the minister responsible for digital affairs. These are real institutions with real inspection powers.

Accessibility requirements for online stores: what must you meet?

The EAA does not provide a ready-made “click here, fix there” list. It refers to harmonised standard EN 301 549, whose current V3.2.1 version directly incorporates WCAG 2.1 AA. In practice, your online store must be perceivable, operable, understandable and technically robust.

Does that sound abstract? Let us turn it into specifics relevant to every online store.

Key areas of e-commerce accessibility

• Keyboard navigation - the entire purchase process, from browsing products to placing the order, must work without a mouse. Every interactive element needs visible focus.
• Contrast and readability - text against its background needs at least 4.5:1 contrast, or 3:1 for large text. This covers buttons, form labels, prices and product descriptions.
• Alternative text - every product photo, promotional banner and functional icon needs descriptive alt text. Not “image1.jpg”, but a real description of what the graphic shows.
• Forms and validation - order, registration and contact fields need clear labels, understandable error messages and an opportunity to correct entries before submitting.
• Responsiveness and zoom - content must remain readable at 200% zoom without losing functionality. Increasing text size must not break the layout.
• Multimedia - product videos need captions, audio needs transcripts and animations need a way to stop them.

The purchase journey: where do users most often drop out?

Across platforms, three stages cause the most accessibility problems in e-commerce audits:

1. Product filtering and sorting - dropdowns, price sliders and multi-select filters rarely work correctly with screen readers and keyboards.
2. Cart and checkout - dynamically updated elements, such as quantity changes, discount codes and delivery choices, often fail to announce changes to assistive technology.
3. Payment - payment gateways embedded in iframes can be inaccessible, while CAPTCHA without an alternative blocks users with disabilities.

Fines and penalties for EAA non-compliance: what could your business face?

The European Accessibility Act is not a soft recommendation. Every EU member state must introduce effective, proportionate and dissuasive penalties for accessibility infringements. Poland’s implementing act sets specific penalties.

Understanding enforcement matters because the consequences extend beyond a one-off fine. They can operate on several levels and affect the business over time.

Types of penalties under Polish law

• Financial penalties - the market surveillance authority may impose up to PLN 80,000 for a product or service that fails accessibility requirements. Repeated infringements can lead to repeated fines.
• Product withdrawal order - if a digital product, such as an app or e-book reader, does not meet requirements, the authority can suspend sales until the issues are fixed.
• Service suspension order - in extreme cases, the authority may order an inaccessible digital service to stop operating until it is adapted.
• Duty to inform consumers - a business may have to publicly disclose non-compliance, creating reputational risk.

The real cost of ignoring the EAA: more than fines

A fine is often the smallest problem. The actual cost of inaccessibility combines several factors with long-term business effects:

I will put it plainly: implementing accessibility from the start costs less than patching gaps under inspection pressure. Planned work fits the normal release cycle and improves templates along the way. Forced work lands immediately, mid-season, without time to test.

WCAG and the EAA: meeting technical requirements in practice

The European Accessibility Act does not define its own technical criteria. It refers to EN 301 549, harmonised with EU law, whose current V3.2.1 version directly incorporates WCAG 2.1 AA. This means a store meeting WCAG 2.1 AA is also very likely to meet the EAA requirements.

The standard is already being revised and the threshold will rise. The November 2025 V4.1.0 draft incorporates WCAG 2.2 AA, with a reference to final V4.1.1 expected in the EU Official Journal in October 2026. Aim directly for 2.2 AA during any major store rebuild. It adds a few criteria and means doing the work once rather than twice.

But “meeting WCAG” is not a checkbox. It is a process requiring an understanding of four fundamental accessibility principles and how they apply to store elements.

The four WCAG principles, POUR, in e-commerce

New WCAG 2.2 criteria particularly relevant to e-commerce

Version 2.2 added these criteria, so they become formal requirements with the revised standard. I already check them in audits because they affect places where baskets are actually lost:

• Focus Not Obscured (2.4.11 AA) - keyboard focus must not be covered by sticky headers, cookie pop-ups or chatbots. This is common in e-commerce: the navigation bar covers the active element and the user loses orientation.
• Dragging Movements (2.5.7 AA) - every action requiring dragging, such as a price filter slider, needs a single-click alternative.
• Target Size (2.5.8 AA) - interactive buttons, links and checkboxes need a minimum touch area of 24x24 pixels. Tiny “add to favourites” and “remove from cart” icons often fail this criterion.
• Redundant Entry (3.3.7 A) - if users have already provided information, such as their delivery address, the system should not make them enter it again for billing.

How to adapt an online store for the EAA: a practical action plan

Accessibility does not have to mean rebuilding the store from scratch. Most purchase blockers live in templates and CSS, not the store engine: field labels, contrast, keyboard support and button sizes. Prioritise changes by their effect on users.

Below is the plan we use on e-commerce projects. It works for WooCommerce, PrestaShop and custom solutions alike.

Seven stages of implementing e-commerce accessibility

Quick wins: changes with an immediate effect

Not every improvement requires a rebuild. These actions can be implemented within a week and improve accessibility fastest:

• Add descriptive alt text to every product photo: not “IMG_4523”, but “Black leather handbag with a metal clasp”.
• Ensure every CTA button, including Add to cart and Buy now, has sufficient contrast and a minimum size of 24x24 px.
• Add a Skip to content link at the beginning of each page. Five minutes’ work makes a huge difference for keyboard users.
• Check that form error messages identify the specific field and explain the problem, rather than just saying “An error occurred”.
• Disable or limit automatic homepage carousels, giving the user control over scrolling.

Common e-commerce accessibility mistakes and how to avoid them

Certain errors recur in online store audits regardless of platform, industry or budget. Here are the most common, with concrete fixes so you can check your own store immediately.

Mistake 1. Missing alt text or generic image descriptions

“Product photo”, “image.jpg” and empty alt attributes are the three most common cases I encounter. Screen reader users then do not know what the image shows. In e-commerce, the product photo is often the most important part of the buying decision.

Fix: describe each product photo as if describing it to a customer by phone: colour, material, shape and a key detail. Use empty alt text for decorative images, alt=“”, so the reader skips them.

Mistake 2. Inaccessible product filters and sorting

Price sliders, custom checkboxes and filter dropdowns can look excellent but almost never work with keyboards and screen readers. A user with a disability cannot filter products, effectively preventing them from using the store.

Fix: replace the price slider with minimum and maximum input fields. Ensure custom checkboxes have ARIA roles and respond to Space/Enter. Announce every filter change through a live region.

Mistake 3. Invisible or ineffective keyboard focus

Many developers add outline: none to CSS because the blue outline “looks ugly”. A keyboard user then cannot see which element is active. It is like moving around a dark room without a torch.

Fix: never remove the outline without replacing it with another focus indicator. Use CSS :focus-visible so focus appears for keyboard navigation rather than after mouse clicks.

Mistake 4. Checkout inaccessible to screen readers

Dynamic checkout forms, including product quantity changes, payment selection and summary updates, often fail to announce changes. Users do not know whether the product was added, what they will pay or whether the order was placed.

Fix: add aria-live=“polite” to dynamically updated elements such as cart summaries and status messages. Give every checkout step a clear heading structure.

Mistake 5. Cookie pop-up blocking the content

A cookie banner that does not capture focus or cannot be closed by keyboard blocks the entire site. It is among the easiest problems to fix and one of the most common.

Fix: the cookie banner should capture focus after page load, close with Escape and return focus to the page after closing. The Accept button must be keyboard-accessible.

Mistake 6. Low contrast on buttons and prices

Grey text on light grey, a white price on a pastel banner, a pale yellow Add to cart button on white: fashionable design, poor accessibility. Sale prices, Bestseller labels and secondary buttons are particularly affected.

Fix: check every text element with WebAIM Contrast Checker. The minimum is 4.5:1 for ordinary text and 3:1 for large text (18px+ or 14px bold).

What should you remember?

Most mistakes come from lack of awareness, not bad intentions. Developers and designers rarely test with keyboards or screen readers. One afternoon of manual testing can reveal more problems than a month of automated scans.

For a concrete implementation plan, see the EAA compliance checklist in the final section.

EAA compliance checklist: step by step for e-commerce

Here is a practical checklist to start assessing your store. It does not replace a full accessibility audit but helps you identify the biggest gaps quickly and set priorities.

Work through every point and mark whether your store meets it. Any uncertainty shows you where to start.

Technical foundation

• HTML is semantically correct, with no critical errors from the W3C validator.
• Headings follow a correct hierarchy: one H1 per page and logical H2-H6 levels.
• The page language is declared in the HTML element’s lang attribute.
• Page regions are semantically identified: header, nav, main and footer.
• The site is fully responsive and readable at 200% zoom.

Navigation and interaction

• The entire store, from homepage to order confirmation, works with a keyboard alone.
• Keyboard focus is always visible and never disappears behind fixed or sticky elements.
• A Skip to content link is available.
• Modals, dropdowns and mega-menus close with Escape and capture focus through a focus trap.
• No element requires dragging without a click alternative.

Content and multimedia

• All product photos have descriptive alt attributes, neither empty nor generic.
• Decorative graphics use empty alt=“” and role=“presentation”.
• Product videos have captions and audio content has transcripts.
• Text contrast is at least 4.5:1, or 3:1 for large text.
• Animations and carousels have a pause button or can be stopped.

Forms and checkout

• Every form field has an associated label, using label for or aria-label.
• Error messages identify the specific field and explain the problem.
• Users can undo, correct or confirm their data before finalising an order.
• The payment gateway is accessible, including the provider’s iframe.
• The system does not require users to re-enter information already provided.

Documentation and process

• The site publishes an accessibility statement with its last update date.
• A mechanism for reporting accessibility problems exists: form, email or phone.
• Accessibility is verified with every major store update.
• Developers, designers and content managers are trained in accessibility basics.

Summary: what to remember from this article

The EAA is neither an announcement nor an industry recommendation. It has applied since 28 June 2025, with a Polish implementing act and authorities holding real inspection powers.

Key takeaways

• The rules apply from 28 June 2025. Poland implements them through the Act of 26 April 2024, with the President of UOKiK supervising products and the minister responsible for digital affairs supervising services.
• The microenterprise exemption, below 10 staff and up to EUR 2 million turnover, does not cover manufacturers. Check which side your business falls on before dismissing the subject.
• The current technical threshold is WCAG 2.1 AA through EN 301 549 V3.2.1. The revision will move to 2.2 AA, so aim for the newer version when planning changes.
• Fines can reach PLN 80,000 and recur for repeated infringements. Service suspension and public consumer notification are additional consequences.
• Most purchase-blocking barriers sit in templates and CSS, not the store engine. Changing platforms is rarely the answer.

What next?

• Work through the checklist and mark uncertain points: they form your starting list.
• Run axe, WAVE or Lighthouse and separately navigate the entire buying journey with a keyboard. Automation reveals critical errors; keyboard testing reveals what automation misses.
• Prioritise fixes by one criterion: does the problem prevent a purchase? Cosmetic work can wait.

Accessibility can break quietly: one deployment with a new cart plugin is enough. Build checks into your release process rather than returning to the subject once a year under inspection pressure.

FAQ: common questions about the European Accessibility Act

Five questions online store owners ask when first encountering the EAA: dates, scope, fines and where to begin. Each topic is explained in the sections above.

One question usually causes the most uncertainty: does the microenterprise exemption cover my store? The answer depends on whether you only sell or also manufacture, because manufacturers are not exempt. Have a question not covered here? Email biuro@digidraft.pl. We reply within 24 business hours.