European Accessibility Act (EAA) for Online Shops: What You Need to Fix in 2026

The EAA is live. Law firms are already sending cease-and-desist letters. If you run an online shop selling to EU customers, here's what to actually prioritize.

Let's skip the preamble. The European Accessibility Act took effect on June 28, 2025, across all 27 EU member states. It's not coming. It's here.

And 2026 is when it starts to bite. Market surveillance authorities are ramping up. In Germany, law firms have already sent cease-and-desist letters to online shop owners under unfair competition law. In France, disability organizations filed formal complaints against major retailers within days of the deadline. This isn't theoretical anymore.

If you run an online shop that sells to consumers anywhere in the EU, your website needs to be accessible. Not "we'll get to it eventually" accessible. Actually, measurably, legally accessible.

Here's what to focus on, in order of what matters most.

First: Are You Even in Scope?

Short answer: if consumers can buy from your website, almost certainly yes.

The EAA defines "e-commerce services" broadly. If your site lets someone browse products, add things to a cart, and complete a purchase, you're covered. It doesn't matter if you're based in the EU or not. Selling to EU consumers is enough.

Micro-enterprises (under 10 employees, under €2M turnover) have a limited exemption for services. But "limited" is doing heavy lifting in that sentence. If you sell physical products through your shop, the product-side requirements may still apply.

Two other possible outs: if meeting accessibility requirements would fundamentally alter your service, or if the cost would be genuinely disproportionate. Both require formal documentation and justification to your national regulator. "It's expensive" alone won't cut it.

The Money Part: What Non-Compliance Actually Costs

Every EU country sets its own penalties, and the range is wild:

Germany caps fines at €100,000 per violation. France goes up to €250,000. Spain can hit €1,000,000. The Netherlands reaches €900,000. Ireland adds the fun twist of potential imprisonment (up to 18 months) for severe cases.

And here's the thing people miss: if you sell across multiple EU countries, each country can fine you separately. A Spanish customer and a Dutch customer filing complaints about the same website means two different regulators, two different proceedings.

But fines aren't even the scariest part. In several countries, authorities can order you to stop providing your service entirely until you're compliant. For an online shop, that means your store goes dark.

Priority #1: Your Checkout Flow

This is where regulators and auditors will look first, because it's the core of what an e-commerce site does. If a person with a disability can't complete a purchase, that's the textbook definition of the problem the EAA exists to solve.

Every form field needs a real label. Not placeholder text. Not a floating gray hint that vanishes when you start typing. A proper <label> element connected to its input. Screen readers depend on this to tell users what information a field expects.

Error messages need to be specific and tied to the right field. "There was an error" is useless. "Please enter a valid email address" works. Use aria-describedby to connect the error with its field so assistive technology announces it in context.

The entire flow needs to work by keyboard alone. Every field, every dropdown, every "apply coupon code" button, every payment step. Test it right now: put your mouse aside, go to your shop, and try to buy something using only Tab, Enter, and Space. If you get stuck anywhere, that's a compliance failure and a lost sale.

Don't break focus order. When someone tabs through your checkout, the sequence should follow the visual layout. Name, then email, then address, then payment. If focus jumps from the email field to the terms checkbox and then back to the street address, something is broken.

Priority #2: Product Browsing and Navigation

People need to find your products before they can buy them. That means your navigation, filters, and product pages all need to work for everyone.

Your main navigation needs keyboard support. Dropdown menus, mega menus, hamburger menus on mobile: all of it. Users need to open submenus, move through them, and close them without a mouse. Escape should close any open menu and return focus to where it was.

Product filters matter more than you'd expect. If your shop uses filter panels (size, color, price range, category), those controls need proper labels and keyboard support. A checkbox labeled "Blue" inside a group labeled "Color" makes sense. An unlabeled checkbox next to a colored swatch? That's invisible to a screen reader.

Product images need real alt text. "Product image" tells a screen reader user nothing. "Red wool scarf, 180cm, draped loosely around the neck" tells them what they're looking at. For fashion, furniture, food, anything visual: the alt text does the job that the photo does for sighted users. Make it count.

Dynamic content needs to be announced. When someone adds an item to the cart and a little counter updates in the header, screen reader users won't notice unless you use an ARIA live region to announce it. Same goes for "added to cart" confirmations, stock warnings, and search-as-you-type suggestions.

Priority #3: Color, Contrast, and Visual Design

Your design team might push back on this one. Push back harder.

WCAG 2.1 Level AA requires a minimum contrast ratio of 4.5:1 for normal text and 3:1 for large text. That's the standard the EAA references through EN 301 549.

In practice, this means auditing your entire color palette. The usual suspects: light gray text on white backgrounds, white text on pastel buttons, disabled-state text that's nearly invisible, placeholder text that blends into nothing.

Don't rely on color alone to communicate information. If an item is out of stock and the only indicator is a grayed-out "Add to Cart" button, you've excluded everyone who can't perceive that color change. Add text. Always.

Focus indicators need to be visible. If your CSS includes outline: none without a proper replacement, you've created an invisible navigation experience for keyboard users. Fix it with a solid, contrasting focus ring. Two minutes of CSS, massive compliance impact.

Content and Media: The Stuff That Slips Through

Marketing teams are the accidental accessibility villains of most organizations. Not out of malice. Just because nobody told them the rules.

PDFs uploaded after June 28, 2025, need to be accessible. Tagged structure, reading order, alt text on images, defined language. A scanned image of your terms and conditions is not an accessible PDF. It's a picture. Screen readers can't read pictures. If you generate PDFs from Word or InDesign, use their built-in accessibility tools. Ten times easier to do it right at the source than to fix it later.

Video content needs captions. Pre-recorded videos published after June 2025 fall under the EAA. Auto-generated captions are a start, but they're often inaccurate enough to be useless. Review and correct them.

Link text needs to make sense on its own. "Click here" and "Read more" are meaningless out of context. A screen reader user tabbing through links hears: "click here, click here, click here." Helpful, right? Use descriptive text instead: "View our return policy," "Download the size guide."

Heading structure matters. H1 for your page title, H2 for main sections, H3 for subsections. Don't skip levels. Don't use headings just to get bigger text (use CSS for that). Proper heading hierarchy lets screen reader users scan your page the way sighted users scan visually.

Testing and Documentation

The EAA requires you to demonstrate compliance. That means keeping records of what you've done, when, and how it meets the requirements.

For testing, start free:

Automated scanners like axe DevTools, WAVE, and Chrome's built-in Lighthouse catch around 30-40% of issues. The obvious ones: missing alt text, contrast failures, missing form labels.

The rest needs hands-on testing. Keyboard navigation (can you reach everything?). Screen reader testing (NVDA on Windows is free, VoiceOver on Mac is built in). Text zoom to 200% (does the layout survive?). These are the tests that find the problems tools miss.

For documentation, you'll need:

An accessibility statement on your site (what's accessible, what isn't yet, how users can report issues, and contact info). Technical documentation showing which standards you've applied. Records of your testing and what you fixed. If you're claiming exemptions, documented justification for each.

Keep everything for at least five years. Regulators can request it at any point.

Frequently Asked Questions

What standard do I need to meet?

The EAA references EN 301 549, the harmonized European ICT accessibility standard, which incorporates WCAG 2.1 Level AA. An updated version referencing WCAG 2.2 is expected in 2026. For now, WCAG 2.1 AA is your working target.

My shop is based outside the EU. Does this still apply?

Yes. The EAA covers any business offering e-commerce services to EU consumers, regardless of where the company is headquartered. If EU residents can buy from your site, you're in scope.

Can I use an accessibility overlay widget to comply?

No. Overlay tools don't fix the underlying code, and they're not recognized as a valid compliance path. The accessibility community and regulators agree on this. There's no shortcut.

What if I can't fix everything at once?

Prioritize the user journey: homepage, product listing, search and filters, cart, checkout, account pages. Those are what regulators examine first. Document your remediation plan with a timeline. "We're actively fixing this according to a documented plan" is a much better position than "we haven't started."

Do I need an accessibility statement?

Yes. The EAA requires a public accessibility notice describing your service's accessibility features, compliance status, and how users can report barriers. Most member states check this early in any complaint process. If you don't have one, that's an immediate red flag.

What about legacy contracts from before June 2025?

Service contracts signed before June 28, 2025, can continue unchanged until they expire, but no later than June 27, 2030. This applies to things like streaming subscriptions. It does not mean your live, active e-commerce website gets a pass. If your shop is serving customers right now, it needs to comply right now.

---

Not Sure Where Your Shop Stands?

We offer a free accessibility audit for online shops. We'll test your key user flows, flag the critical issues, and hand you a clear, prioritized list of what to fix first. No obligations, no pitch. Just an honest look at where you are.

Request Your Free Audit →