What Does the European Accessibility Act Require for E-commerce?

E-commerce sits at the heart of the European Accessibility Act's mission to create an accessible digital economy. With the June 28, 2025 deadline now imminent, online retailers serving EU customers must ensure their entire shopping experience—from browsing products to completing checkout to receiving customer support—is accessible to people with disabilities. The EAA's e-commerce provisions affect virtually every aspect of online selling, and non-compliance can result in market restrictions, fines, and loss of access to over 400 million EU consumers. This guide details exactly what e-commerce businesses must do to comply.

Key Takeaways

E-commerce businesses face comprehensive accessibility requirements under the EAA that touch every part of the online shopping experience.

• All e-commerce services offered to EU consumers are covered, regardless of where the business is headquartered or physically located
• Product information must be accessible through multiple means, including text descriptions, alt text for images, and structured data
• The entire checkout process must be operable by users with disabilities, including cart management, payment entry, and order confirmation
• Customer service channels must be accessible, whether through chat, email, phone, or self-service support
• EN 301 549 and WCAG 2.1 AA provide the technical standards that define e-commerce accessibility compliance

What E-commerce Services Are Covered?

The EAA's definition of e-commerce services is deliberately broad, capturing the full range of online selling activities.

Definition Under the EAA

E-commerce services under the EAA include:

> "Services which provide for the online conclusion of consumer contracts for the sale of products or services"

This encompasses any business activity that enables consumers to:

• Browse and discover products or services online
• Select products and add them to a shopping cart
• Complete transactions through digital payment methods
• Receive confirmation and fulfillment information

Types of Businesses Covered

Direct online retailers: Businesses selling their own products through owned websites or apps, including fashion, electronics, home goods, and any other consumer products.

Digital marketplaces: Platforms that connect buyers with third-party sellers, such as Amazon Marketplace, Etsy, or regional equivalents.

Service booking platforms: Websites and apps for booking services like travel, accommodations, appointments, or subscriptions.

Digital product sellers: Businesses selling downloadable content, streaming services, or software products.

Omnichannel retailers: Businesses with both physical stores and online shopping options, where the online component must be accessible.

Geographic Reach

The EAA's e-commerce provisions apply to:

• EU-based businesses of any size above the microenterprise threshold
• Non-EU businesses that actively target EU consumers through their websites
• Businesses accepting EU payment methods and shipping to EU addresses

If your website is available to EU consumers, accepts euros or EU-country currencies, and ships to EU addresses, you're likely within scope—regardless of where your company is headquartered.

Product Information Requirements

Accessible product information is foundational to e-commerce accessibility. Consumers with disabilities must be able to understand what they're buying.

Essential Product Information Elements

Every product listing must provide accessible information about:

Product identification: Name, brand, model number, and unique identifiers must be programmatically determinable and not conveyed only through images.

Product descriptions: Detailed text descriptions that convey key features, specifications, and characteristics. These descriptions should not rely solely on visual presentation.

Pricing: Prices must be clearly associated with products and accessible to screen readers. Dynamic pricing updates must be communicated to assistive technologies.

Availability: Stock status, shipping timeframes, and availability information must be accessible and clearly associated with products.

Product variations: Size, color, and other variant options must be selectable and distinguishable without relying solely on visual differentiation.

Image Accessibility

Product images require particular attention:

Alternative text: Every product image needs descriptive alt text that conveys the image's purpose. For product photos, this means describing the product's appearance, key features, and relevant details.

Multiple images: When products have multiple views or detail shots, each image should have appropriate alt text explaining what aspect it shows.

Zoom functionality: Image zoom features must be keyboard accessible and work with screen magnification tools.

Color representation: When images show color variants, the color names must be provided in text form, not just as color swatches without labels.

Structured Content

Product information should be structured for accessibility:

Heading hierarchy: Use proper heading levels to organize product pages (product name as H1, sections like Description, Specifications, Reviews as H2s).

Tables for specifications: Technical specifications should use properly structured data tables with headers, not just visual alignment.

Lists for features: Feature lists should use semantic HTML list elements, not just visual bullets.

Clear labeling: All form fields, selection options, and interactive elements need clear, associated labels.

Checkout Process Requirements

The checkout process is where accessibility barriers most directly prevent transactions. Every step from cart to confirmation must be accessible.

Shopping Cart Accessibility

Cart summary: Users must be able to review their cart contents using assistive technologies. Each item should be clearly identified with product name, quantity, and price.

Quantity adjustments: Controls for changing quantities must be keyboard accessible and provide feedback to screen readers when values change.

Remove items: The ability to remove items must be accessible, with clear confirmation of removal actions.

Cart updates: Dynamic cart updates (totals, shipping estimates) must be announced to assistive technology users.

Form Accessibility

E-commerce forms—shipping, billing, payment—must meet strict accessibility standards:

Input labels: Every form field needs a visible, programmatically associated label. Placeholder text alone is insufficient.

Error identification: Errors must be identified in text (not just color), describe the issue, and suggest corrections. Error messages must be programmatically associated with the relevant fields.

Error prevention: For financial transactions, provide review and confirmation steps. Allow users to review order details before final submission.

Required fields: Clearly indicate which fields are required, using both visual indicators and programmatic means.

Input assistance: Provide format hints for fields like phone numbers, dates, and postal codes. Consider autocomplete attributes to reduce input burden.

Payment Process

Payment entry has additional accessibility requirements:

Payment method selection: Radio buttons or similar controls for selecting payment methods must be keyboard accessible and properly labeled.

Card entry fields: Credit card number, expiration, and CVV fields must have clear labels and support assistive technology input.

Security features: CAPTCHAs or security challenges must have accessible alternatives. Audio CAPTCHAs for visual ones, or alternative verification methods.

Third-party payment processors: If using PayPal, Apple Pay, or similar services, ensure the integration doesn't break accessibility. Test the complete payment flow.

Order Confirmation

Confirmation display: Order confirmation information must be accessible on screen, with clear organization of order number, items, totals, and expected delivery.

Confirmation emails: Confirmation emails should be accessible, using semantic HTML and appropriate structure.

Account integration: If orders are saved to customer accounts, that information must be accessible through the account interface.

Customer Service Accessibility

The EAA requires that customer service related to e-commerce be accessible through accessible communication channels.

Support Channel Requirements

Contact information: Information about how to contact customer service must be easily findable and accessible. Don't hide contact options behind inaccessible interfaces.

Multiple channels: While you don't have to provide every possible channel, the channels you do offer must be accessible:

• Phone support should work with TTY/relay services
• Email support should provide responses in accessible formats
• Chat support should be keyboard accessible and work with screen readers
• Self-service portals must meet web accessibility standards

Response accessibility: Support responses must be provided in accessible formats. PDFs sent as attachments must be accessible PDFs.

Live Chat Accessibility

If offering live chat support:

Chat interface: The chat widget must be keyboard accessible, including opening, typing, submitting, and closing.

Message display: Chat messages must be accessible to screen readers, with new messages announced appropriately.

Alternative to chat: For users who can't use live chat, provide alternative contact methods that achieve similar response times.

Self-Service Support

Help centers: FAQ pages, knowledge bases, and help documentation must be accessible.

Account management: Order history, tracking, returns, and account settings interfaces must be fully accessible.

Tracking information: Shipment tracking pages and notifications must convey information accessibly.

Technical Implementation

Meeting EAA e-commerce requirements means implementing accessibility across your technology stack.

Web Platform Requirements

WCAG 2.1 AA compliance: Your website must meet Web Content Accessibility Guidelines 2.1 Level AA success criteria as incorporated in EN 301 549.

Key WCAG requirements for e-commerce include:

• Keyboard accessibility for all functionality
• Sufficient color contrast (4.5:1 for normal text, 3:1 for large text)
• Text resizing up to 200% without loss of functionality
• Accessible names for all interactive elements
• Consistent navigation and identification
• Input assistance and error handling

Mobile accessibility: Mobile apps must also be accessible. EN 301 549 includes requirements for mobile applications that parallel web requirements.

Responsive design: Accessibility must work across different screen sizes and zoom levels. Test at 200% zoom and on mobile viewports.

Third-Party Integrations

E-commerce sites typically integrate multiple third-party services. Each must be evaluated:

Payment processors: Stripe, PayPal, Square, and others provide embeddable payment forms. Test these integrations for accessibility or use accessible implementation options.

Review systems: Product review platforms (Bazaarvoice, Yotpo, etc.) must integrate accessibly. Review widgets must be keyboard accessible and work with screen readers.

Chat widgets: Intercom, Zendesk, and similar chat tools vary in accessibility. Select accessible options and configure them properly.

Marketing tools: Pop-ups, notification bars, and email capture forms are frequent accessibility barriers. Ensure these are keyboard accessible and dismissible.

Analytics and tracking: While analytics scripts don't directly affect accessibility, ensure they don't interfere with accessibility features.

E-commerce Platforms

If using a platform like Shopify, WooCommerce, Magento, or BigCommerce:

Theme selection: Choose themes with strong accessibility foundations. Many themes have significant accessibility issues out of the box.

Plugin/extension evaluation: Every plugin, app, or extension can introduce accessibility barriers. Test additions thoroughly.

Customizations: Custom development work must maintain accessibility. Include accessibility requirements in development specifications.

Regular updates: Keep platforms and themes updated, as updates may include accessibility improvements.

Common E-commerce Accessibility Issues

Awareness of frequent problem areas helps prioritize remediation efforts.

Navigation and Structure

• Missing skip links: Users can't bypass repetitive navigation to reach main content
• Poor heading structure: Product pages lack logical heading hierarchy
• Inaccessible menus: Dropdown and mega menus that don't work with keyboards
• Breadcrumbs: Navigation aids that aren't announced or accessible

Product Pages

• Missing alt text: Product images with empty or unhelpful alternative text
• Color-only information: Size charts or color options conveyed only visually
• Inaccessible carousels: Product image galleries that can't be controlled by keyboard
• Dynamic content: Price changes or availability updates not announced to screen readers

Cart and Checkout

• Form field errors: Errors indicated only by color or not associated with specific fields
• Timeout issues: Sessions expiring without warning during checkout
• Focus management: Focus lost after adding to cart or during checkout steps
• Inaccessible payment forms: Particularly problematic with embedded payment widgets

Overlays and Pop-ups

• Modal dialogs: Pop-ups that trap keyboard focus or can't be closed accessibly
• Newsletter sign-ups: Email capture forms that appear without warning and block interaction
• Cookie consent: Cookie banners that aren't keyboard accessible or obscure content

Frequently Asked Questions

Does the EAA apply to my Shopify store if I'm based in the US?

Yes, if you sell to EU customers. The EAA applies based on where you offer products and services, not where your business is located. If your Shopify store accepts orders from EU countries, ships to EU addresses, and accepts EU payment methods, you must comply with EAA requirements.

Are third-party apps and plugins my responsibility?

Yes. You're responsible for the accessibility of your entire e-commerce experience, including functionality provided by third-party apps, plugins, and widgets. When selecting and implementing third-party tools, verify their accessibility or ensure you can configure them accessibly.

What accessibility standard should I follow for EAA e-commerce compliance?

EN 301 549 is the harmonized European standard that provides presumption of conformity with the EAA. For web content, EN 301 549 incorporates WCAG 2.1 Level AA. Following WCAG 2.1 AA for your website addresses the web accessibility requirements.

Do I need to make my entire website accessible or just the checkout?

The entire e-commerce experience must be accessible, from homepage through product discovery, product pages, cart, checkout, order confirmation, and customer service. A user with a disability should be able to complete the same tasks as any other user.

What about PDF invoices and receipts?

Documents provided as part of the e-commerce service, including invoices, receipts, and order confirmations, should be accessible. For PDFs, this means proper tagging, reading order, and alternative text. Consider also providing HTML versions of important documents.

How do I handle user-generated content like reviews?

While you may not be able to control the text of user reviews, the platform displaying them must be accessible. Review ratings, sorting options, and navigation through reviews must work with assistive technologies. Consider moderation practices that ensure reviews are understandable.

Related Resources

• ADA vs. EAA Compliance Comparison: Understanding Both Standards
• WCAG 2.2 Compliance Guide: Meeting the Latest Standards
• Best Shopify Accessibility Tool 2025: Automated Testing Solutions

This article was crafted using a cyborg approach—human expertise enhanced by AI to deliver practical guidance on European Accessibility Act e-commerce compliance.