Accessible online shops: what the European Accessibility Act requires and where shops fail

Since 28 June 2025, most online shops selling to consumers in the EU have to be accessible. This guide covers who the European Accessibility Act applies to, what it asks of a shop in particular, where shops get stuck in practice, and how to walk through your own shop in an hour.

Published 2 November 2026 · Libration editorial team · 9 min read

In short The European Accessibility Act covers shops where consumers can conclude a contract. Microenterprises with fewer than ten staff and no more than €2 million turnover or balance sheet total are exempt, and pure B2B shops fall outside it. On top of general accessibility, the Act names sign-in, security features and payment explicitly. That is exactly where most shops fail: in the checkout. The quickest self-test is a test purchase using only the keyboard.

1. Does the law apply to my shop?

The European Accessibility Act (Directive (EU) 2019/882) covers “e-commerce services”: services provided at a distance, through websites and mobile apps, at the individual request of a consumer with a view to concluding a consumer contract. Whether you sell goods, tickets or appointments makes no difference. Two questions decide it: can a consumer order from you, and is your business larger than a microenterprise?

Situation	Covered?
Shop selling to consumers, with ten or more staff or over €2 million turnover or balance sheet total	Yes
Microenterprise: fewer than ten staff and no more than €2 million turnover or balance sheet total	No, the exemption applies to services
Pure B2B shop where consumers cannot place orders	No
Website without ordering, such as a catalogue with a contact form	Generally no
Selling through a marketplace	The platform is responsible for its own service; the exact role of sellers is still being debated

The microenterprise exemption only covers services. If you manufacture or import products the Act lists, such as e-readers, you have duties for those regardless of size. There is no general transition period for shops. Every EU country has transposed the Act into its own law, with its own authorities and penalties. Our overview The EAA across Europe shows how.

In Ireland, the rules are in S.I. No. 636/2023. The Competition and Consumer Protection Commission (CCPC) is the compliance authority for e-commerce services. It can issue directions to fix problems, which can be enforced through the courts. Legal commentary puts the criminal penalties at up to €5,000 on summary conviction and up to €60,000 on indictment, with possible personal liability for directors. Details are in our article on accessibility law in Ireland.

2. What the law requires of a shop

The whole shop has to be perceivable, operable, understandable and robust. That is the wording of the Act, and it mirrors the structure of the Web Content Accessibility Guidelines (WCAG). For e-commerce, Annex I, Section IV(g) adds three specific points:

Accessibility information about the products you sell, where the responsible manufacturer or supplier provides it.
Identification, security and payment functions must be accessible. That includes customer accounts, verification codes and the payment step.
Identification methods, electronic signatures and payment services you offer must be perceivable, operable, understandable and robust too.

You also have to publish information on how your service meets the requirements, in your terms and conditions or an equivalent document (Article 13 and Annex V). Our article on the accessibility statement shows what to include.

Which technical standard applies?

The Act does not name a standard directly. Conformity is presumed for services that meet harmonised standards published in the Official Journal of the EU. The relevant one is EN 301 549. Its new version 4.1.1, published in September 2026, refers to WCAG 2.2. At the time of writing, its reference under the Accessibility Act had not yet appeared in the Official Journal. In practice: WCAG 2.1 level AA is the floor, WCAG 2.2 AA is the safe target for anything you build now. The criteria are listed in our WCAG 2.2 overview.

3. Where shops actually fail

The WebAIM Million 2026 report found automatically detectable errors on 95.9 percent of the top one million home pages. Shopping sites averaged 71 errors per page, about a quarter more than the average site.
The Contentsquare Foundation looked at shops in the UK, France, Germany, Italy and Spain in November 2025: 94 percent had an inaccessible checkout, and 84 percent of checkout pages had buttons or fields with no accessible name.
Baymard Institute’s 2021 benchmark of 33 high-grossing shops found 45 percent had features that could not be used by keyboard, and 9 percent trapped keyboard users, for example in a card security code field. The data is older, but the pattern has not gone away.

The audience is large. The World Health Organization estimates 1.3 billion people live with a significant disability, about one in six. In the UK Click-Away Pound survey, 69 percent of disabled online shoppers said they leave websites they find hard to use, and the authors estimated £17.1 billion in lost sales a year. The survey dates from 2019 but is still the most cited figure on abandoned purchases.

4. Your shop, front to back

The best order is the one your customers follow.

Entry: cookie banner and pop-ups

The cookie banner is often the first barrier. It has to be reachable and dismissible by keyboard, and focus has to land somewhere sensible afterwards. Newsletter pop-ups that are hard to close frustrate everyone, not only disabled users.

Navigation, search and filters

The main menu must open by keyboard, and the search field needs a label that screen readers announce. Filters that update the product list without reloading are a classic trap: users who cannot see the screen don’t notice that anything happened. A short status message such as “24 products found” fixes that. Colour swatches also need the colour name as text.

Product page

Images: the main image needs alt text that describes the product, not just repeats its name. See Writing good alt text.
Variants: size and colour must be recognisable as choices. If a variant is sold out, that has to be announced, not only shown struck through.
Size charts as real tables with headers, not as images.
Star ratings need text such as “4.5 out of 5 stars”.
“Add to basket” must confirm success in a way everyone perceives.

Basket and checkout

This is where revenue is decided and where errors pile up. The key WCAG 2.2 criteria:

Criterion	What it means at checkout
3.3.2 Labels or Instructions	Every field has a visible label, not just placeholder text that disappears when typing
1.3.5 Identify Input Purpose	Name, address, email and phone fields carry the right `autocomplete` attribute so browsers can fill them
3.3.1 Error Identification	Errors are described in text next to the field, not only with a red border
4.1.3 Status Messages	Messages like “Voucher applied” are announced without moving focus
3.3.7 Redundant Entry	The delivery address can be reused as billing address instead of typing it again
2.2.1 Timing Adjustable	If a session expires, users are warned and can extend it
2.5.8 Target Size (Minimum)	Plus, minus and remove buttons are large enough to hit

Account, sign-in and CAPTCHA

Success criterion 3.3.8 requires sign-in without a memory or puzzle test. Pasting passwords and password managers must not be blocked. Verification codes split across six separate boxes that refuse pasting fail this criterion. CAPTCHAs that ask users to transcribe distorted text are not allowed at level AA. Image-recognition CAPTCHAs are permitted, but still lock out blind users. A guest checkout takes a lot of pressure off.

Payment

Card fields are often embedded from the payment provider in a frame you cannot change. You are still responsible for the payment step. Ask your provider for an accessibility conformance report (often called an ACR or VPAT). The July 2026 report for Stripe for WooCommerce, for example, lists several criteria as only partially supported, mostly around the quick-pay buttons. If in doubt, offer at least one payment method that works fully.

5. WooCommerce specifics

WooCommerce states that its core frontend substantially conforms to WCAG 2.2 AA when used with a suitable theme. Since version 10.0 in July 2025, more than 140 improvements have landed, including keyboard access in the mini basket and filters and announcements during checkout. That does not make your shop accessible. Your theme, filter or variation plugins, pop-up tools and payment provider decide the result. WooCommerce itself advises testing your shop with automated tools, the keyboard and a screen reader. Our plugin comparison gives an overview of helper tools.

6. What happens if a shop is not accessible

Enforcement differs by country. In France, a court ordered a major supermarket chain in June 2026 to make its website and app fully accessible within six months, after disability organisations took action. In Germany, the market surveillance authority received around 700 reports in its first months; by July 2026 no fine had been published. Penalties range from a few thousand euros to six figures, depending on the country. For context: in the United States, e-commerce sites have been the most frequent target of digital accessibility lawsuits, with UsableNet attributing 69 percent of cases in the first half of 2025 to them. More in EAA fines and enforcement.

7. Your shop in one hour

Keyboard-only test purchase: put the mouse aside and use Tab, Shift+Tab, Enter and Space from the cookie banner to the order summary. Can you always see where you are? Do you get stuck anywhere?
Fill in the form wrongly on purpose: are errors described in text? Are correct entries kept?
Zoom to 200 percent: does everything stay readable without horizontal scrolling?
Run an automated scan on the home page, a category page, a product page and the basket.
Ask your payment provider for its conformance report and prepare the accessibility information for your terms or footer.

Most findings are quicker to fix than expected: labels, alt text and contrast are diligence work. Theme bugs and third-party extensions take longer. Our article on what accessibility costs helps you budget.

Start with a product page The website scan checks a page in a few seconds and shows the barriers it finds, free of charge. Run it on a product page and on the basket. It does not replace the keyboard test purchase, but it shows you where to look first.

Sources and notes

Directive (EU) 2019/882 (European Accessibility Act), Art. 3(23) and (30), Art. 4(5), Art. 13, Art. 32, Annex I Section IV(g), Annex V
S.I. No. 636/2023, European Union (Accessibility Requirements of Products and Services) Regulations 2023, CCPC guidance and DLA Piper on the Irish regulations (penalty figures)
WebAIM Million 2026
Contentsquare Foundation, E-commerce Accessibility Snapshot, November 2025
Baymard Institute, accessibility benchmark, June 2021
WHO fact sheet on disability and health, March 2023
Click-Away Pound Survey 2019
W3C, Understanding 3.3.8 Accessible Authentication and WCAG 2.2
WooCommerce accessibility, WooCommerce 10.0 and the Stripe for WooCommerce conformance report
UsableNet, mid-year 2025 lawsuit report (US figures)
informations.handicap.fr on the Carrefour ruling, June 2026
All information as of 2 November 2026.

This article is an overview and does not replace legal advice.