The European Accessibility Act never uses the word "marketplace". It covers "e-commerce services", which Article 3(30) of Directive (EU) 2019/882 defines as services provided at a distance, through websites and mobile apps, "with a view to concluding a consumer contract". A multi-vendor platform fits that definition, and recital 43 says the e-commerce obligations "should apply to the online sale of any product or service". So for EAA marketplace compliance, the useful question isn't whether the act applies. It's who owns which part of the page. My reading of the text: the operator owns the interface it builds and runs (search, product page template, cart, checkout, account, payment, the seller listing form). Business sellers own what they upload and, on at least one major platform, are asked for their own accessibility statement. The operator also has to pass on product accessibility information when a seller or manufacturer supplies it. Below is that split clause by clause, with the open parts marked as open. It's a reading of the text, not legal advice.
Does the EAA apply to online marketplaces?
Yes, as an e-commerce service, from 28 June 2025. Article 2(2)(f) lists "e-commerce services" among the services the directive covers when they are provided to consumers after that date (Directive (EU) 2019/882, Art. 2).
Recital 42 explains the definition: "at a distance" means the parties aren't simultaneously present, and the service runs on electronic means at the consumer's request (Directive (EU) 2019/882, recitals). None of that depends on who owns the stock. A marketplace that lets an EU consumer search, compare and buy is providing that service whether it sells its own goods or someone else's.
The definition is about consumers, though. A wholesale platform that only sells to registered businesses sits outside the "consumer contract" wording, and that's a separate scope question.
What is the marketplace operator responsible for?
Everything the operator designs and runs. Article 13(1) says "service providers shall ensure that they design and provide services in accordance with the accessibility requirements of this Directive". On a marketplace, the operator designs the service. Sellers fill in fields; they don't build the checkout.
In practice that means the operator answers for:
- the search, filters and category pages
- the product page template (gallery, variant pickers, price, the "add to basket" button)
- cart, checkout, login, account and order history
- the payment, identification and security steps, which Annex I, Section IV(g)(ii) and (iii) name directly (Directive (EU) 2019/882, Annex I)
- seller-facing tools that shape what buyers see, such as the listing form
The checkout point needs underlining. Most marketplaces route payments through a provider, and some use a separate identity service. Recital 20 says that when "a service, or part of a service, is subcontracted to a third party, the accessibility of that service should not be compromised". So a payment iframe that traps keyboard focus is the operator's problem, even if the operator didn't write a line of it. We went through the payment step in detail in checkout accessibility under the EAA.
WCAG makes the same point from the other side. Its conformance requirement 5.2.3 on complete processes says that if one page in a process fails, the whole process does (W3C WCAG 2.2, 5.2.3). For a marketplace the process runs from search results to the order confirmation. A seller's listing sits in the middle of it.
What do sellers on a marketplace have to do?
Here the directive is quieter, so I'll stick to what's in the text and what one large platform tells its sellers.
The text first. Article 2(4)(d) excludes "third-party content that is neither funded, developed by, or under the control of, the economic operator concerned" (Directive (EU) 2019/882, Art. 2(4)). From the operator's side, a seller's photos and description are often exactly that. From the seller's side they're the seller's own content, and the exemption doesn't help. We covered where that line falls in the EAA and third-party content.
Whether a seller on someone else's platform is itself a "service provider" with its own Article 13 duties isn't spelled out. Platforms have had to pick an answer anyway. eBay's EAA page for sellers tells relevant business sellers to add an accessibility statement to their account, to include accessibility information in listings when a manufacturer or another party in the supply chain has shared it, and to present certain product details in an accessible format. It also says listings that miss required information may be hidden from EU buyers until it's added (eBay Seller Centre). That's one platform's approach, and eBay says plainly it can't give legal advice, but it's a concrete picture of how the split is working in practice.
If a seller sells physical products that are themselves in scope (e-readers, smartphones, computers), product rules apply too. A seller who makes those available on the EU market is usually a distributor or importer under Article 3, and Article 10 gives distributors their own checks before selling.
How does Annex I Section IV(g) work on a multi-vendor site?
Point (g)(i) is the clause that most clearly involves both parties. It requires e-commerce services to provide "the information concerning accessibility of the products and services being sold when this information is provided by the responsible economic operator" (Directive (EU) 2019/882, Annex I).
Read it as a pipe. The manufacturer or seller has the information. The marketplace has the page. If the listing form has nowhere to put "screen reader compatible: yes, VoiceOver and TalkBack" or "large-print manual included", the information has no way to reach the buyer, and the operator can't meet (g)(i) for any listing. So the minimum operator-side fix is a structured accessibility field in the listing schema, shown on the product page in text a screen reader can reach (not only as an icon).
| Duty | Who usually holds it | Where it shows up |
|---|---|---|
| Accessible search, product template, cart, checkout | Operator | Art. 13(1); Annex I, Section IV(g)(ii)–(iii) |
| Payment, login and identification steps | Operator, even when a vendor supplies them | Annex I, Section IV(g)(ii)–(iii); recital 20 |
| A place to publish product accessibility information | Operator | Annex I, Section IV(g)(i) |
| Supplying that information | Seller or manufacturer | Annex I, Section IV(g)(i), "when this information is provided" |
| Alt text and accessible descriptions in listings | Seller writes; operator's form decides whether it's possible | WCAG 2.2, 1.1.1; WCAG 5.4 for uncontrolled content |
| Accessibility statement for the service | Operator; some platforms also ask business sellers | Art. 13(2), Annex V |
Can a small seller or a small marketplace be exempt?
Sometimes. Article 4(5) says microenterprises providing services "shall be exempt from complying with the accessibility requirements" for services. Article 3(23) defines a microenterprise as fewer than 10 people and an annual turnover or balance sheet total not exceeding EUR 2 million (Directive (EU) 2019/882).
Two limits matter on a marketplace. A small seller's exemption doesn't cover the platform, because the operator is assessed on its own size. And the exemption is for services; product requirements still apply to the products themselves. eBay's seller page draws the same line (eBay Seller Centre). The full test is in the EAA microenterprise exemption, explained.
A larger operator that thinks a specific requirement is out of reach has Article 14 (disproportionate burden), but that route has to be assessed against Annex VI, documented, and kept for five years. Recital 66 says "lack of priority, time or knowledge" doesn't count.
How should a marketplace handle seller-uploaded content?
Control the form, then monitor what comes through it. My opinion, plainly: the listing form is the most important accessibility control a marketplace owns. If alt text is an optional field hidden under "advanced", most product images will go up without it, and no amount of scanning afterwards will fix that.
WCAG gives you two honest options for content you don't author. Under section 5.4, you can monitor the page and repair or remove non-conforming contributed content "within two business days", or you can publish a statement of partial conformance: "This page does not conform, but would conform to WCAG 2.2 at level X if the following parts from uncontrolled sources were removed" (W3C WCAG 2.2, 5.4). A marketplace with thousands of new listings a day will live mostly in the first option, with a moderation queue that flags images missing alt text and descriptions pasted in as a single image.
Concretely, that means the image upload asks for a description per image, the description editor only allows real headings and lists (no colour-only "red = sold out" notes), and spec tables come out as an actual <table> with <th> cells rather than a screenshot.
How do you check a marketplace for EAA gaps?
Test templates and journeys, not individual listings. A marketplace may have a million product pages, but they come from a handful of templates. Scan a sample of each template, then walk the main purchase journey end to end.
Our free scan runs axe-core in a real browser and gives you the failing selector, so a finding like .variant-picker button with no accessible name points straight at the template. Be clear about what that gets you. Deque's analysis of more than 2,000 audits found automated testing identified about 57% of issues by volume, and around 30% when counted by WCAG success criteria (Deque). A scanner can tell you an image has no alt. It can't tell you that "IMG_4471.jpg" is a useless description, or that the variant picker announces "button, button, button" in NVDA. That part needs a person with a keyboard and a screen reader; our WCAG checklist lists the manual checks in order.
For the formal side, the harmonised standard is EN 301 549, whose web clauses map to WCAG. The accessibility statement guide covers what Annex V asks the operator to publish, and the statement generator gives a first draft you then edit with what you actually found.
Frequently asked questions
Does the European Accessibility Act apply to online marketplaces?
Yes, as an e-commerce service under Article 2(2)(f), for services provided to EU consumers after 28 June 2025. The directive doesn't use the word "marketplace", but its e-commerce definition covers any website or app used to conclude consumer contracts at a distance.
Is the marketplace or the seller responsible for EAA compliance?
Both, for different parts. The operator is responsible for the interface it designs and runs, including checkout and payment. Sellers are responsible for their own listing content and, on some platforms such as eBay, are asked to publish their own accessibility statement.
Do marketplace sellers need their own accessibility statement?
The directive doesn't answer this for sellers on someone else's platform. eBay asks relevant business sellers to add one to their account, and microenterprises are exempt from service requirements, including the statement.
Is a marketplace responsible for sellers' product images and descriptions?
Partly. Content a seller uploads can fall under the third-party exemption in Article 2(4)(d) from the operator's side, but the operator still controls the listing form and the page template, and must show product accessibility information when it's provided.
Can an automated scan confirm a marketplace meets the EAA?
No. A scan finds machine-detectable issues, roughly 30–57% depending on how you count, and manual testing with a keyboard and screen reader is still needed for full conformance.
Start with your templates
Pick one search page, one product page per template and the checkout, and run a free scan on each. You'll see which failures repeat across every listing, which is where a marketplace gets the most out of each fix.
Pavel Charkasau, founder, wcagc.com. Last updated 2 November 2026.
Sources
- Directive (EU) 2019/882 (European Accessibility Act), enacting terms, legislation.gov.uk: Art. 2(2)(f) and 2(4)(d), Art. 3(4), (20), (23), (30) definitions, Art. 4(5) microenterprise exemption, Art. 10 distributors, Art. 13 service providers, Art. 14 disproportionate burden. Accessed 2 November 2026.
- Directive (EU) 2019/882, recitals, legislation.gov.uk: recitals 20, 42, 43 and 66. Accessed 2 November 2026.
- Directive (EU) 2019/882, Annex I, legislation.gov.uk: Section IV(g) e-commerce requirements. Accessed 2 November 2026.
- Directive (EU) 2019/882 (official text), EUR-Lex: authoritative source for the above. Accessed 2 November 2026.
- The European Accessibility Act, eBay Seller Centre: eBay's guidance to business sellers. Accessed 2 November 2026.
- Web Content Accessibility Guidelines (WCAG) 2.2, W3C Recommendation, 12 December 2024: 5.2.3 complete processes, 5.4 statement of partial conformance for third-party content. Accessed 2 November 2026.
- Automated testing identifies 57% of accessibility issues, Deque: automated coverage figures. Accessed 2 November 2026.