Starting in June 2025, many online shop operators will be required to make their sales platforms accessible under the European Accessibility Act (EAA). This FAQ explains who is affected, which requirements apply, and how shop owners can implement them in a legally compliant way.

Purpose and Scope of the New Accessibility Law

1. What is the aim of the new EAA?

The European Accessibility Act (EAA) is an EU-wide legislation (officially: EU Directive (EU) 2019/882) that sets minimum accessibility requirements for certain products and services across all EU member states.

Its purpose is to require manufacturers and service providers to design their offerings so that people with disabilities can use them without difficulty or outside assistance.

The law defines:

• General accessibility requirements

• Product labeling requirements

• Provisions for market surveillance

• Administrative processes and penalties

It is supplemented by the European Accessibility Act (EAA), which specifies product- and service-specific accessibility standards.

2. When does the EAA take effect?

The European Accessibility Act (EAA) applies to:

• Products placed on the market after June 28, 2025 (i.e., starting June 29, 2025)

• Services provided after June 28, 2025 (i.e., starting June 29, 2025)

Transition periods may vary by country.
EU Member States can allow service providers to continue using non-compliant products until June 27, 2030, provided these were lawfully in use before June 28, 2023.

Additionally, contracts for services signed before June 28, 2025 may be allowed to continue temporarily but must typically end by June 27, 2030, in line with national implementation rules.

Please consult your local legislation for details.

3. Do the accessibility requirements apply only to consumers, or also to businesses?

The EAA is primarily intended to protect consumers.

It applies only to products and services that are offered to consumers, not to purely business-to-business (B2B) transactions.

A consumer is defined as:

“Any natural person who purchases or uses a product or service for purposes that are not primarily attributable to their trade, business, or profession.”

Note:
Even if a product or service is partly used for business, the user may still qualify as a consumer if the private use predominates.

4. Do the accessibility requirements apply to online shops?

Yes — if the shop targets consumers (B2C).

The EAA explicitly covers electronic communication services and e-commerce platforms used by consumers to access products or services.

This includes:

• Websites

• Mobile apps

• Online shops
  …that are designed to allow consumers to view offers, interact, and complete purchases or bookings.

Therefore, if you operate a B2C online shop in the EU, you are legally required to comply with accessibility standards under the EAA by June 28, 2025.

Exemptions and Special Cases under the EAA

Tip:
Microenterprises are exempt from the EAA requirements if they:

• Employ fewer than 10 people, and

• Either have annual turnover not exceeding €2 million or a balance sheet total not exceeding €2 million.

(More details on this can be found below in FAQ 8.)

5. Do the accessibility requirements also apply to B2B-only shops?

Generally, no.

However, this only applies if the shop is clearly structured as B2B-only, and it is immediately clear to all users that:

• The shop’s content and offers are exclusively aimed at businesses, and

• No consumer contracts are concluded through the shop.

So, the B2B nature must be explicit and unambiguous.

6. Are purely informational websites without shop functionality affected?

No.

According to the official legislative commentary, digital services are only subject to the EAA if they:

• Present offers to consumers, and

• Allow bookings and/or payments

This means that informational websites and blogs where no direct purchase of goods or services is possible are notcovered by the BFSG.

7. Are all content elements in online shops subject to accessibility requirements?

Not all content is covered. The European Accessibility Act excludes certain types of content from its scope, depending on the level of control and how current the content is.

Exemptions may include:

• Third-party content that is neither funded, developed, nor controlled by the website owner

• Archived content, meaning material that is not updated or modified after the law takes effect (June 28, 2025)

Important exceptions:

• Third-party advertisements (e.g., banners or popups) and third-party tools (such as cookie consent banners or interactive features) are not exempt if the website operator has control over whether or not to include them

• Individual pages (such as blog posts or category pages) are not automatically exempt just because they haven’t been updated — the entire website must be considered “inactive” (i.e., no updates at all) to qualify as archived

8. Are microenterprises exempt from the accessibility requirements?

Yes — the European Accessibility Act explicitly exempts microenterprises from its accessibility obligations for digital services such as online shops.

A microenterprise is defined at the EU level as a company that:

• Has fewer than 10 employees, and

• Either an annual turnover of less than €2 million, or a balance sheet total of less than €2 million

Note on calculating employee numbers:
This definition follows the EU SME criteria outlined in Annex I of Commission Regulation (EU) No. 651/2014:

• Full-time employees each count as 1

• Part-time and seasonal staff must be converted into full-time equivalents (FTEs) based on hours worked

• Temporary agency workers must also be counted

• Trainees and apprentices are excluded

Example:
An employee working 50% of full-time hours is counted as 0.5 FTE

This means that many small business owners in the EU will likely be exempt from the EAA’s digital accessibility requirements — because they qualify as microenterprises.

Tip: Shop accessibility vs. product accessibility

Important: Being exempt from making the online shop accessible does not exempt microenterprises from ensuring the accessibility of certain products offered via their shop.

The microenterprise exemption only covers the shop interface as a “service in electronic commerce.” It does not apply to physical, technical, or operational accessibility requirements for products explicitly listed in Section 1(2) BFSG.

If you sell any of the following products, you are still required to ensure they meet accessibility standards:

• Consumer computer hardware systems (including operating systems intended for them)

• Payment terminals and associated hardware/software

• ATMs

• Ticket vending machines

• Check-in terminals

• Interactive self-service information terminals

• Consumer devices with interactive features used for telecommunications services

• Consumer devices with interactive features used to access audiovisual media services

• E-book readers

9. Can a business be exempt from the accessibility requirements due to disproportionate burden?

Yes — under strict conditions, the European Accessibility Act allows exemptions where applying the accessibility requirements would result in a disproportionate burden for the business.

This applies when fulfilling the obligations would cause excessive financial or administrative hardship, and it would be unreasonable to expect full compliance with one or more of the EAA requirements.

To claim this exemption, the business must conduct a formal internal assessment based on criteria defined in the directive and further detailed by national authorities.

These criteria typically focus on:

• The net cost of implementation in relation to the business’s total operating and investment costs

• The net cost of implementation compared to the business’s net revenue

The assessment must be:

• Documented in writing

• Retained for five years

• Reviewed and updated every five years

Important:
If a business claims exemption due to disproportionate burden, it must promptly inform the relevant market surveillance authority in its country and — if the service is offered cross-border — in any other EU Member States it targets (e.g., if the shop operates a .fr or .it domain).

The documentation must be made available to those authorities upon request.

Accessibility in Online Shops: Timeline and Implementation Requirements

Online merchants who sell products or services to consumers will be required under the European Accessibility Act (EAA) to meet a range of technical and content-related accessibility standards. These requirements aim to ensure that digital commerce platforms — including websites and mobile apps — are fully usable for people with disabilities.

1. When must online shops comply with accessibility requirements?

The EAA applies to:

• Products placed on the market from June 29, 2025, and

• Services provided from June 29, 2025

For most online shops, there are no transitional exceptions, as web accessibility is not dependent on physical infrastructure or hardware.

Therefore, B2C online shops must comply with accessibility requirements starting on June 29, 2025.

2. What general accessibility principles apply to online shops?

Online shops must be designed and operated in a way that is:

• Perceivable: content must be available to at least one of the user’s senses (sight, hearing, etc.)

• Operable: users must be able to navigate and interact with the interface

• Understandable: content and operations must be clear and predictable

• Robust: content must be compatible with assistive technologies and future technologies

These four principles form the foundation of both the EAA and the WCAG 2.1 Level AA standard.

3. What specific accessibility requirements apply to online shops?

In accordance with the EAA, digital services such as online shops must meet the following criteria:

1. Accessibility of product and service information

If product or service accessibility information is provided by the manufacturer or provider, online shops must present this information in an accessible manner. That means:

• Available via more than one sensory channel (e.g. visual and auditory)

• Clearly findable and understandable

• Presented in text formats that support conversion into alternative assistive formats (e.g. screen readers, Braille)

• Using readable fonts, contrast, and spacing

• Offering text alternatives for non-text content (e.g. images, charts, videos)

2. Accessible checkout, security, and authentication

All functions related to login, checkout, authentication, security, and payment must also be:

• Perceivable

• Operable

• Understandable

• Robust

3. Digital transaction services

Where applicable, features such as e-signatures, authentication methods, and payment services must also meet the same four principles.

4. What practical steps are recommended for implementation?

The EAA and national regulations use broad legal definitions and do not always provide a checklist. As such, shop operators are encouraged to follow the Web Content Accessibility Guidelines (WCAG) 2.1 – Level AA as a practical framework.

Until official national guidelines are published, the WCAG remains the most widely accepted standard for digital accessibility in the EU.

Key questions to assess accessibility readiness:

• Can the shop be fully navigated using only a keyboard?

• Are all form fields labeled clearly and meaningfully?

• Can text size and spacing be adjusted without breaking the layout?

• Are videos or audio content provided with subtitles or transcripts?

• Can multimedia content be paused, stopped, or hidden if needed?

• Are all buttons, menus, and interactive elements accessible to assistive technologies?

• Are headings, links, and labels clear and consistent?

Accessibility Declarations in Online Shops: Legal Information Obligations

In addition to technical implementation requirements, the European Accessibility Act (EAA) also requires online shops that fall under its scope to provide clear, accessible information about how their services meet accessibility standards — starting June 28, 2025.

1. What information must be provided?

Online merchants must make transparency declarations available to explain:

• Which accessibility requirements apply

• A general description of the service in an accessible format

• How the service is delivered, and what measures are in place to ensure accessibility

• How the service meets the applicable criteria

• The identity of the relevant market surveillance authority in the merchant’s country

This information can be included in:

• The shop’s General Terms and Conditions (T&Cs)

• Or displayed clearly and prominently elsewhere, e.g., a dedicated subpage or footer link labeled “Accessibility”

2. How must this information be presented?

The declaration itself must be accessible to all users. That means:

• It must be available through multiple sensory channels (e.g., visual and auditory)

• It must be easily findable on the website or app

• The content must be clear, understandable, and perceivable

• It should use text formats that can be processed by assistive technologies (e.g., screen readers)

• It must use a legible font size, appropriate contrast, and adequate spacing

• If it includes non-text content, an alternative presentation (e.g., alt text, captions) must be offered

Consequences for Non-Compliance and Additional Guidance

1. What are the consequences of non-compliance?

Non-compliance with the EAA’s accessibility and information obligations can lead to:

• Legal consequences under unfair commercial practice laws in many EU countries (e.g., warning letters, cease-and-desist claims, civil lawsuits)

• Regulatory sanctions, such as fines or orders from national market surveillance authorities

In some Member States, failure to comply with accessibility obligations may be classified as an administrative offense and could result in significant financial penalties (up to tens of thousands of euros, depending on national implementation law).

2. Are there online tools to check accessibility compliance?

Yes. A list of free online tools for automatically testing accessibility in online shops can be found here.

Tip: Have questions or want to exchange ideas with others? Join the discussion in the IT-Recht Kanzlei Facebook group for entrepreneurs.

What does this mean for merchants using an ePages shop?

ePages will provide a software update in good time to support merchants in fulfilling legal requirements.
However, some elements—like color contrast and image descriptions—depend on individual shop design. ePages will provide the technical foundation, but each merchant must ensure full compliance.

Before making changes, check whether the law applies to your business at all:

• If you have fewer than 10 employees and either less than €2M turnover or €2M balance sheet total, you are exempt.

Not sure if you’re affected or need help?
Contact eaa@epages.com with the subject line “Accessibility”, and we’ll help you assess your options.

This article contains initial legal information but does not claim to be complete or correct. It can in no way replace legal advice in individual cases.

RA Phil Salewski (IT-Recht Kanzlei)

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