The European Accessibility Act: a step-by-step plan for small online sellers

First work out whether you are a microenterprise: fewer than 10 staff and annual turnover or balance sheet total of EUR 2 million or less. If you are, the European Accessibility Act exempts you from its requirements for services, including your online shop.¹ If you are not, the plan is: find out what your site fails today, fix checkout and the buying journey first, then the rest, publish information on how your shop meets the requirements in or alongside your terms and conditions, and keep checking. This is general information, not legal advice; each EU country applies the Act through its own law.

For the basics of who is covered, read does the European Accessibility Act apply to my online store? first. This post is the step-by-step plan that follows it.

Step 1: Confirm you are in scope

The Act applies to a list of services provided to consumers after 28 June 2025, and the last item on that list is e-commerce services.¹ Its definition of e-commerce services begins with services provided at a distance, through websites and mobile device-based services, by electronic means.¹ The Act defines a consumer as a natural person who purchases the relevant product or is a recipient of the relevant service.¹

• You sell online to consumers in the EU: very likely in scope. Our European Union guide notes that selling to EU consumers brings you in wherever your business is based.
• You sell only to businesses: the e-commerce part of the Act is about consumers, so check with a lawyer whether any of your sales count.
• Your site only shows information and customers cannot buy or agree a contract online: our EU guide describes the requirement as applying to online shops and sites where consumers can conclude a contract online, so ask a lawyer how your country treats your site.

Step 2: Check the microenterprise exemption

The Act defines a microenterprise as one that employs fewer than 10 people and has an annual turnover not exceeding EUR 2 million or an annual balance sheet total not exceeding EUR 2 million.¹ Article 4(5) says microenterprises providing services are exempt from complying with the accessibility requirements for services and any obligations relating to them.¹

Three points to note:

• The exemption is for services. If you also manufacture, import or distribute products the Act covers, the product rules are separate, and microenterprises dealing with products get only limited relief.¹
• You are still encouraged to comply. The recitals say microenterprises should be encouraged to apply the requirements voluntarily, and Article 4(6) requires member states to provide them with guidelines and tools.¹
• Growth changes the answer. Recheck the numbers each year. A business that hires its tenth person or passes the turnover line moves into scope.

Even if you are exempt, customers with disabilities still need to buy from you, and other laws may apply where you sell. The website accessibility laws by country overview is a good place to check.

Step 3: Know what "accessible" means here

The Act's requirements for all services say websites and mobile device-based services must be made accessible "in a consistent and adequate way by making them perceivable, operable, understandable and robust".¹ Those are the four principles WCAG is built on.² For e-commerce services, Annex I adds three specific points:¹

1. providing the accessibility information about the products and services you sell, where the responsible economic operator provides it;
2. making identification, security and payment functions accessible when they are delivered as part of the service;
3. providing identification methods, electronic signatures and payment services that are perceivable, operable, understandable and robust.

The Act's text does not name WCAG. In practice, our EU guide explains that the harmonised standard EN 301 549 points to WCAG 2.1 AA for web content. Testing against WCAG 2.2 A and AA covers those criteria and the newer ones.

Step 4: Find out where you stand

1. Run an automated check on your home page, a collection page, a product page and the cart. Jralo's free check tests against WCAG 2.2 A and AA with axe-core in a real browser, and reads your terms, privacy and contact pages to suggest which countries' accessibility laws are likely relevant to you, with a link to our guide for each. It is a pointer, not legal advice.
2. Do a keyboard test of the buying journey; see how to test with only a keyboard in 10 minutes.
3. Listen to one product page with a screen reader; see what a screen reader user hears.
4. Write the results down with the date. That becomes your starting record.

Automated testing finds many problems, not all, which is why the manual steps are there.

Step 5: Fix in order of what blocks a sale

Your platform carries part of the load. Shopify publishes an accessibility conformance report for its checkout against WCAG 2.0, 2.1 and 2.2 A and AA, and says merchants are responsible for their own store.⁴ WooCommerce says its core front end is substantially conformant with WCAG 2.2 AA.⁵ Your theme, apps and content are yours. Our guide to fixing accessibility without breaking your theme covers how to make changes safely.

Step 6: Publish the information the Act asks for

Article 13 requires service providers to prepare information, following Annex V, explaining how their services meet the accessibility requirements, to make it available to the public in written and oral format in a way that is accessible to persons with disabilities, and to keep it for as long as the service is in operation.¹ Annex V says it goes in the general terms and conditions, or an equivalent document, and includes:¹

• a general description of the service in accessible formats;
• the descriptions and explanations needed to understand how the service operates;
• a description of how the service meets the relevant accessibility requirements.

A practical way to do this is an accessibility statement, linked from your terms and conditions and your footer, that covers those three points, the standard you test against, known issues with fix dates, and a contact route. W3C's guidance and free generator help with the structure.³ Our guide to what to put in an accessibility statement has a template. Check with a lawyer how your country expects the "oral format" part to be met.

Step 7: If full compliance would be a disproportionate burden

Article 14 says the requirements apply only to the extent that complying does not fundamentally alter the service or impose a disproportionate burden on the business. A business relying on this must assess it, document the assessment, renew it at least every five years for services, and inform the relevant market surveillance authorities.¹ This is an exception to be argued, not a way out of the work, and it is a decision to take with a lawyer.

Step 8: Keep it up

Stores change every week, and every new app, theme update or campaign banner can introduce a problem. Recheck after each change, and keep a dated record of what you checked and fixed. Paid Jralo plans check daily and keep a record stamped each day by an independent timestamp authority, which is useful if a customer or authority asks what you have done. No tool, badge or audit makes a site compliant on its own.

Enforcement and penalties are set by each member state, and in some countries associations and competitors can also take action. See the European Union guide and the country guides linked from it before you rely on any figure.