Since 28 June 2025, Directive (EU) 2019/882 — the European Accessibility Act — has imposed accessibility requirements on several digital services, including e-commerce. Microenterprises providing services are exempt, and a transition period runs until 2030 for some equipment. Here's what the text says, article by article, and where to start technically.
The services covered
Article 2 lists the services in scope. They include consumer banking services, e-books and dedicated software, and, last on the list, "e-commerce services" (Directive (EU) 2019/882, Art. 2). The European Commission repeats the same list on its overview page, alongside the products covered: computers, smartphones, ATMs and ticketing machines (European Commission, European Accessibility Act).
The date: 28 June 2025
Article 31 requires Member States to apply their national measures "from 28 June 2025" (Art. 31). The directive sets the framework; it's each country's transposition law that actually applies to businesses.
The microenterprise exemption
This is the most important point for a small business, and it's written unambiguously: "Microenterprises providing services shall be exempt from complying with the accessibility requirements" (Art. 4(5)).
The definition is in Article 3: a microenterprise employs fewer than 10 persons and has an annual turnover or an annual balance sheet total not exceeding EUR 2 million (Art. 3, point 23). A five-person online shop is therefore not subject to the requirements. A forty-employee SME selling online to European consumers is.
The transition until 2030
Article 32 provides for a transition period ending on 28 June 2030, during which service providers may continue to provide their services using products they lawfully used before that date. Service contracts agreed before 28 June 2025 may continue without alteration until they expire, "but no longer than five years from that date" (Art. 32).
Don't read this transition as a general grace period: it covers products already in service and ongoing contracts, not an e-commerce site you're redesigning today.
Penalties
The directive sets no amount. Article 30 lets each Member State define its penalties, which must be "effective, proportionate and dissuasive" and accompanied by remedial action (Art. 30). The real risk therefore depends on the country you sell into — a question for a lawyer, not a developer.
Technically, what should you comply with?
The most widely used technical reference for assessing a website is the W3C's WCAG 2.2, whose current version is a Recommendation of 12 December 2024. It defines three conformance levels: A (lowest), AA and AAA (highest) (W3C, WCAG 2.2). In practice, audits target level AA.
On an e-commerce site, I always start with the journey that makes money: product page, basket, checkout, payment. The most common blockers:
- a checkout that can't be completed with the keyboard alone;
- form fields without a label a screen reader can announce;
- error messages signalled by colour only;
- an invisible focus: you lose track of where you are when tabbing;
- product images without useful alternative text.
An automated tool catches part of it; manual keyboard and screen-reader testing finds the rest.
This article describes the text of the directive; it is not legal advice on your situation.