Getting a Store Ready for the European Accessibility Act: Dates, Scope, and Evidence

The European Accessibility Act has applied to ecommerce services since 28 June 2025. What it covers, the microenterprise limit, and the evidence a store should be able to produce.

The European Accessibility Act stopped being a future date on 28 June 2025, when its requirements began to apply to covered services sold into the EU, including ecommerce. The technical reference behind it is EN 301 549, which in turn points at WCAG 2.1 AA for web content. A store that has been working to WCAG 2.2 AA for the US market is most of the way there on content. What is usually missing is the surrounding evidence: scope decisions, an accessibility statement, and records of how barriers get reported and fixed.

Scope is the first question and it is not all or nothing. The Act has a carve out for microenterprises providing services, defined as fewer than 10 employees and turnover or balance sheet at or under 2 million euro. Above that line, or selling through larger entities, a store should assume it is in scope for EU customers and plan accordingly. Get that determination written down, with the reasoning, rather than leaving it as a conversation nobody can reconstruct.

What readiness looks like in practice

An accessibility statement that names the standard you conform to, lists known issues honestly with dates, and gives a contact route for reporting barriers that actually reaches somebody. Conformance work on the buying path first: browse, product, cart, checkout, account, and the transactional emails and documents around them. And a process for third party components, because payment, chat, reviews, and consent tools are where a store's own work stops being the whole answer.

Transitional arrangements existed for services using products lawfully used before the June 2025 date, running in some cases to 2030, but that is not a general grace period for websites, which are expected to be updated continuously. Treat any reliance on a transitional provision as a specific legal question for your situation, documented, rather than as a reason to defer fixes everyone agrees are needed.

Market surveillance and what they can ask

Member states operate market surveillance authorities for the Act, and they can ask how a service meets the requirements. The useful evidence is unglamorous: audit reports against EN 301 549 or WCAG, a remediation log with dates, vendor conformance reports for embedded tools, and records of user reported barriers and their outcomes. A store that can produce that file is in a different position from a store with a badge in the footer and nothing behind it.

Penalties are set by member states and vary, which makes a single fine figure impossible to quote honestly. What can be said is that the direction is toward enforcement with paperwork. Complaints from users are a trigger for attention in many regimes, so the reporting route in your statement is not decoration. Answer it, log it, and fix what it surfaces.

Where US and EU work overlap, and where it does not

The overlap is large: perceivable, operable, understandable, robust covers the same defects in both markets, and a WCAG 2.2 AA programme exceeds the 2.1 AA reference in the current EN standard on most points. The differences are procedural. The EU expects a statement and information about accessibility in terms and service information, and it reaches documents and support services as well as pages. An accessible checkout with an inaccessible PDF invoice and a phone only support route is a partial answer.

Start with an inventory: templates, third party tools, documents, apps if you have them, and support channels. Score each against the standard, fix the buying path, publish the statement, and keep the log. That sequence is the same work a good ADA programme does, with the statement and evidence given more weight.

Related reading: Accessible Loyalty Points and Rewards Dashboards, Accessible Split Payment and Instalment Selectors at Checkout, Accessible Gift Wrapping, Gift Messages, and Receipt Options.

Frequently asked questions

When did the European Accessibility Act start applying?

Requirements began to apply on 28 June 2025 for covered products and services placed on the EU market, including ecommerce services. Some transitional provisions run longer for specific situations, but new and continuously updated web services should plan on being in scope now.

What standard does it use for websites?

EN 301 549 is the harmonised standard, and for web content it incorporates WCAG 2.1 AA. Working to WCAG 2.2 AA covers the content requirements and adds criteria such as focus not obscured, though the formal reference remains the EN standard.

Are small stores exempt?

Microenterprises providing services are exempt: fewer than 10 people and annual turnover or balance sheet total at or under 2 million euro. Above that, or if you sell through a larger business, do not assume an exemption. Record how you determined your status.

Do I need an accessibility statement?

Yes, information about how the service meets the accessibility requirements is part of the model, and a public statement with known issues and a contact route is the practical way to provide it. A statement that claims full conformance while listing nothing is less credible than one that lists issues with dates.