EAA since June 2025 — scope and exemptions for consumer e-commerce

The European Accessibility Act (Directive 2019/882) applies to covered consumer e-commerce services from 28 June 2025, subject to its scope, exemptions and transitional provisions. Check whether your service falls within the national rules; selling online alone does not determine your obligations.

Who is covered?

A microenterprise employs fewer than 10 persons and has annual turnover or an annual balance-sheet total not exceeding EUR 2 million. Microenterprises providing services are exempt from the EAA service accessibility requirements and related compliance obligations; assess your actual status using the rules for autonomous, partner and linked enterprises, not just shop staff.

The service exemption does not exempt economic operators from separate duties for covered products. Assess whether you act as a manufacturer, importer or distributor of a product listed in Article 2(1), a service provider, or both; not every product sold online is covered.

What actually changed

WCAG 2.1 Level AA and EN 301 549 provide technical web accessibility criteria, not a blanket legal mandate for every shop. Applicable legal requirements depend on the covered service and country; technical criteria do not replace those rules.

The competent national authorities of each Member State handle supervision, and penalties follow national law; check the rules in every country where you sell.

Fix these first

• Missing image alt text — every meaningful product image needs a concise, descriptive alternative text.
• Decorative images — these need an empty alt so screen readers skip them.
• Colour contrast — body text must meet the 4.5:1 ratio.

Accessible service information

The public-sector accessibility statement model comes from Directive 2016/2102 and Decision 2018/1523. For covered services, EAA Article 13 and Annex V require accessible service information in terms and conditions or an equivalent document, retained while the service operates; Annex V is not a statement template. Check the national information duty for your service.

Country notes: in Poland, the Act of 26 April 2024 (Dz.U. 2024 item 731), Article 32(2), requires accessible service information in the service regulations or an equivalent document. In Germany, BFSG section 14 and Annex 3 set the service information duty, supplemented by the BFSGV. In Czechia, Act No. 424/2023 Coll., section 14, requires it in general terms or a comparable document. Confirm the competent authority in your country.

Where to start

Run a free WCAG check on your storefront, then prioritise the pages with the most traffic. An automated check detects only some barriers, so complete a manual review of keyboard use and checkout. Scans, alt text and generated documents do not guarantee compliance.

Primary sources

Sources checked on 2026-10-12. EU: Directive 2019/882, Directive 2016/2102, Decision 2018/1523, Recommendation 2003/361/EC. Poland: Dz.U. 2024 item 731. Germany: BFSG, BFSGV. Czechia: 424/2023 Sb..