The EAA since 28 June 2025: a practical guide for sellers outside the EU
Published: 7 min readThe AccessibleOrNot team
Since 28 June 2025, the European Accessibility Act (EAA, Directive 2019/882) has required e-commerce and certain other digital services offered to consumers in the EU to be accessible. It doesn't look at where the company is based: a company in Türkiye, the UK or the US that sells to consumers in the EU is most likely in scope, unless it is a microenterprise.
In short
- The EAA has applied since 28 June 2025; each member state's own authority enforces it.
- What counts is who the service is offered to: non-EU companies selling to consumers in the EU can be in scope.
- The only exemption is for microenterprises providing services: fewer than 10 employees and an annual turnover or balance sheet of no more than €2 million.
- The technical reference is EN 301 549; the current reference is based on WCAG 2.1 AA, and v4.1.1, published in September 2026, moves to WCAG 2.2.
- In Germany (BFSG), fines go up to €100,000; in France, a court set a penalty of €500 a day for Carrefour.
The EAA at a glance
| Topic | Details |
|---|---|
| Official name | Directive (EU) 2019/882 on the accessibility requirements for products and services |
| Adopted | 17 April 2019 |
| Applies from | 28 June 2025 |
| Services covered | E-commerce, banking, e-books, electronic communications, access to audiovisual media, digital channels of passenger transport |
| Technical reference | EN 301 549 (legal reference v3.2.1 → WCAG 2.1 AA) |
| Exemption | Microenterprises providing services |
| Enforcement | Each member state's market surveillance authority |
For scope and country examples in detail, see our EAA guide. This post focuses on the steps a company outside the EU should take.
Source: EUR-Lex
Why are non-EU companies in scope?
The Directive looks at whether the service is offered to consumers in the EU. A brand from Istanbul, Manchester or New York that sells with a German interface, prices in euros and delivers to Germany is offering an e-commerce service to German consumers.
Cases that fall outside scope:
- Selling only to businesses (B2B): the EAA covers services offered to consumers.
- Microenterprises providing services: fewer than 10 employees and an annual turnover or balance sheet total of no more than €2 million. Both conditions must be met.
- Not selling to the EU at all: the EAA doesn't apply, but your home market may have its own rules (the ADA in the US, the Equality Act 2010 in the UK, Circular No. 2025/10 in Türkiye).
If you sell on a marketplace (such as Amazon.de or Zalando), the code of your store page belongs to the marketplace. Your responsibility may be limited to product content (image descriptions, product information); clarify this with your lawyer.
Source: EUR-Lex
What does the EAA require of an e-commerce site?
The Directive requires the service to be perceivable, operable, understandable and robust for disabled users; these are the same as WCAG's four principles. In practice, the flows that are checked are: finding products, product information, the cart, checkout, creating an account and customer contact.
In practice, the reference is the EN 301 549 standard. Conformance with it gives a presumption of conformity with the Directive. The current reference is v3.2.1, based on WCAG 2.1 AA for the web. Version 4.1.1, published in September 2026, added the six new Level A and AA criteria from WCAG 2.2; the legal reference will change once the European Commission publishes it in the Official Journal of the EU.
The Directive also requires information on how the service meets the accessibility requirements to be made available to consumers. The common way to do this is an accessibility statement.
Where do enforcement and penalties stand?
Penalties are set not by the Directive but by each member state in its transposition law. Known examples:
| Country | What happened | Date |
|---|---|---|
| Germany | BFSG § 37: administrative fines of up to €100,000 for certain breaches and up to €10,000 for others; the authority first asks for a fix and can then ban sales | Since June 2025 |
| Netherlands | The ACM tested about 100 large online shops: 61% were not accessible, 33% had serious problems | 24 March 2026 |
| France | A court in Caen gave Carrefour 6 months, then a penalty of €500 per day | June 2026 |
The problems highlighted in the ACM's report were buttons that couldn't be activated with a keyboard and CAPTCHAs with no accessible alternative. Both block sales directly at checkout.
Source: bfsg-gesetz.de, ACM (Netherlands Authority for Consumers and Markets), Faire Face
"We have until 2030": is that right?
The Directive allows a transition period ending on 28 June 2030, but it applies to products already in use to provide services before 28 June 2025, and to contracts signed before that date. Reading it as "my website has until 2030" is common, but risky.
How the transition rule applies to your site may vary from country to country. Ask a lawyer about it; don't wait for 2030 to start the technical work.
Source: EUR-Lex
A 7-step plan for sellers outside the EU
- Confirm your scope. Do you sell to consumers in the EU? Do you have 10 or more employees, or is your turnover or balance sheet above €2 million? Our scope check answers this in three questions.
- Rank your markets. Look at the transposition law and the enforcing authority of the EU country where you sell most (the BFSG in Germany).
- Choose your target. WCAG 2.1 AA today; WCAG 2.2 AA for new development.
- Test your sales flow. Scan your product search, product page, cart, checkout, account and contact templates automatically; try once to complete checkout with a keyboard alone.
- Sort issues by owner. Your code, your theme, your platform or a third party (payment provider, chat tool). Report platform issues with the page, the element and the WCAG criterion.
- Publish an accessibility statement. In the language you sell in: say what you meet, what is still open and how users can reach you. The statement generator drafts one in 5 languages.
- Move to monitoring. Every theme update and campaign page can bring new issues. Re-scan monthly or after every release.
If you also sell in Türkiye
In Türkiye, Circular No. 2025/10 requires e-commerce sites to meet WCAG 2.2 Level A by 21 June 2027. The EAA is based on WCAG 2.1 AA for EU consumers. Together, the two lists come close to WCAG 2.2 AA in practice: one target can cover both.
Frequently asked questions
Does the EAA cover companies outside the EU?
Most likely yes, if they sell products or services to consumers in the EU and don't qualify for the microenterprise exemption. The Directive looks at who the service is offered to, not where the company is headquartered.
What exactly is the microenterprise exemption?
Businesses that provide services, employ fewer than 10 people and have an annual turnover or balance sheet total of no more than €2 million are exempt from the service requirements. There is no such exemption for product manufacturers.
What is the penalty for not complying with the EAA?
Each member state sets its own. In Germany, BFSG § 37 provides for administrative fines of up to €100,000 for certain breaches. In France, a court in Caen set a penalty of €500 a day for Carrefour in June 2026.
Which WCAG version does the EAA require?
The Directive doesn't refer to WCAG directly; the presumption of conformity comes from the EN 301 549 standard. The current reference is v3.2.1 (WCAG 2.1 AA). Version 4.1.1, published in September 2026, is based on WCAG 2.2 and will become the reference once it is published in the Official Journal of the EU.
Is an accessibility statement mandatory?
The Directive requires information on how the service meets the accessibility requirements to be made available to consumers. The format varies by country; the common practice is a separate statement page on the site.
Sources
- Directive (EU) 2019/882 (European Accessibility Act) · EUR-Lex · 17 April 2019
- The European accessibility standard EN 301 549 has been updated · AccessibleEU (European Commission) · 7 September 2026
- § 37 BFSG, penalty provisions (in German) · bfsg-gesetz.de · 2025
- Customers with disabilities cannot shop at most large web shops (in Dutch) · ACM (Netherlands Authority for Consumers and Markets) · 24 March 2026
- Caen court ruling against Carrefour (in French) · Faire Face · 11 June 2026
- Presidential Circular No. 2025/10, Official Gazette No. 32933 (in Turkish) · Lexpera · 21 June 2025
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Enter your store's URL. We list the findings in the EAA (WCAG 2.1 AA) view, with cart and checkout templates first.