Ecommerce accessibility and the EAA

Keyboard and assistive device used for online shopping

By Patricia Jarmek E-commerce 9 October 2026

8 min read

A purchase should not depend on someone's ability to use a mouse

Imagine a customer who has found a product, read the description and decided to buy it.

They add the item to their cart, choose a delivery option and proceed to checkout.

But the final confirmation button cannot be activated using a keyboard.

For many customers, this problem may never become visible.

For someone who cannot use a mouse because of a motor impairment, it can make the purchase impossible.

Other barriers are less obvious.

A form may have fields without accessible labels. Error messages may rely entirely on colour. A screen reader may be unable to interpret the structure of a product page.

Accessibility is not simply about making a website look different.

An accessible online store allows customers to find products, understand information and complete purchases independently.

Since 28 June 2025, accessibility has also become a legal requirement for certain ecommerce services in the European Union.

What is the European Accessibility Act?

The European Accessibility Act (EAA) is based on Directive (EU) 2019/882.

Its purpose is to reduce barriers faced by people with disabilities and establish more consistent accessibility requirements across EU member states.

The legislation covers selected products and services, including certain electronic devices, banking services, ebooks, electronic communications and ecommerce.

Its requirements have applied through national legislation since 28 June 2025. [1]

For merchants operating across borders, understanding the EU directive is only part of the task.

National implementing laws also matter.

For example, Croatia adopted its Accessibility Requirements for Products and Services Act in 2025.

Slovenia introduced additional ecommerce provisions through amendments adopted on 11 February 2026.

Those amendments explicitly address the accessibility of information, identification, payment and security processes during online purchases. [2], [4]

Does the EAA apply to every online store?

Not automatically.

The directive covers ecommerce services provided to consumers for the purpose of concluding consumer contracts.

This makes the distinction between B2C and exclusively B2B operations important.

An online store selling to individual consumers may fall within the scope of the requirements.

A business offering services exclusively to other businesses may require a different legal assessment.

There is also an exemption for microenterprises providing services.

Under the directive's framework, a microenterprise generally has fewer than ten employees and annual turnover or an annual balance-sheet total not exceeding €2 million.

However, the exemption applies to the provision of services. It should not be interpreted as a blanket exemption from every accessibility obligation associated with products or other legislation. [1]

A small online retailer should therefore verify its actual legal position rather than assuming that its size automatically removes every obligation.

What must an accessible ecommerce experience provide?

Accessibility must cover the customer journey, not just the homepage.

Customers need to be able to discover products, read descriptions, select variants, use the shopping cart, enter information and complete payment.

The EAA specifically addresses accessibility requirements for identification, security and payment functions that form part of ecommerce services.

It also addresses the provision of accessibility information about products and services being sold, where that information is supplied by the responsible economic operator. [1]

Keyboard accessibility

Important functions should work without a mouse.

This includes menus, filters, product selectors, buttons and forms.

Keyboard focus should be visible, and the order of navigation should make sense.

Clear information

Product pages should use meaningful headings, accessible labels and understandable descriptions.

Important information should not be communicated through colour alone.

Images conveying meaningful information should have appropriate text alternatives.

Accessible forms

Customers should understand what information each field requires.

If an error occurs, the message should explain what went wrong and how to correct it.

A red border without an explanation is not sufficient.

Accessible checkout

A website is not meaningfully accessible if the customer can browse products but cannot complete payment.

Payment interfaces, authentication steps and security checks must therefore be included in accessibility testing.

The use of a third-party component does not automatically remove the need to assess the customer's experience.

WCAG 2.2 and EN 301 549: understanding the difference

The Web Content Accessibility Guidelines (WCAG) provide an internationally recognised framework for making web content accessible.

They are organised around four principles: perceivable, operable, understandable and robust.

WCAG 2.2 became a W3C Recommendation on 5 October 2023.

It introduced additional success criteria addressing issues such as keyboard focus visibility, target sizes and accessible authentication. [5], [6]

A new version of the European standard EN 301 549, version 4.1.1, was published in September 2026.

However, publication of a technical standard and its formal harmonisation under a particular legal instrument are not the same thing.

It would therefore be misleading to claim that WCAG 2.2 AA is the single universal legal requirement for every EU online store, or that meeting it automatically establishes complete EAA compliance.

The applicable legal requirements must be assessed separately.

For new ecommerce projects, WCAG 2.2 AA is a sensible technical quality target alongside the relevant legal framework. [7], [8]

Why an accessibility widget is not enough

Some websites use accessibility widgets that allow visitors to increase text size, change contrast or adjust visual presentation.

These features may be useful.

But they cannot automatically correct inaccessible forms, poor HTML structure, broken keyboard navigation or unusable checkout processes.

An accessibility widget is not a substitute for accessible implementation.

The same applies to automated testing.

Automated tools can identify many potential problems, but they cannot establish complete accessibility on their own.

Reliable evaluation requires human judgement and, where possible, testing with people who use assistive technologies. [9]

What should WooCommerce merchants check?

In WooCommerce, accessibility depends on more than the ecommerce platform itself.

Themes, plugins, custom components and configuration choices all affect the result.

Product variants are a common example.

If a customer can select a colour only through unlabeled coloured circles, someone using a screen reader may not understand the available options.

Dynamic notifications also matter.

When a product is added to the cart, the confirmation should be available to users of assistive technology.

Other areas requiring particular attention include filters, quantity controls, coupons, address forms, shipping selection and payment methods.

For multilingual stores, each language version should be tested.

Longer translations and different form labels can introduce problems even when the original language version works correctly.

How to conduct a practical accessibility audit

Start with critical customer tasks.

Select a representative product and attempt to complete a purchase using only a keyboard.

Check whether menus open, variants can be selected, forms can be completed and payment can be reached.

Then test text resizing, mobile layouts and basic screen-reader behaviour.

Use automated accessibility tools to identify technical issues, but do not treat their results as proof of complete compliance.

Prioritise findings according to their impact.

A checkout barrier that prevents a customer from paying is more urgent than a minor visual inconsistency in a decorative element.

After fixing problems, test the complete journey again.

Accessibility information and ongoing maintenance

For covered service providers, the EAA framework also includes requirements concerning information describing how the service meets relevant accessibility requirements.

Such information should reflect the actual service rather than relying on generic claims.

Accessibility also requires maintenance.

Online stores change constantly. New products, plugin updates, redesigned components and payment integrations can introduce new barriers.

That makes regular testing more useful than treating accessibility as a one-time project.

A well-designed online store should not work only for customers with ideal devices and abilities. It should make purchasing possible for people with different needs and ways of interacting.