European Accessibility Act 2025 – how to prepare for changes in the legislation?

Introduction

The new regulations will also extend to e-commerce – meaning that online shops will have to meet specific requirements for functionality, readability and usability. And while this may sound like just another formality, in reality we’re talking about a change that will affect both the design of interfaces and the structure of websites themselves – whether you’re running on WordPress, WooCommerce or another platform.

In this article, we’ll explain:

• what the European Accessibility Act actually is and why it also applies to small shops,
• which products and services the directive covers,
• what accessibility means in practice and how it relates to WCAG 2.1,
• how to prepare your online shop step by step – without panicking, but in advance.

Instead of treating these changes as a problem, it is worth seeing them as an opportunity – to improve the quality of the service, increase conversions and reach customers who may until now have hit invisible barriers.

Ready to get specific? Let’s start at the beginning.

European Accessibility Act - New developments

For years now, the European Union has been highlighting the problem of digital exclusion – a phenomenon that leaves part of the population without real access to online services, even if they are technically ‘public’ and accessible via the internet. The inability to navigate a website without using a mouse, the lack of image descriptions for screen readers, text contrast that is too low, forms that are impossible to fill in from the keyboard – all these exclude hundreds of thousands of users every day.

The European Accessibility Act is a response to these problems – but not only. It is also a step towards creating a coherent, single internal market, where every consumer has the same rights and opportunities, regardless of the country they live in or the device they use.

Importantly, the EAA is a directive that obliges businesses to act. It applies to private companies – those that are large, medium-sized, but to a selected extent also micro-enterprises. If you offer products or services in the sectors covered by the directive (online commerce, media, banking, transport, communications), you need to comply in order to be ready by June 2025.

But what exactly does ‘accessibility’ mean? What products and services does the EAA cover? Are there exceptions? What are the real consequences for companies that ignore the regulations? And most importantly – how do you implement the changes wisely, without chaos and profitably for your own business?

1.1 What does the EAA cover? – the scope of the directive in practice

The European Accessibility Act covers products and services that have been identified as being fundamental to the everyday functioning of citizens. Examples?

• e-commerce websites and applications
• payment terminals and ticketing machines,
• banking applications and transaction services,
• streaming platforms and audiovisual devices,
• e-books and digital readers,
• transport ticketing and reservation systems.

1.2 Who is directly affected by the EAA?

Four key groups are affected by the obligations:

• manufacturers – they must design hardware and software in accordance with the requirements,
• importers – they are responsible for the compliance of imported products,
• distributors – it is prohibited to offer products that do not meet the EAA requirements,
• service providers – i.e. companies operating online: from banks to shops and carriers.

1.3 Micro-entrepreneurs – do they have to comply too?

Yes, but to a limited extent. If you are a sole trader or employ fewer than 10 people and have a turnover of less than €2 million per year – you may be exempt from some of the documentation obligations. But you still need to ensure basic accessibility. Why?

• It’s a condition for customer trust.
• It’s a way to improve conversion.
• It’s a safeguard against negative feedback or complaints.

1.4 What are the objectives of the EAA – and what do they have to do with your business?

Although the EAA is a legal directive, its foundation is the logic of the available market:

• Levelling the playing field – everyone has the right to buy, watch, benefit.
• Increasing competitiveness – companies compete fairly, on a level playing field.
• Removing digital barriers – accessibility is not a luxury, it is the norm.
• Facilitate development – instead of having to adapt to different national regulations, companies can create a single, unified EAA-compliant system.

Why is digital accessibility a necessity today?

Until a few years ago, the topic of digital accessibility mainly appeared in the context of public institutions and administrative duties. Today, it has become an integral part of the strategy of any company that plans to grow in the digital space – especially in e-commerce. Regulation is keeping pace with real market needs.

The modern customer expects not only aesthetics and functionality, but also accessibility – i.e. the ability to use a website or application in a simple, intuitive way and without technical limitations. For many users, this is an absolute necessity, not a preference. The inability to operate a shop without the use of a mouse, a lack of contrast or an unadapted interface all cause the user to leave the site and look for an alternative.

In this sense, accessibility is no longer an optional feature – it is becoming a competitive standard.

2.1 Who really needs accessibility?

The group of users for whom digital accessibility is crucial is much larger than many businesses assume:

• people with sensory disabilities (blind, visually impaired, deaf),
• people with motor limitations (e.g. without the ability to use a mouse),
• senior citizens,
• people with cognitive impairments (e.g. dyslexia, ADHD, autism),
• mobile users in difficult conditions – e.g. on the move, on a poor connection, with a small screen.

In the European Union alone, there are more than 87 million people with various types of disabilities. This is a huge customer segment that is often overlooked in the design of digital platforms. Taking their needs into account is not only a social responsibility, but also a purely business decision.

2.2 Better accessibility = better UX

Designing for accessibility benefits all users – not just those using assistive technologies. A simple interface, clear navigation, unambiguous messages and forms make it easier for any user to use the site – regardless of their age, experience or level of technological literacy.

Research shows that companies that have implemented digital accessibility principles:

• record an average 20% increase in conversions,
• reduce cart abandonment by up to 25%,
• improve site dwell time and return visitor rates.

2.3 Accessibility influences SEO and web visibility

A website’s compliance with WCAG 2.1 standards translates directly into better search engine optimisation. Accessible pages are better indexed by search engines because they contain:

• a logical heading structure,
• alternative descriptions (alt text) for images,
• semantic HTML code,
• well structured forms and interactive elements.

As a result, accessibility is not only a compliance issue, but also a factor supporting organic traffic and the effectiveness of marketing campaigns

Products and services covered by the EAA - what do you need to adjust?

The European Accessibility Act (EAA) indicates precisely which categories of products and services are subject to accessibility obligations. This list is not generic – it is a closed catalogue covering technologies, devices and services that are key to functioning in the digital society.

3.1 Products covered by the EAA

The following devices and technologies must be accessible to users with various functional limitations:

(a) Computer hardware and operating systems

• Operation without mouse (keyboard navigation),
• Compatibility with screen readers,
• Ability to zoom in on content and change contrast,
• Interfaces compatible with assistive devices (e.g. voice control, motion switches).

b) Mobile devices (smartphones, tablets)

• Voice control and zoom functions,
• Possibility to change the interface layout,
• Support for system accessibility standards (VoiceOver, TalkBack).

c) Self-service terminals

• ATMs, ticket machines, info kiosks, payment terminals:
• High-contrast touchscreens,
• Speech synthesisers,
• Braille keypads,
• Physical accessibility for wheelchair users.

d) E-book readers

• Change of font size and contrast,
• Possibility to change background colours and text,
• Text-to-speech (TTS) conversion function,
• Compatibility with external assistive technologies.

e) Consumer electronics

• Televisions, set-top boxes, media players:
• Ability to include subtitles and audiodescription,
• Intuitive operation of accessible functions (e.g. subtitle menu),
• Adaptation to the use of alternative remote controls.

3.2 Services covered by the EAA directive

The EAA also covers specific types of services that must be provided in a way that complies with accessibility requirements – in both web and mobile versions.

a) E-commerce

• Online shops, marketplaces, B2B platforms:
• WCAG 2.1 (level AA) compliant websites and applications,
• Support for screen readers,
• Alternative image descriptions (alt text),
• Mouse-free navigation (keyboard, switches),
• Text and button contrast min. 4.5:1,
• Forms compatible with assistive technologies

b) Retail banking services

• Transaction services, mobile applications of banks:
• Clear, accessible interfaces (e.g. font magnification),
• Text or video chat contact options with PJM translator,
• Reader-readable information on financial products and operations.

c) Telecommunications

• Network operators, Internet providers:
• WCAG-compliant customer portals and applications,
• Accessible helpline (e.g. alternative written form),
• Invoices and regulations in readable format.

d) Media and audiovisual services

• VOD services, TV stations, streaming portals:
• Mandatory subtitling and audiodescription of content,
• Possibility to adjust these features from the interface,
• Alternative programme information.

e) Passenger transport

• Railways, airlines, road and water transport operators:
• WCAG-compliant ticket booking sites,
• Passenger information in text and audio versions,
• Possibility to purchase tickets and use information in a form accessible to people with visual and hearing impairments.

3.3 Technical scope of requirements – common features

Although the products and services are different, the EAA Directive imposes the following common requirements on all:

• Interfaces must be intuitive, logical and predictable,
• Operation must be possible without the use of sight, hearing or precise movements,
• Content must be perceivable, understandable and operable,
• Systems must be compatible with screen readers, TTS, alternative input devices.

WCAG 2.1 - Technical foundation for digital accessibility

The European Accessibility Act (EAA) for websites and mobile applications explicitly refers to the WCAG 2.1 standard, the Web Content Accessibility Guidelines, a set of international guidelines developed by the W3C consortium. WCAG sets out principles for designing and coding digital content so that it is accessible to all users, regardless of disability.

For e-commerce, this means that every shop page, mobile app, contact form, shopping interface or promotional banner must comply with specific requirements in accordance with WCAG 2.1 at level AA – the level required by the EAA as a minimum standard.

4.1 WCAG 2.1 structure – the four accessibility principles

The WCAG 2.1 guidelines are organised around four fundamental principles, defining what it means for digital content to be accessible:

(a) Perceivability (Perceivable)

Information and interface elements must be presented in a way that they can be perceived by at least one sense.

Requirements:

• Alt text for images,
• Subtitles and audiodescription for videos,
• Structured hierarchy of headings (H1-H6),
• Clear text and background contrast,
• Text can be resized by min. 200% without loss of content.

b) Functionality (Operable)

The user must be able to operate all the functions of the interface – irrespective of the device used or mobility restrictions.

Requirements:

• Full keyboard operation,
• Avoidance of flashing content (e.g. flashes more than 3 times per second),
• Clear indication of the current focus (e.g. illumination of the active button),
• Ability to skip repeated blocks (skip links),
• Consistent navigation throughout the site.

c) Understandable

Both the content and the way of interaction must be logical and predictable for the user.

Requirements:

• Clear, simple message language,
• Labels and instructions for each form,
• Error messages and suggestions for their correction,
• Consistency of page structure and interfaces (e.g. the same button always works the same way).

d) Robustness

Content must be technically correct and compatible with a wide range of assistive technologies – current and future.

Requirements:

• Correct HTML semantics,
• Use of ARIA attributes if dynamic components require them,
• Avoidance of code validation errors,
• Compatibility with screen readers and alternative access technologies.

4.2 WCAG compliance levels – what do you need to implement?

The WCAG guidelines are divided into three levels of compliance:

• Level A – minimum compliance (very basic accessibility),
• Level AA – mandatory compliance level required by the EAA,
• Level AAA – advanced level (recommended but not required).

Any company covered by the EAA must comply with at least Level AA. Implementation of this level includes, but is not limited to:

• an alternative description for each image,
• adequate colour contrast,
• accessibility of interfaces for users without the use of a mouse,
• forms with unambiguous messages,
• support by assistive technologies.

4.3 How to assess the compliance of an online shop with WCAG 2.1?

There are both automatic and manual methods for auditing compliance:

Automatic tools:

• WAVE – visual accessibility analysis (plugin and web),
• axe DevTools – developer tool for WCAG testing,
• Google Lighthouse – part of Chrome DevTools, accessibility + performance audit,
• Accessibility Insights – step-by-step audit from Microsoft.

Manual testing:

• Review of page performance using keyboard only (Tab/Shift+Tab),
• Simulation of the use of screen readers (NVDA, VoiceOver, TalkBack),
• Colour contrast analysis with WebAIM Contrast Checker,
• Checking of focus order and correctness of forms.

4.4 WCAG implementation in practice – what to look out for in e-commerce?

The most common elements that need to be adapted in online shops:

• Shopping buttons – must have unambiguous labels, appropriate contrast and visible focus,
• Product images – all must have an alt description, taking into account product features,
• Purchase and registration forms – easy to read, with error messages and helpful labels,
• Menus and navigation – keyboard-operable, without navigation traps,
• Dynamic content (pop-ups, slider) – ARIA compliant and can be handled without a mouse,
• Mobile applications – responsiveness, gesture support, TTS, correct focus order.

How to implement EAA in e-commerce - step by step

Adapting a sales platform to comply with the European Accessibility Act (EAA) requires a systematic approach, cross-departmental collaboration and knowledge of both technology and legislation. Below, I outline the complete process of an EAA-compliant e-commerce transformation – from analysis to implementation and maintenance.

5.1 Stage 1: Conducting an accessibility audit

The first step in the implementation process is a thorough analysis of the current state of the website or application for compliance with WCAG 2.1 and EAA requirements.

How to perform the audit?

• Use automated tools (WAVE, Lighthouse, axe DevTools),
• Hire an external auditing company specialised in digital accessibility,
• Conduct tests with people with different types of disabilities,
• Evaluate functionality using only the keyboard, screen readers and increased contrast.

What should the audit report contain?

• A list of barriers (e.g. lack of alt text, poor readability, navigation errors),
• Description of their impact on users,
• Recommendations for adaptation with prioritisation.

5.2 Stage 2: Drawing up an action plan and timetable

Based on the results of the audit, develop an implementation strategy – a document that identifies:

• which elements have the highest priority (e.g. homepage, shopping process, shopping cart),
• which actions can be implemented immediately (e.g. contrast improvement),
• which require more extensive redevelopment (e.g. navigation, source code),
• deadlines for completion of individual tasks,
• persons responsible for implementation (IT, UX, content, marketing).

5.3 Stage 3: Technical implementation of changes

This is the key moment to act in accordance with WCAG 2.1 – level AA.

Key technical actions:

• Adding alternative descriptions (alt text) to all graphics, banners and icons,
• Improving the structure of headings (H1-H6) and page titles,
• Providing keyboard navigation in all interactive elements,
• Changing the colour scheme and contrast to meet the 4.5:1 minimum,
• Modification of forms (labels, tips, error messages),
• Optimisation of HTML/CSS/JavaScript code for semantics and compatibility with screen readers,
• Improvement of the user interface (readability, predictability, repeatability).

For mobile applications:

• Support for TTS (Text-to-Speech),
• Logical focus order (e.g. “swipe”), correct button semantics,
• Clear typography and vertical and horizontal responsiveness.

5.4 Stage 4: Compliance testing after implementation

Once the changes have been implemented, a re-test of accessibility is required, which should include:

• Tests with real users – e.g. blind people, seniors, users with manual limitations,
• Manual tests (without mouse, with screen reader, with simulation of visual impairment),
• Code validation (HTML, CSS, ARIA) according to the latest W3C standards,
• Use of tools such as axe, WAVE, Lighthouse in a before/after comparison mode.

Objective: to confirm full compliance with WCAG 2.1 and effectiveness in user practice.

5.5 Stage 5: Team training and maintenance procedures

Even the best adapted website will not be available forever if you do not take care to maintain the standards. To this end, you should:

• train staff responsible for content, marketing, UX/UI, customer service and SEO,
• develop internal policies for content editing and interface design that are WCAG-compliant,
• implement procedures for reviewing and testing accessibility with each update or redesign,
• commission regular accessibility audits (e.g. quarterly or before each campaign).

5.6 Step 6: Informing users and documenting compliance

The EAA also requires transparency and the possibility for users to report barriers.

Care should be taken to:

• Visible information on the website about accessibility,
• A simple form to report inaccessibility,
• Technical documentation of accessibility (for auditors or supervisors),
• A link to an alternative version of the content (if present).

5.7 Financial support and external sources of assistance

Implementing an EAA is an investment, but there are tools that can facilitate it:

• Subsidies from EU programmes, e.g. European Funds for Digital Development,
• Support from PFRON (for companies employing people with disabilities),
• Support from platforms such as Shoper, which offer WCAG-compliant templates,
• Collaboration with accessibility experts (certified auditors, UX specialists).

Mistakes and consequences - what to avoid and why it's not worth the risk

Bringing a website or mobile app into compliance with the European Accessibility Act (EAA) requires not only knowledge, but also consistency and awareness. Unfortunately, many companies make repeated mistakes – due to oversights, misconceptions or a superficial approach to digital accessibility. Worse still, disregarding the EAA can lead to severe consequences – from financial penalties to the loss of the right to sell online.

6.1 The most common technical and design errors

(a) Lack of a full audit – ‘eye’ measures

Many companies limit themselves to a simple contrast test or checking alternative texts. Meanwhile, WCAG 2.1 compliance is more than 50 detailed criteria, failure to meet which can prevent the use of the site even in the simplest scenarios.

b) Incorrect or missing alt texts

Alternative description of graphics is essential – but many alts are too generic (‘product’), confusing (‘photo’) or do not exist at all. This is particularly problematic in shops where blind customers cannot understand what they are buying.

c) Lack of keyboard support for the interface

Mouse-only navigation is a major barrier for people with mobility impairments. Shops often do not test the functionality of forms, drop-down menus or shopping carts in keyboard mode.

d) Inappropriate form labelling

Data entry fields that do not have captions (e.g. “First name”, “Email address”) are not understood by screen readers. Lack of validation errors and suggestions for improvement are further oversights.

(e) Insufficient contrast

Light grey text on a white background, links in a colour that blends with the background – these are common problems in modern layouts. Insufficient contrast is not only an aesthetic problem – it is a violation of regulations.

f) Lack of repair after page updates

Even if accessibility has been implemented once, after implementing a new version of a site or updating an e-commerce platform, many companies forget to recheck compliance. Every change – in the template, code structure, plugins or content – can introduce new barriers. Therefore, accessibility is not a one-off project, but an ongoing process that requires constant monitoring.

6.2 Organisational and decision-making errors

a) Treating accessibility as an add-on

Some companies implement accessibility “at the end” – after the launch of the shop, after the publication of the campaign, after the design of the application. Meanwhile, accessibility should be an integral part of the UX/UI design and development process, not a fix to the finished product.

b) Lack of team involvement

Accessibility is not just a matter of code – it’s also about content, graphics, marketing, customer service. If only the IT department knows WCAG principles and the rest of the team does not – the results will be inconsistent. It is the team (content, UX, SEO, design, customer service) that is collectively responsible for accessibility standards.

c) Ignoring user feedback

Not having channels to report accessibility barriers is a serious mistake. People who encounter problems often want to report them. Many shops do not provide a contact form, do not provide text chat support or ignore reports – which can lead to official complaints and legal consequences.

6.3 Consequences of non-compliance with the EAA

The European Accessibility Act provides real sanctions for companies that do not bring their products and services into compliance:

(a) Financial penalties

The amount of the penalty is set by the national supervisory authorities (e.g. the President of PFRON in Poland). They can range from several thousand to hundreds of thousands of zlotys, and in Germany even up to €500,000. The penalties are proportionate to the scale of the infringement.

b) Cease and desist order

If an online shop does not meet the accessibility requirements, it can be blocked throughout the EU and the products offered withdrawn from the market until corrections are made.

c) Consumer complaints and lawsuits

Customers may report cases of inaccessibility to the relevant institutions, as well as file civil lawsuits – especially in cases of persistent obstruction of access to services.

d) Exclusion from public tenders and projects

Companies that do not comply with EAA standards cannot participate in public procurement, EU projects and programmes supporting digitisation.

e) Loss of reputation and customer confidence

In the age of social media and growing consumer awareness, lack of accessibility becomes an image blow. Companies that ignore the needs of people with disabilities are seen as negligent, archaic and socially irresponsible.

Tools, good practices and benchmarks - how to successfully implement EAA in e-commerce

Adapting an online shop to the requirements of the European Accessibility Act does not have to be a complicated process if you use the right methods, tools and experience of companies that have already carried out such implementation. Below, I present a compilation of practical solutions and best practices that will help you achieve EAA compliance and raise the accessibility standards of your e-commerce.

7.1 Tools to support digital accessibility

a) Automated testers and analysers

• WAVE (Web Accessibility Evaluation Tool) – free tool to analyse the structure of a website, detects missing alternative descriptions, incorrect headings, low contrast.
• Lighthouse (Google Chrome) – analyses the accessibility, performance and SEO of a website in a single report.
• axe DevTools (Deque Systems) – professional audit tool, ideal for testing source code against WCAG.
• Accessibility Insights – Microsoft tool with ‘FastPass’ mode for quick compliance testing.

b) Contrast checking tools

• WebAIM Contrast Checker – allows easy comparison of text and background contrast, in accordance with WCAG.
• Color Oracle – simulates colour vision disorders (daltonism, tritanopia) to optimise graphic design.

c) Functionality tests

• NVDA (NonVisual Desktop Access) – free screen reader for Windows,
• VoiceOver (Apple) – built-in screen reader for macOS and iOS,
• TalkBack (Android) – screen reader for Android mobile devices,
• Only Keyboard Navigation – testing the entire user path using only the keyboard.

7.2 Good design and implementation practices

a) Design with accessibility in mind from the outset (design for all)

Instead of improving the finished system, introduce accessibility principles at the interface design stage. This means:

• choosing contrasting colours with an appropriate luminance difference,
• clear and legible labels for fields, buttons and links,
• a logical structure of headings (H1, H2, H3…),
• appropriate positioning of form elements (label → input → error),
• legible, simple fonts without decoration (e.g. Arial, Open Sans, Roboto).

b) User testing

True accessibility is one that is confirmed by the user, not just an automated audit. Conduct tests with people:

• blind (e.g. using NVDA or VoiceOver),
• elderly
• with manual limitations (e.g. not using a mouse),
• with cognitive difficulties (e.g. memory problems, concentration).

c) Team training and knowledge updates

Invest in:

• WCAG and EAA training for the content team, marketing, IT, UX,
• workshops on designing accessible interfaces,
• accessibility certification for key staff,
• internal documentation with an accessibility checklist for each campaign.

d) Integration with accessibility platforms

If you use off-the-shelf e-commerce platforms (e.g. Shoper, WooCommerce, Shopify, PrestaShop), choose:

• WCAG 2.1 compliant themes,
• templates built in the “a11y-ready” standard,
• accessibility optimisation plug-ins (e.g. UserWay, accessiBe – with the proviso that these do not replace full implementation!).

7.3 Benchmarks and examples of companies that have implemented accessibility

a) Shoper

• Polish e-commerce platform integrated with WCAG 2.1,
• Templates accessible to people with visual and motion disabilities,
• Administration panel allows the addition of alt text, contrast options, optimisation for screen readers.

b) ING Bank Śląski

• One of the leaders in the implementation of digital accessibility in the financial sector,
• Mobile application and transaction service meets WCAG 2.1 requirements,
• Accessibility of communication (video with PJM interpreter, text chats).

c) Allegro

• Poland’s largest marketplace that systematically introduces accessibility solutions,
• Filters, forms, navigation – designed with the needs of users with disabilities in mind.

Summary - What you need to know and do before the EAA takes effect

Key findings of the article

The European Accessibility Act (EAA) is not just a new legal obligation – it is one of the most important pillars of a modern, responsible and scalable online business. Implementing digital accessibility principles:

• protects you from financial penalties and the blocking of your business,
• enables you to reach millions of new customers, including those from previously excluded groups,
• improves UX, SEO and conversion in the online shop,
• builds trust and the image of the company as socially responsible.

The upcoming changes require a real commitment – both technological and organisational. It is not about a one-off website modification, but a permanent standard of performance that will become a cornerstone in any modern e-commerce project.

Frequently asked questions (FAQ) – concisely and specifically

• Is a “WCAG compliant” template enough? No – this is just the starting point. Equally important is the content, the way the forms work, the accessibility of the shopping cart, the structure of the links, descriptions, navigation.
• How long does it take to implement EAA? It depends on the state of your current shop. On average: 2-8 weeks with the involvement of the team and an external auditor. For new shops – it is worth considering EAA right away.
• Does accessibility improve sales? Yes – statistically, companies with well implemented accessibility report a 20-25% increase in conversions, a decrease in cart abandonment and higher engagement.
• Is there funding for EAA implementation? Yes – from EU funds, PFRON and regional digital programmes, among others. It is worth consulting your funding advisor.

The European Accessibility Act is not a cost. It is an investment. Indevelopment, in quality, in trust and in customers who will finally be able to buy, watch and use without barriers.

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