The European Accessibility Act covers e-commerce services. In practice, this means most online stores that sell to consumers must have an accessible site and an accessible purchase process, from search all the way to payment.
The basis is the directive on accessibility requirements for products and services, and in Poland it is implemented by the act on the accessibility of products and services. Below you will find who these rules apply to, what needs to change in your store and where to start, so you don’t burn your budget on fixes done in the wrong order.
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Does the European Accessibility Act apply to your store?
Do you sell online to consumers, in other words run an ordinary B2C store? Then the act most likely covers you, because e-commerce is one of the services listed in the directive. There is an exception for microenterprises, but only when it comes to providing services. According to the definition in the directive, a microenterprise employs fewer than 10 people and its annual turnover or balance sheet total does not exceed two million euros.
This exemption does not cover products. A microenterprise that sells equipment covered by the act (e-book readers, terminals and the like) still has obligations related to that product range. Before you wave the topic away as something that doesn’t concern you, answer a few questions:
- Do you sell to consumers, or only to businesses?
- Does your company fit the definition of a microenterprise in terms of headcount and turnover or balance sheet?
- Does your product range include products listed in the directive, for example computers, smartphones or e-book readers?
- Do you operate only in Poland, or also in the markets of other member states?
What online store accessibility means in practice
An accessible store is perceivable, operable, understandable and works well with assistive technologies such as screen readers. The directive applies these four principles to services, but its text does not point to a specific technical standard. This is where WCAG (Web Content Accessibility Guidelines) comes in. In practice, these guidelines are the reference point, because they turn general slogans into criteria that can be checked.
And behind all of this are real customers. People who are blind or have low vision, people with motor impairments, people who navigate a site with the keyboard only or with a heavily magnified screen. How do these requirements translate into a design? We show it using the example of websites compliant with WCAG built from scratch.
WCAG in e-commerce: a list of changes in your store
Most of the work is usually on the purchase path, from the product page to payment. That is exactly where a customer with a disability most often drops off. Review your store in these areas:
- Alternative texts for product photos: they should describe what is visible, not repeat the product name.
- Contrast of text and buttons, plus readability after zooming the page.
- Keyboard operation across the whole store and a visible focus, meaning a clear indication of the active element.
- Form field labels and error messages that state plainly what to correct.
- An accessible cart and checkout: changing quantities, discount codes, choosing delivery and payment without a mouse.
- Filters and search that a screen reader can handle.
- Information about the accessibility of the service published in the store.
That last point comes straight from the directive. The service provider has to describe how its service meets the accessibility requirements, in the general terms and conditions or in an equivalent document. And, funnily enough, that description itself has to be accessible too.
Where to start adapting your store to the EAA
With an audit. Fixes come only after that, because without an audit it is easy to tinker with small details and miss a checkout that makes it impossible to place an order. In my view, a sensible order looks like this:
- An automated and manual audit, including going through a purchase with the keyboard alone.
- Priorities based on impact on the purchase: first whatever blocks placing an order.
- Fixes to the theme and plugins.
- Screen reader tests on the most important pages.
- Documentation and a check with every subsequent change.
When choosing methods, our overview describing accessibility testing tools will help. Take a particularly close look at WooCommerce, Shopify and PrestaShop themes and plugins. Ready-made sliders, modal windows or custom checkout fields are often the main source of trouble.
Rebuild or fixes: when it makes sense to design the store from scratch
An old theme with a mass of errors in the code? Then a rebuild can be cheaper than patching component after component. Base the decision on three things: what state the theme is in and whether anyone is still developing it, how many inaccessible elements came up in the audit, and what changes to the store you are planning anyway. If you are preparing a new look or a platform migration, write accessibility into the requirements from day one, and base your store design and implementation on components tested with a keyboard and a screen reader. Adding it later always turns out more expensive.
Oh, and don’t forget about the rest of the site. The blog, the contact page and the terms and conditions often sit on the same theme, so the digital accessibility of company websites should go hand in hand with the work on the store.
Supervision and the consequences of a lack of accessibility
Member states are obliged to monitor whether services meet the accessibility requirements and to establish penalties for infringements. The directive says that penalties are to be effective, proportionate and dissuasive, and supervisory authorities can require a service provider to remove the non-compliance. The details, including which authorities are competent, are set out in the national act on the accessibility of products and services. So when assessing risk, rely on its text and not on the amounts circulating in Facebook groups.
The European Accessibility Act is best treated as a permanent part of store maintenance, not a one-off project to tick off. Every new plugin, promotion or change in the checkout can bring barriers back. That is why accessibility checks should become part of the normal process of rolling out changes, just like tests before a deploy.
Frequently asked questions
Does a small online store have to meet the EAA requirements?
Microenterprises providing services are exempt from the accessibility requirements with regard to those services. But this does not apply to products, so selling equipment covered by the act still comes with obligations. Whether a company is a microenterprise is decided by the definition in the directive.
Is WCAG compliance enough to meet the requirements of the European Accessibility Act?
WCAG is a practical reference point when assessing a site, but the obligations do not end there. The store must also provide information on how the service meets the accessibility requirements. So it is best to work on the technical fixes and this description in parallel.
Does an accessibility plugin solve the problem?
No. Overlays with a panel for zooming or changing contrast do not touch the code of the theme or the checkout. Missing labels, focus traps and inaccessible modal windows stay where they were. What is needed is an audit and fixes in the store itself.
