The European Accessibility Act Has Applied Since June. Your Store Is in Scope.

The European Accessibility Act has applied to ecommerce services since June 28, 2025, with WCAG 2.1 Level AA as its yardstick. Small businesses are exempt, but the exemption is narrower than most stores assume.

The European Accessibility Act started applying on June 28, 2025. It covers ecommerce services sold into the EU, and its technical yardstick is WCAG 2.1 Level AA, with member states writing the rule into national law on their own timetables. A US store that ships to Europe is in scope, and the question is no longer whether the Act applies, but whether the store's checkout can pass a 2.1 AA audit.

The surprise for most stores is the exemption. Very small businesses are exempt, but the definition is tight, and a store doing real volume into the EU will not qualify. The second surprise is that the Act reaches beyond the website: it covers the whole service, including the checkout, the order confirmation, and the customer service channels the store offers.

What the Act covers

The Act applies to products and services placed on the EU market, and ecommerce services are named explicitly. That means the storefront, the checkout, and the post-purchase flows a customer uses to manage an order. The harmonised standard points at EN 301 549, which in turn points at WCAG 2.1 Level AA for web content, so a store that meets 2.1 AA has covered the core of what the Act asks.

The timing is national. The Act is a directive, so each member state transposed it into its own law, with its own enforcement body and its own penalties. Germany, France, and Ireland have their own enforcement routes, and a store cannot assume that slow enforcement in one market means slow enforcement everywhere.

The small business exemption, read carefully

Microenterprises, businesses with fewer than ten employees and under 2 million euros in annual turnover, are exempt from the Act's service obligations. That is a narrow door. A store with eleven staff, or with turnover above the threshold, is in scope even if it feels small, and the exemption is measured per business, not per website.

The exemption also does not cover products. A store that sells a physical product into the EU still has product-side obligations, and the service exemption does not help if the store's own checkout is the barrier. Read the exemption as a test with numbers, not as a general excuse for small stores.

What to fix first

Start with the same failures that dominate US demand letters, because they are the same failures the Act's yardstick measures: contrast below 4.5:1, missing alt text, unlabeled form fields, empty buttons, and a checkout a keyboard cannot finish. Fix those, then test against WCAG 2.1 AA, not 2.2, because 2.1 is the version the harmonised standard names.

Then look at the service beyond the site. Order confirmations by email have to be readable, customer service chat has to be keyboard operable, and any PDF invoice has to be tagged. The Act treats the store as a service, and the service does not end at the thank-you page.

Related reading: Ready Means Not Asking Twice: Redundant Entry at Checkout, Title II Dates Are Set: What Public Sector Sellers Should Already Have Done, Getting a Store Ready for the European Accessibility Act: Dates, Scope, and Evidence.

Frequently asked questions

When did the European Accessibility Act start applying?

June 28, 2025. It covers ecommerce services sold into the EU, with WCAG 2.1 Level AA as the technical yardstick through the harmonised standard EN 301 549.

Is my store exempt as a small business?

Only if it is a microenterprise: fewer than ten employees and under 2 million euros in annual turnover. A store above either threshold is in scope, and the exemption is measured per business, not per website.

Does the Act cover anything beyond the website?

Yes. It covers the ecommerce service, which includes checkout, order management, email confirmations, customer service channels, and PDF invoices. The service does not end at the thank-you page.

Should I test against WCAG 2.1 or 2.2 for the Act?

Test against 2.1 Level AA, because that is the version the harmonised standard names. A store that meets 2.2 AA also meets 2.1 AA, since 2.2 keeps the 2.1 criteria, so 2.2 is a safe target too.