The European Accessibility Act: who it binds, what it asks for, and what a business can be asked to show.

The Act applies to a list of services provided to consumers after 28 June 2025, and e-commerce is the last service on that list.

the following services provided to consumers after 28 June 2025 Article 2(2) and 2(2)(f), 17 April 2019.

An e-commerce service is one provided at a distance, through a website or an app, at the consumer's request, in order to conclude a consumer contract. A shop that sells online is one.

with a view to concluding a consumer contract Article 3(30), 17 April 2019.

What matters is where the consumer is, not where the seller is. A service provider under the Act is anyone who provides a service on the Union market or offers one to consumers in the Union.

makes offers to provide such a service to consumers in the Union Article 3(4), 17 April 2019.

A consumer is a natural person acting outside their trade, business, craft or profession. A shop that sells only to other businesses is not providing a service to consumers.

purposes which are outside his trade, business, craft or profession Article 3(22), 17 April 2019.

The Act also covers a list of products placed on the market after 28 June 2025: consumer computers and their operating systems, self-service terminals such as payment terminals and ticket machines, phones and other consumer terminal equipment, and e-readers.

products placed on the market after 28 June 2025 Article 2(1), 17 April 2019.

Some content on a website is outside the Act: recorded video and office documents published before 28 June 2025, some online maps, archives not updated after that date, and third-party content that the site neither funds, develops nor controls.

third-party content that is neither funded, developed by, or under the control Article 2(4), 17 April 2019.

The Act's own recitals say why online shops are on the list: the Directive was written to include obligations for e-commerce websites.

this Directive includes obligations to ensure that e-commerce websites are accessible Recital 35, 17 April 2019.

Every service in scope must meet the accessibility requirements in Annex I of the Act: the general requirements for services in Section III and the service-specific ones in Section IV.

services shall comply with the accessibility requirements set out in Section IV of Annex I Article 4(3), 17 April 2019.

For websites and apps the general requirement is the four words that WCAG is built on: the site must be perceivable, operable, understandable and robust. The Act does not name WCAG or any standard in its text.

accessible in a consistent and adequate way by making them perceivable, operable, understandable and robust Annex I, Section III(b), 17 April 2019.

Online shops carry three requirements of their own: pass on the accessibility information about the products they sell where the maker supplies it, make sign-in, security and payment accessible, and make identification methods, electronic signatures and payment services perceivable, operable, understandable and robust.

ensuring the accessibility of the functionality for identification, security and payment Annex I, Section IV(g), 17 April 2019.

A service provider must explain, in writing, how the service meets the requirements, make that explanation public in an accessible form, and keep it for as long as the service runs.

shall explain how the services meet the applicable accessibility requirements Article 13(2), 17 April 2019.

That explanation goes in the general terms and conditions or an equivalent document: a general description of the service in accessible formats, what a person needs to know to use it, and how each requirement in Annex I is met.

in the general terms and conditions, or equivalent document Annex V, 17 April 2019.

A provider that finds its service does not conform must take corrective measures and tell the authorities of every member state where it provides the service.

shall immediately inform the competent national authorities of the Member States Article 13(4), 17 April 2019.

On a reasoned request from an authority, a provider must hand over everything needed to demonstrate that the service conforms, and cooperate with whatever the authority does next.

all information necessary to demonstrate the conformity of the service Article 13(5), 17 April 2019.

Each member state must set up procedures to check that services comply, to follow up complaints, and to verify that a provider has taken corrective measures, and must name the authorities that do this.

check the compliance of services with the requirements of this Directive Article 23, 17 April 2019.

Products are policed by market surveillance authorities under the EU's general market surveillance rules.

of Regulation (EC) No 765/2008 shall apply to products Article 19(1), 17 April 2019.

In Ireland the Competition and Consumer Protection Commission is the authority for e-commerce services.

Competition and Consumer Protection Commission S.I. No. 636/2023, Regulations 3(2)(g) and 4, 12 December 2023.

In the Netherlands the consumer and markets authority supervises online shops under the Act. In March 2026 it reported that on 61 of the roughly 100 largest Dutch webshops a customer using assistive technology could not complete an order.

61 procent van de grootste Nederlandse webwinkels niet digitaal toegankelijk is Autoriteit Consument en Markt, news release, 24 March 2026.

The Act sets no fine of its own. Each member state sets penalties, which must be effective, proportionate and dissuasive, and must be accompanied by action to put the failure right.

The penalties provided for shall be effective, proportionate and dissuasive. Article 30, 17 April 2019.

Germany's act, the Barrierefreiheitsstärkungsgesetz, sets a fine of up to one hundred thousand euros for providing a service that does not meet the requirements, and up to ten thousand euros for lesser breaches such as failing to give information.

mit einer Geldbuße bis zu hunderttausend Euro BFSG § 37(2), 16 July 2021, as amended 6 May 2024.

Ireland's regulations make providing a non-conforming service an offence: on summary conviction a class A fine of up to five thousand euros or up to six months in prison, and on indictment a fine of up to sixty thousand euros or up to eighteen months.

a fine not exceeding €60,000 or to imprisonment for a term not exceeding 18 months S.I. No. 636/2023, Regulation 32, 12 December 2023.

Spain's act refers breaches to sectoral law and, failing that, to the general disability rights law, whose scale runs from 301 euros to one million euros.

desde un mínimo de 301 euros hasta un máximo de 1.000.000 de euros Real Decreto Legislativo 1/2013, Article 83, 29 November 2013, consolidated text.

A microenterprise that provides services is exempt from the requirements altogether. This exemption is for services only.

Microenterprises providing services shall be exempt from complying with the accessibility requirements Article 4(5), 17 April 2019.

A microenterprise is a business with fewer than ten people and either an annual turnover or an annual balance sheet total of two million euros or less.

fewer than 10 persons and which has an annual turnover not exceeding EUR 2 million Article 3(23), 17 April 2019.

A microenterprise that makes or sells products is not exempt from the requirements. It is spared some paperwork: it need not document its assessment of disproportionate burden, though it must give the facts on request.

microenterprises dealing with products shall be exempted from the requirement to document their assessment Article 14(4), 17 April 2019.

A requirement does not apply where meeting it would change the basic nature of the product or service.

results in the fundamental alteration of its basic nature Article 14(1)(a), 17 April 2019.

A requirement also does not apply where meeting it would be a disproportionate burden, judged against the criteria in Annex VI. The assessment must be written down and kept for five years, and it cannot be claimed by a business that took outside funding to improve accessibility.

keep all relevant results for a period of five years Article 14(1)(b), 14(3) and 14(6), 17 April 2019.

A service may keep using products it lawfully used before 28 June 2025 until 28 June 2030, and a service contract agreed before that date may run unaltered until it ends, for up to five years.

a transitional period ending on 28 June 2030 during which service providers may continue Article 32(1), 17 April 2019.

A member state may let a self-service terminal that was in use before 28 June 2025 stay in use to the end of its economic life, for up to twenty years.

until the end of their economically useful life, but no longer than 20 years Article 32(2), 17 April 2019.

The one formal conformity instrument in the Act, the EU declaration of conformity with the CE marking, applies to products, and it is the manufacturer's own declaration.

the manufacturer shall assume responsibility for the compliance of the product Article 16(4), 17 April 2019.

A product or service that meets a harmonised standard cited in the Official Journal is presumed to meet the requirements the standard covers.

shall be presumed to be in conformity with the accessibility requirements of this Directive Article 15(1), 17 April 2019.

The European standard for digital accessibility is EN 301 549. Its version 3.2.1, from March 2021, is built on WCAG 2.1.

The present document reflects the content of the W3C WCAG 2.1 Recommendation ETSI EN 301 549 V3.2.1, Introduction, March 2021.

A new version, 4.1.1, adopted on 24 August 2026 and published in September 2026, was written for this Act and is built on WCAG 2.2.

updated to align with the WCAG 2.2 recommendation ETSI EN 301 549 V4.1.1, Foreword, September 2026.

As of the date this page was last checked, no version of the standard had been cited in the Official Journal under this Act, so the presumption of conformity is not yet available and the reference in use remains version 3.2.1.

the new version is not yet the legal reference standard AccessibleEU Centre (European Commission), news, 7 September 2026.

Germany's act puts the explanation of how a service meets the requirements in the provider's terms and conditions or somewhere equally visible, and adds the name of the competent market surveillance authority to it.

in seinen Allgemeinen Geschäftsbedingungen oder auf andere deutlich wahrnehmbare Weise BFSG Anlage 3, 16 July 2021.

Member states had to write the Act into national law by 28 June 2022.

adopt and publish, by 28 June 2022, the laws, regulations and administrative provisions Article 31(1), 17 April 2019.

Those national laws apply from 28 June 2025.

They shall apply those measures from 28 June 2025. Article 31(2), 17 April 2019.