The European Accessibility Act (EAA) for online shops

The European Accessibility Act (EAA) is an EU directive that sets accessibility requirements for a list of products and services. E-commerce services are on that list. Its full name is Directive (EU) 2019/882 of the European Parliament and of the Council of 17 April 2019 on the accessibility requirements for products and services, and it was published in the Official Journal L 151 of 7 June 2019.

Article 31 of the Directive required each Member State to adopt and publish the national provisions needed to comply with it by 28 June 2022 and to apply them from 28 June 2025. In Germany, the law that transposes it is the BFSG. The sections near the end of this guide describe it and the laws that transpose the EAA in Denmark, France and Spain.

The EAA covers e-commerce services provided to consumers after 28 June 2025, subject to the transitional rules of Article 32 described below (Article 2(2)). Whether the requirements apply to a shop depends on the Directive’s definition of an e-commerce service and on the exemption for microenterprises.

Article 3, point (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”.

The definition refers to concluding a consumer contract. This guide does not assess whether a particular business falls under it. Microenterprises that provide services are exempt from the requirements, as the next section explains.

Microenterprises that provide services are exempt from the EAA’s accessibility requirements for services and from the obligations that relate to them (Article 4(5)). Other businesses, including small and medium-sized ones, are not named in that exemption.

A microenterprise, as Article 3, point (23) defines it, meets two conditions: it employs fewer than 10 persons, and its annual turnover or its annual balance sheet total does not exceed EUR 2 million. The same article defines small and medium-sized enterprises, and that definition excludes microenterprises.

Recital 72 of the Directive says that, while some microenterprises are exempted from its obligations, all microenterprises should be encouraged to provide services that comply with its accessibility requirements. Article 4(6) asks the Member States to provide guidelines and tools for microenterprises, developed with the relevant stakeholders.

Article 31 sets 28 June 2025 as the date from which the Member States apply their national provisions, and Article 2(2) covers e-commerce services provided to consumers after that date.

The transitional rules of Article 32 cover three situations:

• Until 28 June 2030, service providers may continue to provide their services using products they lawfully used to provide similar services before that date.
• Service contracts agreed before 28 June 2025 may continue without alteration until they expire, but no longer than five years from 28 June 2025.
• Member States may allow self-service terminals that service providers lawfully used before 28 June 2025 to stay in use until the end of their economically useful life, but no longer than 20 years after they entered into use.

These rules concern products already in use, existing service contracts and self-service terminals. This guide does not assess how they apply to a particular shop.

For e-commerce services, the EAA’s accessibility requirements are in Annex I of the Directive. Under Article 4(3), Section III of Annex I applies to services in general (urban, suburban and regional transport services aside), and Section IV applies to all services and has a point on e-commerce services, point (g).

Annex I, Section III requires websites, including related online applications, and mobile device-based services to be made accessible “in a consistent and adequate way”. It names four principles for this, the same four by which WCAG organises its success criteria. Point (g) of Section IV, on e-commerce services, adds requirements for information on the accessibility of the products and services sold, and for identification, security and payment (Annex I).

Beyond the requirements themselves, Article 13 sets duties for service providers:

• They design and provide their services in accordance with the accessibility requirements.
• They have procedures in place so that the service remains in conformity, and they take account of changes to the service, to the requirements, and to the harmonised standards or technical specifications by reference to which the service is declared to meet the requirements.
• Where a service does not meet the requirements, they take the corrective measures needed and immediately inform the competent national authorities of the Member States where the service is provided, with details of the shortfall and of the corrective measures taken.
• They prepare and publish information on how the service meets the requirements (next section).

The EAA asks service providers to describe how their service meets the accessibility requirements, in the general terms and conditions or an equivalent document (Article 13 and Annex V). The information is made available to the public in written and oral format, including in a way that is accessible to persons with disabilities, and is kept for as long as the service is in operation.

This information comes in addition to the consumer information that Directive 2011/83/EU already requires. A separate guide explains what an accessibility statement for an online shop contains.

Under Article 15 of the EAA, a service that conforms to a harmonised standard whose reference is published in the Official Journal of the EU is presumed to meet the accessibility requirements that standard covers. No reference to a harmonised standard under the EAA had been published in the Official Journal when this guide was last checked (6 October 2026). Where no such reference exists and certain conditions are met, Article 15(3) allows the Commission to adopt technical specifications instead.

EN 301 549 is the European standard for the accessibility of ICT products and services. When this guide was last checked (6 October 2026), no citation of any version of it under the EAA was found in the Official Journal. Its status on that date:

• Version 3.2.1 (2021-03) is cited in the Official Journal under a different law, the Web Accessibility Directive (Directive (EU) 2016/2102), by Commission Implementing Decision (EU) 2021/1339 of 11 August 2021.
• For the EAA, the Commission asked CEN, CENELEC and ETSI to draft harmonised standards in its standardisation request M/587 (C(2022) 6456), published on 14 September 2022 (Rolling Plan for ICT Standardisation 2026).
• ETSI published EN 301 549 V4.1.1 in September 2026. ETSI’s document says it was prepared under that request as one voluntary means of conforming to the essential requirements of the EAA. Its Annex ZB relates the standard to the EAA, with one table for all services (ZB.4) and one for specific services (ZB.5).

According to AccessibleEU, a European Commission initiative (7 September 2026), V4.1.1 adopts WCAG 2.2 for websites, software and digital documents, adds six requirements from WCAG 2.2 and removes the criterion 4.1.1 Parsing. AccessibleEU adds that once the Commission cites V4.1.1 in the Official Journal, it will give a presumption of conformity under both the EAA and the Web Accessibility Directive. Under Article 15, such a presumption extends only to the requirements that the cited standard covers.

The guide to WCAG 2.2 AA and EN 301 549 explains how the two standards relate.

Article 14 of the EAA allows an exception where meeting the accessibility requirements would fundamentally alter the basic nature of a service or, judged by the criteria set out in Annex VI, impose a disproportionate burden. A business that relies on it assesses this and documents the assessment, keeps the relevant results for five years after the service was last provided, and gives the authorities a copy of the assessment on request. It informs the authority that checks services in the Member State where the service is provided. A service provider renews its assessment of a disproportionate burden when the service changes, when the authority asks, and at least every five years. A business that receives funding from other sources, public or private, for improving accessibility cannot rely on a disproportionate burden.

This guide does not assess whether the exception is open to a particular shop.

Each Member State designates the authorities that check whether services meet the EAA’s requirements, follow up complaints or reports, and verify that corrective action has been taken (Article 23).

Penalties are national as well. Article 30 has each Member State set the rules on penalties for infringements of its national provisions. The penalties are to be effective, proportionate and dissuasive, come with effective remedial action, and take into account the extent of the shortfall, including its seriousness, the number of products or services concerned and the number of persons affected.

Validiscan is a web accessibility remediation service for EU online shops on Shopify, Shopware, WooCommerce and Magento. It scans a shop against WCAG 2.2 AA and EN 301 549, delivers the fixes as changes to the shop’s own source code, and documents the result in a dated Remediation Evidence Package. It does not assess whether a shop meets the EAA or a national law that transposes it: that is a legal assessment, for the shop and its lawyer.

The changes come as a pull request, an unpublished copy of a Shopify theme, or a patch bundle. The package’s scope statement reads: “Conformance with WCAG 2.1 AA and WCAG 2.2 AA success criteria as evaluated on the listed pages and dates.” It also says: “This package is evidence of an evaluation and of remediation work. It is not a certificate and does not state legal compliance.”