European Accessibility Act checklist for small online shops
Updated 2026-10-24 · Altlark guides
The European Accessibility Act (EAA) is an EU directive, Directive (EU) 2019/882, on accessibility requirements for certain products and services. E-commerce is one of the services it covers. If you run an online shop that sells to consumers in the EU, this page summarizes what the directive itself says, with article references, and turns it into a practical checklist for your website.
It's a summary, not legal advice. The EAA is a directive, which means each EU country applies it through its own national law, and the details (who enforces it, how, and any penalties) are set nationally. Check the law of the countries you sell into, and talk to a lawyer for decisions about your business.
Last checked against the directive text: October 24, 2026.
Key dates
- Member States had to adopt their national laws by 28 June 2022 and apply them from 28 June 2025 (Article 31).
- The directive applies to covered services provided to consumers after 28 June 2025 (Article 2(2)).
- Transitional period (Article 32): until 28 June 2030, service providers may keep providing services using products they lawfully used before that date, and service contracts agreed before 28 June 2025 may continue unchanged until they expire, but no longer than five years from that date.
Does it apply to my shop?
E-commerce services are defined (recital 42 and Article 3) 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. Recital 43 says the e-commerce obligations apply to the online sale of any product or service.
The microenterprise exemption (Article 4(5)): "Microenterprises providing services shall be exempt" from the service accessibility requirements and related obligations. A microenterprise is defined in Article 3(23) as an enterprise that employs fewer than 10 persons and has an annual turnover not exceeding EUR 2 million or an annual balance sheet total not exceeding EUR 2 million. Article 4(6) asks Member States to provide guidelines and tools for microenterprises. Note that the exemption is for microenterprises providing services; it doesn't cover products.
Disproportionate burden (Article 14): the requirements apply only to the extent they don't require a fundamental alteration of the service or impose a disproportionate burden. Businesses that rely on this must carry out and document an assessment using the criteria in Annex VI.
If you're not sure whether you're in scope, that's a question for the national law and your lawyer. Even if you're exempt, the checklist below is still good practice: these are barriers that stop real customers from buying.
What the directive requires of websites and shops
The requirements for services are in Annex I.
All covered services (Annex I, Section III) include, among other things, providing information about how the service works in accessible ways, and "making websites, including the related online applications, and mobile device-based services, including mobile applications, accessible in a consistent and adequate way by making them perceivable, operable, understandable and robust."
Additional requirements for e-commerce (Annex I, Section IV):
- providing information about the accessibility of the products and services being sold, when the responsible economic operator provides that information;
- making the functionality for identification, security and payment accessible (perceivable, operable, understandable and robust) when delivered as part of the service;
- providing identification methods, electronic signatures and payment services that are perceivable, operable, understandable and robust.
Information obligations (Article 13 and Annex V): service providers must prepare information explaining how their services meet the accessibility requirements, make it available to the public in written and oral format (including in an accessible way), and include it in their general terms and conditions or an equivalent document. Annex V lists the elements: a general description of the service in accessible formats, explanations needed to understand how it operates, and a description of how the relevant Annex I requirements are met. Annex V also says providers may apply harmonised standards and technical specifications whose references are published in the Official Journal of the EU.
Keeping it up (Article 13(3)): providers must have procedures in place so the service stays in line with the requirements as it changes.
"Perceivable, operable, understandable and robust" are also the four principles that structure WCAG. The directive's articles don't name WCAG directly, but WCAG is the most widely used practical reference for making a website meet those four principles.
Practical checklist for a small online shop
Product pages
- Product images have alt text that describes what matters (color, style, what's included). See missing alt text on linked images for linked thumbnails.
- Size, color and variant pickers are real form controls with labels, not unlabeled divs. See missing form labels.
- "Add to cart", wishlist and quantity +/- buttons have names. See empty buttons.
- The page declares its language, and each language version declares its own. See missing html lang.
Navigation and search
- Icon links (cart, account, search) have names. See empty links.
- The search field has a label.
- Headings follow a logical order. See skipped heading levels.
Checkout and payment
- Every field (name, address, card, discount code) has a label, and errors are described in text, not only with red borders.
- You can complete checkout with a keyboard alone.
- Embedded payment and identity frames have titles (see iframe titles), and you've asked your payment provider what they've done to meet the directive's payment requirements.
Information
- An accessibility statement or section in your terms that describes your service and how it meets the requirements, as Article 13 and Annex V describe.
- A way for customers to reach you if something doesn't work for them.
Ongoing
- Re-check after theme updates, new apps or plugins, and seasonal redesigns.
Example: a variant picker and an add-to-cart button
Theme code like this is common, and it fails several of the items above at once:
<div class="swatches">
<span class="swatch" data-value="red" style="background:#c00"></span>
<span class="swatch" data-value="blue" style="background:#00c"></span>
</div>
<input type="number" name="qty" value="1">
<button class="add"><svg><use href="#icon-cart"/></svg></button>The swatches can't be reached by keyboard and have no names, the quantity field has no label, and the button is empty. A fixed version uses native controls:
<fieldset>
<legend>Color</legend>
<label><input type="radio" name="color" value="red"> Red</label>
<label><input type="radio" name="color" value="blue"> Blue</label>
</fieldset>
<label for="qty">Quantity</label>
<input type="number" id="qty" name="qty" value="1" min="1">
<button type="submit" class="add">
<svg aria-hidden="true" focusable="false"><use href="#icon-cart"/></svg> Add to cart
</button>You can still style the radio buttons as color swatches with CSS; the point is that the underlying controls are real, labeled and keyboard-operable.
How Altlark helps (and where it stops)
The free scan checks one page of your shop for common issues in the server HTML: missing alt text, empty links and buttons, unlabeled fields, missing page language and title, heading problems, untitled iframes and autoplaying media. Run it on your home page, a product page and your cart. Monitoring rescans up to 100 pages a day and emails you when new issues appear, which catches regressions after updates.
Automated checks find some, not all, issues. They can't judge alt text quality, color contrast, keyboard access, or checkout steps rendered by JavaScript. A clean scan is a good start, not a conclusion about the law.