European Accessibility Act: what small online shops must do

Since 28 June 2025, EU law has required online shops that sell to consumers to be accessible, unless they are very small. A shop's duties depend on its size and on what it sells, and each point below carries its article number.

Who is covered

The Act is Directive (EU) 2019/882. A directive is addressed to the Member States (Article 35), so your legal duty comes from the national act that implements it.

Article 2(2)(f) covers e-commerce services. Article 3(30) defines them as services provided at a distance through websites and apps “with a view to concluding a consumer contract”. Recital 43 applies this to “the online sale of any product or service”, so a shop selling candles and a site selling online courses both count. An online booking that ends in a consumer contract fits the definition. A form that only requests a quote is less clear.

Position of different businesses under Directive (EU) 2019/882
Your situation	Position	Articles
Sells to consumers online, 10 or more staff	Covered	2(2)(f), 3(30), 4(3)
Sells to consumers online, under 10 staff, turnover or balance sheet total up to EUR 2 million	Exempt for the service	3(23), 4(5)
Under 10 staff, turnover and balance sheet total both above EUR 2 million	Covered, not a microenterprise	3(23), 4(3)
Based outside the EU, offers its service to EU consumers	Covered, same size test	2(2)(f), 3(4)
Sells only to businesses	Outside the e-commerce definition	3(22), 3(30)
Blog, portfolio or brochure site with no way to buy	Not listed, unless in a listed sector	2(2)
Microenterprise selling computers, smartphones or e-readers	Shop exempt, product duties remain	2(1), 4(2), 4(5), 10

Under Article 3(4), a service provider includes anyone who “makes offers to provide such a service to consumers in the Union”. The directive does not say what counts as making an offer, so a shop that ships to the EU only now and then gets no clear answer from the text. Listed sectors include passenger transport (Article 2(2)(c)) and consumer banking (Article 2(2)(d)).

The microenterprise exemption

Article 3(23) has two tests and you must pass both: fewer than 10 persons, and annual turnover or annual balance sheet total of no more than EUR 2 million. Article 4(5) then exempts microenterprises providing services from the service requirements and any obligations relating to them.

Recital 53 says a business must “genuinely fulfil the requirements” of Commission Recommendation 2003/361/EC. Article 6(2) of the annex to that recommendation adds in the staff and finances of partner and linked enterprises, so a five-person shop owned by a larger group can fall outside the exemption.

The exemption covers services only. Article 4(2) has no size exception for products, so a microenterprise selling laptops, smartphones or e-readers placed on the market after 28 June 2025 is still a distributor. Article 10(2) requires a distributor to check, among other things, that the product bears the CE marking. A shop that sells such a product under its own brand is treated as the manufacturer (Article 11).

Dotted pixel art of three hot air balloons in red, orange and blue against a pale blue sky.

What a covered shop must do

Annex I holds the requirements. Section III(c) requires websites and apps to be accessible “in a consistent and adequate way” by making them “perceivable, operable, understandable and robust”. Section III(b) asks for information about the service in “fonts of adequate size and suitable shape”, which accessible font sizing covers in CSS.

Section IV(g) adds duties for e-commerce:

Show accessibility information about what you sell when the responsible economic operator provides it, which for resold goods usually means the manufacturer.
Make identification, security and payment functions accessible, along with any identification methods, electronic signatures and payment services you provide.

Article 13 adds the running duties:

Publish how the service meets the requirements, in your general terms and conditions or an equivalent document (Annex V, point 1). It must be available “in written and oral format” and in a form accessible to disabled people (Article 13(2)).
Keep procedures that hold the service in conformity as it changes (Article 13(3)), for example when a new theme or checkout provider goes live.
Correct any failure and “immediately inform” the national authorities where the service is provided (Article 13(4)).

Article 2(4) excludes pre-recorded media and office files published before 28 June 2025, archives not updated or edited after that date, some online maps, and third-party content “neither funded, developed by, or under the control of” you. User reviews may fit that last exception. A payment form you embed is unlikely to, because Section IV(g) names payment services directly.

The dates

Dates in Directive (EU) 2019/882
Date	What happens	Articles
28 June 2022	Deadline for national laws	31(1)
28 June 2025	National rules start to apply	2, 31(2)
28 June 2030	Transition ends for products already used to provide a service; first Commission report	32(1), 33(1)

Article 32(1) lets service providers keep using “products which were lawfully used by them” until 28 June 2030. Article 3(2) defines a product as a good produced through a manufacturing process. A website is hard to fit into that wording, so we would not count on 2030 for a shop’s own site. The same article lets service contracts agreed before 28 June 2025 run unchanged until they expire, for five years at most.

Disproportionate burden

Article 14(1) applies the requirements only as far as they do not fundamentally alter the service or impose a disproportionate burden. You make that assessment yourself using Annex VI, which compares the net cost of compliance with your overall costs and with your net turnover, and weighs your costs and benefits against the benefit to disabled people. Recital 66 says “Lack of priority, time or knowledge” do not count as legitimate reasons, and that requirements you can meet still apply in full.

If you rely on it:

Document the assessment, keep the results for five years after the service was last provided, and give authorities a copy on request (Article 14(3)).
Renew it when the service changes, when an authority asks, and at least every five years (Article 14(5)).
Tell the authority in the country where the service is provided (Article 14(8)).
Outside funding given to improve accessibility rules the claim out (Article 14(6)).

EN 301 549 and WCAG

The directive does not mention WCAG or name any standard. Article 15(1) gives a presumption of conformity to services that meet a harmonised standard whose reference is published in the Official Journal.

EN 301 549 is the European standard for ICT accessibility. Version 3.2.1 (March 2021) is cited under the separate directive for public sector websites, through Implementing Decision (EU) 2021/1339. Version 4.1.1 (September 2026) was written for this directive and maps to it in clause A.2 and Annex ZB. It says a presumption follows once it is “cited in the Official Journal” under the directive.

We found no such citation on EUR-Lex on 8 November 2026, and the Commission’s list of harmonised standards had an accessibility entry only for public sector websites. Without a citation, Article 15(1) gives no presumption, and Annex I applies regardless. That can change at any time, so check EUR-Lex before relying on it.

Clause 9.0 of version 4.1.1 treats WCAG 2.2 Level AA as equivalent to meeting clauses 9.1 to 9.4 and 9.6. We would use it as the working target for a small shop’s web pages. Annex ZB also points e-commerce to clauses 4.2, 5, 10 and 11.

Steps for a small shop

Work out your size under Article 3(23), including partner and linked enterprises, and keep the dated figures. Exempt shops should still check for Article 2(1) products.
Test the path from product page to order confirmation against WCAG 2.2 Level AA. Deciding what to test helps you pick browsers and devices.
Ask your payment, login and theme suppliers how their parts meet Annex I, and show the product accessibility information your suppliers give you.
Write the Annex V information into your terms or an equivalent page, recheck after site changes and keep any Article 14 assessment on file.
Read your country’s implementing act and find the authority designated under Article 23(2).

Enforcement and national law

Member States must check services and follow up complaints (Article 23), and a consumer can take a case to a court or administrative body (Article 29(2)). Penalties must be “effective, proportionate and dissuasive” (Article 30(2)), and the directive sets no amount.

Each Member State has to pass its own act, name its own authority and set its own penalties, and details may differ from the directive’s wording. We did not review any national text for this page. Norway has its own universal design rules. This page is general information and not legal advice. For a decision about your own business, ask a lawyer in your country.

Common questions

Does my website need a CE marking?

No. CE marking belongs to the product rules (Articles 7 and 16 to 18). Services publish the Annex V information instead.

What happens if my shop grows past the limits?

The directive does not say. The recommendation that recital 53 relies on keeps a business’s status unless the ceilings are exceeded over two consecutive accounting periods (Article 4(2) of its annex). Check how your national act handles it.

Does the size test change if my shop is outside the EU?

No. Article 3(23) has no location condition, so the same staff and turnover limits decide whether you are a microenterprise.

Sources

Where this comes from: we read each text below on 8 November 2026, when EUR-Lex listed the directive as in force. This article was prepared with help from AI.