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EAA compliance for e-commerce: a practical checklist

A practical EAA compliance checklist for online stores: who is in scope, what the law requires, and how to verify your site.

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Pavel Charkasau

EAA compliance for e-commerce means your online store has to be usable by people with disabilities, because the European Accessibility Act (Directive (EU) 2019/882) lists e-commerce as a covered service and has applied since 28 June 2025. In practice that comes down to three things. First, the whole buying journey (browsing, product pages, cart, login, checkout, and payment) has to meet the technical bar the law points to, which is EN 301 549 and, for the web, WCAG 2.1 Level AA. Second, e-commerce carries a few extra duties WCAG never mentions: you have to convey accessibility information about the products you sell when the maker provides it, and keep identification, security, and payment steps accessible. Third, you need to publish an accessibility statement describing where you stand and give people an accessible way to report problems. The scope is set by market, so a non-EU store selling to EU consumers is included. This guide turns that into a checklist you can actually work through.

Does the EAA apply to my online store?

Probably, if you sell to consumers in the EU. The EAA defines e-commerce services as those "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" (Directive (EU) 2019/882, Article 3). That description covers most online shops. It applies by market rather than by where the company sits, so a business outside the EU that sells into the EU is in scope for those sales (European Commission).

There is one real exemption worth knowing. A microenterprise that provides a service is not bound by the EAA's accessibility requirements. A microenterprise is a business with fewer than 10 people and an annual turnover or balance sheet total of no more than €2 million (Directive (EU) 2019/882, Article 3(23)). Two catches. The exemption is for services, so if you manufacture a covered product it does not help you. And it disappears the moment you cross the threshold, with no grace period. If you are a small shop under those limits, you have no legal obligation today, though the accessibility work still widens your customer base. Everyone else should treat the store as in scope. We go deeper on eligibility in our EAA overview.

What does the EAA actually require of an e-commerce site?

The law is written in outcomes, not code. It says a service must be accessible, then leans on a harmonised standard for the technical detail. That standard is EN 301 549, and conformity with it earns a presumption of conformity with the EAA under Article 15. For anything web-facing, EN 301 549 v3.2.1 incorporates WCAG 2.1 Level AA. So the working bar for an online store's website is WCAG 2.1 AA, applied across the entire transactional flow: product listings, filters, product detail, cart, account creation and login, checkout, and payment (Freshfields).

On top of that general bar, Annex I Section IV adds two requirements specific to e-commerce. You have to provide information about the accessibility of the products and services you sell, when the responsible economic operator supplies that information. And when identification, security, and payment functions are delivered as part of your service, they have to be perceivable, operable, understandable, and robust in their own right (accessible.org). In plain terms: a screen-reader user has to be able to complete a purchase and pay for it, not just reach the cart.

The EAA e-commerce compliance checklist

Work through this in order. It maps the general WCAG 2.1 AA bar onto the parts of a store that actually break, then adds the e-commerce-specific and administrative duties.

The buying journey (WCAG 2.1 AA across every step):

  • Product listings and filters: every product image has meaningful alt text; filter controls are real, labelled form elements a keyboard can reach and operate.
  • Product detail pages: price, variants, and stock status are conveyed in text, not colour alone; size and colour pickers have visible labels and clear focus states.
  • Search: the search field has a label, results are announced, and "no results" is text a screen reader reads out.
  • Cart: quantity steppers, remove buttons, and totals are keyboard-operable and labelled; updates are announced rather than silently changing on screen.
  • Account and login: form fields have persistent labels, errors say what went wrong and how to fix it, and any CAPTCHA offers a non-visual alternative.
  • Checkout and payment: the full flow works with a keyboard and a screen reader, error messages are tied to the right field, and time limits can be extended. This is where Section IV bites: payment cannot be a visual-only step.
  • Structure and media: headings are ordered, the page has one clear language, and any video has captions.

E-commerce-specific duties (Annex I Section IV):

  • Surface accessibility information about products where the manufacturer provides it.
  • Confirm identification, security, and payment steps are independently perceivable, operable, understandable, and robust (accessible.org).

Administrative duties:

  • Publish an accessibility statement describing how the service meets the requirements, known limitations, and a plan to fix them.
  • Offer at least one accessible support channel where customers can ask questions or report a barrier.
  • Keep the evidence: audit results, a remediation log, and a record of what has been tested.

How do I verify my store meets the requirements?

Start with an automated scan, then finish by hand, because automation only reaches part of the picture. Deque's analysis of more than 2,000 audits found automated testing identified about 57% of issues by volume, and estimates based on the share of WCAG success criteria a scanner can even evaluate put the figure closer to 30% (Deque). A scanner is good at the high-frequency, machine-detectable failures: missing alt text, low contrast, unlabelled form fields, missing page language, duplicate IDs. Those are common on product pages, so a scan is a strong first pass.

What a scanner cannot judge is whether the checkout flow works. Only a person testing with a keyboard and a screen reader can confirm that focus order makes sense, that a payment error is announced, or that alt text is meaningful rather than merely present. So the honest process is: scan your key templates to clear the machine-detectable issues, then run a manual pass on the transactional flow with real assistive technology. Our WCAG checklist tool tracks against 2.1 AA and separates the automated checks from the ones that need a human.

A note on claims. No scanner and no overlay widget can confirm WCAG conformance on its own, and saying otherwise is what earned the overlay vendor accessiBe a $1 million order from the US Federal Trade Commission for representing that its product made websites WCAG compliant (FTC). Automation finds issues; a person confirms conformance.

What about the accessibility statement?

For a covered service, the statement is not optional. The EAA expects service providers to explain how the service meets the accessibility requirements, and this is one of the more common gaps regulators point to. A useful statement names the standard you are working to (EN 301 549 / WCAG 2.1 AA), records your current conformance honestly, lists known limitations, gives a timeline for fixes, and provides a contact for reporting problems. EN 301 549 Annex C gives a clause-by-clause template you can use to mark each requirement met, partially met, or not met, which is the natural backbone of the statement. If you want a starting draft, our accessibility statement generator builds one from your scan results that you then review and finish.

Frequently asked questions

Does the EAA apply to my online store?

Most likely, if you sell to consumers in the EU. The EAA lists e-commerce as a covered service and applies by market, so non-EU stores selling into the EU are included. The main exception is a microenterprise providing a service: fewer than 10 people and turnover or balance sheet of €2 million or less.

What standard does an e-commerce site have to meet?

For the web, WCAG 2.1 Level AA, because that is the bar built into EN 301 549 v3.2.1, the harmonised standard the EAA relies on. Meeting the relevant EN 301 549 clauses gives a presumption of conformity with the law.

What is the deadline for EAA e-commerce compliance?

The EAA has applied since 28 June 2025. There is no separate later deadline for e-commerce; the obligation is already live for businesses in scope.

Do I need an accessibility statement for my shop?

Yes, if you are a covered service provider. You must publish a statement describing how the service meets the requirements and offer an accessible way for customers to report problems.

Can an automated scanner prove my store is compliant?

No. Automated tools catch roughly 30–57% of issues, mostly the machine-detectable ones. Confirming the checkout and payment flow works needs manual testing with a keyboard and a screen reader.

Check your store against the standard

The practical first move is to measure your key templates (a product page, the cart, and checkout) against WCAG 2.1 AA, since that is the bar EN 301 549 sets for the web. Run a free scan to surface the machine-detectable issues, then work through the manual checks for what a scanner cannot judge. You will have a real baseline and the evidence to write an honest accessibility statement instead of a guess.

Pavel Charkasau, founder, wcagc.com. Last updated 2 July 2026.

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