The European Accessibility Act: what it requires of websites selling into the EU
The European Accessibility Act has applied since 28 June 2025. A year on, the most common question we get from store owners is not what it says — it is whether it applies to them, and whether they have until 2030. Both questions have clearer answers than the coverage suggests, and the second one is frequently reported incorrectly.
This is what the directive itself says, with the article numbers, so you can check any of it against the source.
What the EAA is
The European Accessibility Act is Directive (EU) 2019/882. It sets common accessibility requirements for a defined list of products and services sold to consumers in the EU, and it applies to services provided to consumers after 28 June 2025. Because it is a directive rather than a regulation, it takes effect through each member state's own transposing law, which is also where the penalties are set.
It is a market-access rule, not a territory rule. It attaches to products placed on the Union market and services provided to consumers in the Union, so a business outside the EU that sells to EU consumers is within its scope.
Whether it applies to your site
Article 2(2) lists the services covered: electronic communications, access to audiovisual media services, specified elements of air, bus, rail and waterborne passenger transport, consumer banking, e-books and dedicated software, and — the one most readers are here for — e-commerce services.
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. If a consumer in the EU can buy from your website, that is the definition.
The microenterprise exemption
Article 4(5) exempts microenterprises providing services from the accessibility requirements for services. Article 3(23) defines a microenterprise 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.
Read the conjunctions carefully, because they do different jobs. The headcount test and the financial test must both be satisfied — fewer than ten people and under the money threshold. Within the financial test the two limits are alternatives: turnover under EUR 2 million or balance sheet total under EUR 2 million is enough. A twelve-person company is not a microenterprise however small its turnover.
The second detail: the exemption in 4(5) is written for microenterprises providing services. The directive treats microenterprises placing products on the market differently, giving them lighter documentation duties rather than a clean exemption. For an online store the service is what is in scope, so the exemption does generally reach it — but do not state flatly that microenterprises are exempt from the EAA.
Why the 2030 date is usually misquoted
You will read that existing websites have a five-year grace period until 28 June 2030. That is not what the transitional measures in Article 32 say. Article 32(1) provides a transitional period ending 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. It also lets service contracts agreed before 28 June 2025 run to expiry, for no more than five years.
The distinction that matters is the directive's own: Article 2(1) lists products — computer hardware and operating systems, payment and ticketing terminals, e-readers, consumer terminal equipment — and Article 2(2) lists services, with e-commerce among them. An online store is a service under 2(2)(f), not a product under 2(1). Reading Article 32(1) as a deadline extension for the storefront itself does not follow from that structure.
How a national authority or court would read it in a specific case is a legal question, and it is one for your lawyer rather than your scanner. The safe operating assumption, and the one we would plan around, is that the requirements applied from 28 June 2025.
What 'accessible' means under the EAA
The directive states functional requirements rather than a technical standard: information must be perceivable through more than one sensory channel, be understandable, be presented in ways users can perceive, and the service must be provided in a way that supports assistive technology. The bridge from those words to testable criteria is the harmonised European standard EN 301 549.
The version of EN 301 549 cited in the Official Journal of the European Union incorporates WCAG 2.1 Level AA for web content, and a revision aligning the standard to WCAG 2.2 is in progress. A harmonised standard only confers a presumption of conformity once it is cited in the Official Journal, so check the current citation status before relying on one.
The practical consequence is the same either way. WCAG 2.2 is a superset of 2.1 apart from one removed criterion, so targeting 2.2 Level AA satisfies the version in force today and needs no revisiting when the revision lands.
The documentation obligation people forget
The EAA is not only a build requirement. Article 13 obliges service providers to prepare information explaining how the service meets the applicable accessibility requirements, and to make that information available to the public in an accessible format.
In practice that means a published accessibility statement that names the standard you target, states your current conformance status honestly, lists known limitations, and gives people a way to report a barrier. A statement that claims full conformance you cannot evidence is worse than one that says partially conformant and shows the work in progress.
A working order of operations
- Confirm scope. Do you sell to consumers in the EU, and are you above the microenterprise thresholds on both headcount and finances?
- Establish a baseline. Audit the site against WCAG 2.2 AA and keep the dated report. You cannot write an honest statement without one.
- Fix the templates, not the pages. Store issues are template issues: one product-page fix propagates across the catalogue.
- Cover the whole purchase path. Home, collection, product, cart, checkout, account, and the transactional emails. Checkout is where a failure stops a sale outright.
- Audit what you installed. Review widgets, upsell modals, cookie banners and chat bubbles — third-party scripts carry their own failures into your service.
- Publish the Article 13 information. An accessibility statement with your standard, status, known limitations, test method, and a feedback channel.
- Re-scan on a schedule. Themes update, apps change, products get added. A statement dated eighteen months ago undercuts itself.
On enforcement
Enforcement runs through national market-surveillance and service-compliance authorities designated by each member state, and the directive requires penalties that are effective, proportionate and dissuasive — but it leaves the amounts to national law. Figures circulating as though there were one EU-wide maximum fine are not in the directive. Check the transposing law of the member states you actually sell into, and do not plan around a number you read on a vendor blog.
Where AdaChecked fits
Our scans test against WCAG 2.2 A, AA and AAA and map findings to the frameworks that reference them, including the EAA and EN 301 549, so an EU-facing store gets its issue list and its documentation from the same audit. Every plan, including the free ones, produces a publishable accessibility statement from the latest scan.
If the list is longer than one sprint, work it by level: Level A must-fix issues first, then AA, then the advisory findings. The report ranks them that way already, and a re-scan tells you when a batch has actually landed rather than when it was marked done.