European Accessibility Act: what ecommerce stores must do by 2025

The European Accessibility Act (EAA) became enforceable on June 28, 2025. It requires ecommerce services sold to EU consumers to meet specific accessibility standards. Unlike the ADA in the United States, the EAA is not enforced through private lawsuits. It is enforced by national market surveillance authorities with the power to issue fines up to 4% of annual revenue.

If your store sells to customers in the EU, you are likely in scope. This guide covers what the EAA requires, who it applies to and what you need to do.

What the EAA covers

The EAA (Directive 2019/882) sets accessibility requirements for products and services. For ecommerce, the relevant category is "ecommerce services," which the directive defines broadly as any service that enables online transactions between consumers and traders.

The directive does not define technical standards itself. Instead, it references the harmonized European standard EN 301 549, which in turn maps closely to WCAG 2.1 AA. If your site meets WCAG 2.1 AA, you are most of the way to EAA compliance. Note that WCAG 2.2 has since been published with additional success criteria relevant to ecommerce, and EN 301 549 is expected to reference the updated version.

The EAA goes beyond WCAG in some areas. It requires:

• Services to be perceivable, operable, understandable and robust (the four WCAG principles).
• Identification, authentication and payment processes to be accessible.
• Customer support channels (chat, email, phone) to be accessible.
• Information about the accessibility features of products sold through the store.

Who is in scope

The EAA applies to economic operators that provide ecommerce services to consumers in the EU. This includes:

• EU-based stores. Any ecommerce business established in an EU member state.
• Non-EU stores selling to EU consumers. If you actively target EU customers (accepting euros, shipping to EU addresses, translating to EU languages), you are likely in scope.
• Marketplaces. Platforms that facilitate transactions between sellers and EU consumers.

There is a microenterprise exemption: businesses with fewer than 10 employees and annual turnover below 2 million euros are exempt. Everyone else must comply.

The exemption is narrow. A store with 10 employees doing 3 million euros in revenue is in scope. A solo founder doing 2.5 million is in scope. Most mid-market ecommerce stores are well above the threshold.

How it differs from the ADA

US stores are familiar with ADA accessibility risk. The EAA differs in several important ways:

• Explicit web standard. The ADA does not reference WCAG directly (though courts use it as guidance). The EAA explicitly references EN 301 549, which maps to WCAG 2.1 AA. The standard is not ambiguous.
• Government enforcement. The ADA is primarily enforced through private lawsuits. The EAA is enforced by government authorities in each member state. This means larger fines and no ability to quietly settle.
• Fines based on revenue. ADA settlements typically range from $5,000 to $25,000. EAA fines can reach 4% of annual revenue. For a $20M store, that is $800,000.
• Proactive obligation. Under the ADA, stores typically fix issues after receiving a demand letter. The EAA requires stores to proactively ensure accessibility before enforcement action.

How member states are implementing it

The EAA is a directive, meaning each EU member state transposes it into national law. Implementation varies:

• Germany transposed the EAA through the Barrierefreiheitsstarkungsgesetz (BFSG). Enforcement is handled by the Federal Network Agency (Bundesnetzagentur).
• France integrated EAA requirements into its existing accessibility framework under RGAA. The ARCOM oversees enforcement.
• Netherlands assigned enforcement to the Authority for Consumers and Markets (ACM).
• Spain transposed through Real Decreto 193/2023 with enforcement by the Ministry of Social Rights.

The key point: enforcement is happening at the national level, which means 27 different authorities can investigate your store. Selling across the EU means exposure to all of them. Our guide on EAA enforcement actions in 2026 tracks the first cases and fines across member states.

What violations look like

EAA enforcement focuses on functional accessibility barriers, not cosmetic issues. The violations that draw enforcement attention:

• Inaccessible checkout. If a screen reader user or keyboard-only user cannot complete a purchase, that is a fundamental failure. Checkout is the highest priority flow.
• Missing form labels. Input fields without programmatically associated labels make forms unusable for assistive technology users.
• No keyboard navigation. Interactive elements (dropdowns, modals, accordions, filters) that only work with a mouse.
• Inaccessible customer support. If your live chat widget is not keyboard accessible or your support forms lack proper labels, you are not meeting the EAA requirement for accessible customer service.
• Missing product accessibility information. The EAA requires that stores provide information about the accessibility features of the products they sell, where applicable.

The compliance timeline

The EAA enforcement date was June 28, 2025. There is no grace period for new services. Services that existed before June 28, 2025 had until that date to comply.

There is a transitional provision for service contracts concluded before June 28, 2025: these can continue under existing terms until June 28, 2030. But new customers, new features and new pages must all be accessible from day one.

What to do now

• Audit against WCAG 2.1 AA. This covers the core technical requirements. Focus on checkout, cart, account creation and search, the flows that matter most for both users and enforcement.
• Test with real assistive technology. Automated scanning catches about 30-40% of WCAG violations. Test critical flows manually with a screen reader (NVDA or VoiceOver) and keyboard-only navigation.
• Fix checkout first. If a user cannot complete a purchase, nothing else matters. Accessible checkout is the single highest priority.
• Make customer support accessible. Test your chat widget, contact forms and support pages. The EAA specifically requires accessible customer service channels.
• Document your efforts. The EAA requires economic operators to be able to demonstrate compliance. Keep records of audits, remediation work and testing results.
• Monitor continuously. Accessibility is not a one-time project. Every theme update, new product page, app installation or checkout change can introduce regressions. Automated monitoring catches these before enforcement authorities do.

The bottom line

The EAA is not optional and the fines are substantial. For US stores selling to EU customers, it adds a regulatory layer on top of ADA risk. For EU stores, it is a legal obligation with government enforcement.

The good news: if you meet WCAG 2.1 AA, you cover the bulk of EAA requirements. The work you do for accessibility protects you on both sides of the Atlantic. The stores that invest in accessibility now avoid fines, reduce ADA lawsuit risk and reach 15-20% of consumers who have some form of disability.

Frequently asked questions

What is the European Accessibility Act (EAA)?

The EAA (Directive 2019/882) is an EU directive requiring ecommerce services sold to EU consumers to meet accessibility standards based on EN 301 549, which maps closely to WCAG 2.1 AA. It became enforceable on June 28, 2025 and is enforced by national market surveillance authorities.

What are the EAA fines for non-compliance?

EAA fines can reach up to 4% of annual revenue, enforced by government authorities in each EU member state. For a store doing $20M in revenue, that is up to $800,000. Unlike ADA lawsuits which typically settle for $5,000-$25,000, EAA fines are set by regulators and cannot be quietly settled.

Does the EAA apply to non-EU stores?

Yes, if you actively target EU customers by accepting euros, shipping to EU addresses or translating your site to EU languages. There is a microenterprise exemption for businesses with fewer than 10 employees and under 2 million euros in annual turnover.

How does the EAA differ from the ADA?

The EAA explicitly references EN 301 549 and WCAG 2.1 AA as the technical standard, is enforced by government authorities rather than private lawsuits, imposes fines based on revenue percentage and requires proactive compliance rather than reactive fixes after a demand letter.