Your Online Store and the EAA: What Changes Now

The deadline has passed

The European Accessibility Act came into force on June 28, 2025. For eCommerce businesses selling to EU customers, accessibility is no longer a recommendation — it’s a legal requirement.

If your organization has more than 10 employees and more than €2 million in annual turnover, and you sell products or services to customers in the EU, you are within scope. Microenterprises (under 10 employees and under €2 million turnover) have a lighter-touch regime, but the EAA still encourages compliance.

What does compliance actually mean for an online store? The short answer: your website and app must meet WCAG 2.1 Level AA, applied across the complete customer journey — not just your homepage.

Why eCommerce is particularly high risk

Checkout is the most litigated surface in digital accessibility. In the United States, which has years more enforcement history under the ADA than Europe has under the EAA, eCommerce sites account for a disproportionate share of accessibility lawsuits — and the checkout flow accounts for a disproportionate share of those complaints.

The reason is practical: checkout is where the task matters most. A blind user who can navigate your product pages but encounters a broken form field at payment can’t complete the purchase. The friction is maximal. So is the motivation to complain.

The EAA enforcement pattern is expected to follow the US trajectory. Accessibility advocates and enforcement bodies will prioritize the journeys that most directly affect disabled people’s ability to participate in commerce.

The four high-risk areas in eCommerce

1. Product pages

Product pages fail accessibility most often through:

Missing or inadequate image alt text — product images with filenames as alt text (“DSC0042.jpg”), empty alt attributes, or auto-generated descriptions that don’t mention the product or its relevant attributes.

Color-only product variants — swatches that use only color to distinguish options, with no text alternative. A color-blind user may not be able to distinguish between “burgundy” and “forest green” swatches that are selected only by clicking a small colored circle.

Contrast failures in product descriptions — light grey text on white for specifications, pricing, or availability information.

Inaccessible image galleries — carousel components that can’t be operated by keyboard, or that don’t announce the current slide number to screen readers.

2. Search and filtering

Navigation and discovery flows fail when:

• Search results are not announced to screen readers (the new count of results appearing doesn’t trigger an announcement)
• Filter checkboxes or dropdowns lack programmatic labels
• Applied filters can’t be removed using the keyboard
• Autocomplete suggestions aren’t accessible to screen reader users

3. Checkout

Checkout contains the densest concentration of complex interactive components — forms, payment widgets, address lookups, delivery date pickers — and therefore the highest density of accessibility failures.

Common checkout failures:

• Form fields without associated <label> elements (fields announced as “edit text, blank”)
• Error messages that appear visually but aren’t announced to screen readers
• Focus not managed correctly after form submission errors (user doesn’t know where the errors are)
• Third-party payment iframes that don’t meet accessibility standards
• CAPTCHAs with no accessible alternative

The most impactful single improvement you can make to an eCommerce site’s accessibility is usually fixing the checkout form — specifically: proper labels, linked error messages, and correct focus management on validation failure.

4. Account management and post-purchase flows

Order confirmation, tracking, returns, and account settings pages are frequently overlooked in accessibility reviews. They matter: a user who can complete a purchase but can’t track their order or initiate a return has not had an accessible experience.

PDF receipts and invoices that aren’t tagged properly are common failures in post-purchase flows. Accessible PDF documents require specific tagging and reading order — a PDF exported from a design tool without any accessibility processing is almost certainly not compliant.

What the EAA doesn’t require

It’s worth clarifying a few things the EAA does not require:

• 100% automated scan perfection — automated tools reliably detect only 30–40% of WCAG issues. A perfect automated score does not mean compliance, and a failing automated score doesn’t mean you’re in breach if the issues are minor.
• Instant compliance — organizations that demonstrate good-faith effort, an accessibility statement, and a documented remediation plan are in a meaningfully better position than those who have done nothing.
• Compliance from an overlay widget — installing a “one-click accessibility” overlay does not satisfy the EAA. National enforcement bodies are aware of these products, and several EU member states have clarified that overlays do not constitute compliance.

Where to start

If you haven’t audited your store yet, start by understanding where you stand.

A free automated scan gives you an immediate picture of the most obvious violations — contrast failures, missing alt text, unlabeled form fields. This takes two minutes and costs nothing.

For a complete view — including the errors automated tools can’t find, like inaccessible keyboard navigation, broken focus management in checkout, and screen reader announcement failures — you need manual testing. Our accessibility audits performed by people with disabilities will surface the barriers that your real users would actually encounter.

Prioritize checkout, product pages, and search. Fix the highest-impact issues first. Document your progress. That combination — audit, remediate, document — is the EAA compliance foundation that keeps your organization ahead of enforcement rather than reacting to it.