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EAA Deadline is June 28, 2025: What EU Ecommerce Stores Must Do Now

14 April 2025 7 min readUpdated 18 April 2026

The European Accessibility Act (EAA) — Directive 2019/882 — requires ecommerce services operating in the EU to meet WCAG 2.1 Level AA accessibility standards. The compliance deadline is June 28, 2025. This is not a soft launch: member states have been required to implement enforcement mechanisms since 2022, and the first complaints are expected within weeks of the deadline.

Who must comply

The EAA applies to "ecommerce services" — which the directive defines broadly to include any website or app through which consumers can purchase products or services. If your store sells to EU consumers, you must comply regardless of where your business is registered.

There is a temporary exemption for microenterprises (fewer than 10 employees and annual turnover below €2 million), but this exemption is narrow and applies only to services — not to products themselves.

What WCAG 2.1 AA requires in practice

WCAG 2.1 Level AA covers four areas — Perceivable, Operable, Understandable, and Robust. For ecommerce stores, the most commonly violated requirements are:

  • Images need descriptive alt text. Every product image, banner, and UI icon must have alt text that conveys meaning. Decorative images use empty alt="" — but product images must describe what is shown.
  • Text must meet 4.5:1 contrast ratio. Grey text on white backgrounds is a widespread failure. Test every text/background combination with a contrast checker. Large text (18pt or 14pt bold) requires only 3:1.
  • Forms must have visible labels. Placeholders that disappear when typing are not labels. Every input field, including checkout fields, must have a persistent label.
  • The whole site must be keyboard navigable. Users who cannot use a mouse must be able to browse products, add to cart, and complete checkout using keyboard only. Test by pressing Tab through every page.
  • The page language must be declared. <html lang="en"> or the equivalent in the store's language. This is a one-line fix but extremely common WCAG failure.
  • Pinch-to-zoom must not be disabled. Remove user-scalable=no from any viewport meta tags. Zoom is essential for low-vision users.

Enforcement and penalties

Each EU member state designates its own enforcement authority. Some notable examples:

  • Germany: State consumer protection offices and the Bundesnetzagentur. Fines under the BITV 2.0 can reach tens of thousands of euros.
  • France: DGCCRF (Direction Générale de la Concurrence) enforces accessibility requirements. Up to €25,000 per violation.
  • Spain: AEPD (Agencia Española de Protección de Datos) and sector-specific regulators. Fines up to €300,000.
  • Netherlands: ACM (Autoriteit Consument & Markt). Up to €900,000 per violation for serious cases.

In addition to regulatory fines, the EAA creates private enforcement rights — users can complain to national bodies, and some member states allow non-governmental organisations to bring collective actions.

How to prioritise your fixes

If you are starting from zero, focus on the high-impact, low-effort fixes first:

  1. Add alt text to all product images (highest impact, usually a data entry task)
  2. Fix the html lang attribute if missing (one-minute code change)
  3. Remove user-scalable=no from viewport meta (one-minute code change)
  4. Add visible labels to all form fields
  5. Fix colour contrast in your CSS — typically limited to a few colour variables
  6. Test keyboard navigation and fix any focus-trap or tab-order issues

Many of these require zero design changes — they are code and content tasks. Use our free scanner to identify which specific failures affect your store, then work through them systematically.

The business case beyond compliance

An accessible store is not just legally required — it converts better. Screen reader users and keyboard-only users represent a significant minority of consumers, and accessibility improvements directly correlate with better SEO (alt text, semantic HTML, logical structure). Stores that fix accessibility before the deadline avoid both legal risk and the cost of rushed remediation later.

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