What does the EAA require from an online store specifically?

Beyond the general requirement that websites and apps be perceivable, operable, understandable and robust, Annex I adds two e-commerce points: providing the accessibility information about the products and services being sold when the responsible economic operator provides it, and making identification, security and payment functionality accessible when it is delivered as part of the service.

Does my payment page have to be accessible?

Annex I requires the accessibility of identification, security and payment functionality when it is delivered as part of a service instead of a product. For an online store, the checkout, login and payment steps are where that requirement bites. A payment provider's embedded form is still part of the purchase journey your customer has to complete.

Does the EAA apply to a store with fewer than 10 employees?

Microenterprises providing services are exempt from the accessibility requirements for those services. The Directive's definition is fewer than 10 persons employed and an annual turnover not exceeding €2 million or an annual balance sheet total not exceeding €2 million. Check your country page, because national transposition can add detail.

Is a store that only sells to businesses covered?

The services list covers services provided to consumers, and the e-commerce definition refers to concluding a consumer contract. A store that sells only to businesses sits outside that definition as written, but a store that accepts orders from individuals or sole traders buying for personal use is selling to consumers in the Directive's sense.

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European Accessibility Act for E-commerce

E-commerce is one of the six service categories the European Accessibility Act names. If you run an online store selling to consumers in the EU, this is the part of the Directive that applies to you most directly, and it asks for more than an accessible homepage.

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What counts as e-commerce under the EAA

Article 3 of the Directive gives the legal definition:

"'e-commerce services' means 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"

Four elements, and a store is in scope when all four are present:

At a distance: the buyer and seller are not together.
Through a website or mobile service, by electronic means.
At the individual request of a consumer: the customer initiates it.
With a view to concluding a consumer contract: the purpose is a sale to a consumer, which the Directive defines as a natural person acting outside their trade, business, craft or profession.

Source: Directive (EU) 2019/882, Articles 2(2) and 3.

What the Directive asks of an online store

Annex I sets the accessibility requirements. For services, it starts with a general one that applies to every covered service's website and app, and then adds points specific to each service category. Two layers apply to a store.

The general requirement for websites and apps

Websites, including related online applications, and mobile device-based services, including mobile apps, must be made accessible "in a consistent and adequate way by making them perceivable, operable, understandable and robust". Those four words are the four principles of WCAG, which is how the Directive connects to the technical standard in practice. SeeEAA vs WCAG for that chain.

The two points added for e-commerce

Accessibility information about what you sell. Providing "the information concerning accessibility of the products and services being sold when this information is provided by the responsible economic operator". If a manufacturer tells you a product is compatible with screen readers, or has tactile markings, that information has to reach your product page rather than stop in a supplier spreadsheet.
Identification, security and payment. "Ensuring the accessibility of the functionality for identification, security and payment when delivered as part of a service instead of a product by making it perceivable, operable, understandable and robust". For a store, this is the login, the account creation, any CAPTCHA or verification step, and the payment form: the stages where a customer who cannot get through cannot buy at all.

Source: Directive (EU) 2019/882, Annex I, Section IV.

Most EAA guides for online stores skip both points and go straight to generic WCAG checklists. They are the two requirements written for stores specifically, and they point at the product data pipeline and the checkout, which are the two places a store is least likely to have tested.

Where online stores actually fail

A store that is accessible on the homepage and breaks at checkout has not met the requirement, however good the marketing pages look. The recurring findings:

Product images without alt text. Usually the largest single finding, because it repeats once per product. Catalogs imported from supplier feeds arrive with the field empty.
Icon-only buttons: a cart icon, a wishlist heart, a filter toggle, with no accessible name for screen reader users.
Custom dropdowns and filters built from generic elements instead of native form controls, often not operable with a keyboard.
Variant selectors for size and colour drawn as swatches that announce nothing, or announce only an internal code.
Low-contrast sale and stock badges, and stock status shown only in red or green.
Checkout forms with placeholder-only labels: the label disappears the moment the customer starts typing.
Visual-only CAPTCHAs and verification steps with no accessible alternative, which is exactly the identification and security functionality Annex I names.
Errors shown only in colour, or announced nowhere, so a customer who submits the checkout form does not know why nothing happened.

E-commerce accessibility checklist

Ordered by the purchase journey, because that is how a customer meets the problems. Each line is something you can test yourself; the keyboard tests need no tools at all.

Browsing

Every product image that carries information has alt text describing the product.
Search and filters can be operated with the keyboard alone, and applying a filter does not throw focus back to the top of the page.
Every icon-only button has an accessible name.
Prices, sale badges and stock status do not rely on colour alone and meet contrast minimums.

Product page

Size and colour selectors announce the option and whether it is selected.
Accessibility information supplied by the manufacturer appears on the page.
Add to cart confirms that the item was added, in a way a screen reader announces.

Account and login

Every field has a visible label that stays visible while typing.
Any CAPTCHA or verification step has an accessible alternative.
Password requirements are stated before submission, not only after an error.

Checkout and payment

The whole checkout, including the payment form, can be completed with the keyboard alone.
Errors are identified in text and associated with the field that caused them.
Shipping and payment method choices have accessible names.
Session timeouts warn the customer and let them extend the time.
The order confirmation is announced and states what happens next.

Around the store

An accessibility statement is published and linked from every page. The statement generator covers what Article 13 requires.
Customer service can explain the store's accessibility position by phone, because Article 13 requires the information in oral format as well as written.

Platform-specific guides

Where the fix lives depends on the platform, and each one draws the line between what it covers and what you own in a different place:Shopify, WooCommerce,PrestaShop, and WordPress.

Does the exemption apply to a small store?

Microenterprises providing services are exempt from the accessibility requirements for those services. The Directive defines a microenterprise as one employing fewer than 10 persons, with an annual turnover not exceeding €2 million or an annual balance sheet total not exceeding €2 million. See EAA exemptions for what that covers and what it does not, and your country page for how it was transposed locally.

E-commerce and the EAA: common questions

Does the European Accessibility Act apply to my online store?: If it sells to consumers in the EU, very likely. E-commerce services are one of the six service categories in Article 2(2), and Article 3 defines them 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. Microenterprises providing services are exempt.
What does the EAA require from an online store specifically?: Beyond the general requirement that websites and apps be perceivable, operable, understandable and robust, Annex I adds two e-commerce points: providing the accessibility information about the products and services being sold when the responsible economic operator provides it, and making identification, security and payment functionality accessible when it is delivered as part of the service.
Does my payment page have to be accessible?: Annex I requires the accessibility of identification, security and payment functionality when it is delivered as part of a service instead of a product. For an online store, the checkout, login and payment steps are where that requirement bites. A payment provider's embedded form is still part of the purchase journey your customer has to complete.
Does the EAA apply to a store with fewer than 10 employees?: Microenterprises providing services are exempt from the accessibility requirements for those services. The Directive's definition is fewer than 10 persons employed and an annual turnover not exceeding €2 million or an annual balance sheet total not exceeding €2 million. Check your country page, because national transposition can add detail.
Is a store that only sells to businesses covered?: The services list covers services provided to consumers, and the e-commerce definition refers to concluding a consumer contract. A store that sells only to businesses sits outside that definition as written, but a store that accepts orders from individuals or sole traders buying for personal use is selling to consumers in the Directive's sense.

Sources: Directive (EU) 2019/882, Articles 2, 3, 4(5) and 13, and Annex I, Section IV. Quotations are from the English text published in the Official Journal. Checked 13 September 2026.

This page is a general overview, not legal advice. Whether the EAA applies to your specific store, and what your national law adds, depends on your country: see thecountry-by-country breakdown.