What is the EAA?
The European Accessibility Act is EU Directive 2019/882. Member states transposed it into their own laws, and the rules have applied since 28 June 2025.
It requires e-commerce services to be perceivable, operable, understandable and robust for disabled users. The technical reference is EN 301 549, which builds on WCAG 2.1 AA for the web.
Source: Directive (EU) 2019/882, EUR-Lex
Who does it cover?
Websites and apps that sell products or services online to consumers in the EU.
Flows in scope
- Finding products
- Product information
- Cart
- Checkout
- Creating an account
- Customer contact
Exemption: microenterprises providing services, meaning businesses with fewer than 10 employees and an annual turnover or balance sheet total of no more than €2 million. Both conditions must be met.
Am I in scope?
Three questions. Your answers never leave this page.
Answer the three questions; your result will appear here.
Selling into the EU from outside it
The Directive looks at who the service is offered to, not where the company is based. A brand from Türkiye, the UK or the US that sells to Germany in euros, with a German interface, is most likely in scope.
The authority of the member state concerned enforces the rules, and penalties vary from country to country. Ask a lawyer about the rules in each market you sell to. Outside the EU, other laws apply: the ADA and Section 508 in the US, the Equality Act 2010 in the UK. WCAG is the common technical reference.
Türkiye's Circular No. 2025/10
Published in the Official Gazette of 21 June 2025. It gives service providers selling online under Law No. 6563 two years to comply: June 2027.
The reference is the Ministry of Family and Social Services' "Checklist – Level A" and WCAG 2.2. The text sets no turnover threshold for e-commerce.
Source: Official Gazette 32933, Lexpera
The EAA and the Circular
| EAA | Circular | |
|---|---|---|
| Scope | Sellers to EU consumers | E-commerce in Türkiye under Law No. 6563 |
| Standard | WCAG 2.1 AA (EN 301 549) | WCAG 2.2 A |
| Deadline | 28 Jun 2025 | Jun 2027 |
| Exemption | Microenterprises | None |
| Enforcement | Member state authority | The Ministry |
The two overlap, but they are not the same. The new Level A criteria in WCAG 2.2 (3.2.6 Consistent Help, 3.3.7 Redundant Entry) are not on the EAA's WCAG 2.1 AA list.
Timeline
2019
Directive adopted
28 Jun 2022
Deadline for transposition into national law
21 Jun 2025
Circular No. 2025/10 published in Türkiye's Official Gazette
28 Jun 2025
The EAA applies
Mar 2026
ACM report (Netherlands)
Jun 2026
Caen court ruling against Carrefour
Jun 2027Upcoming
Circular: deadline for e-commerce
2030Upcoming
End of the EAA transition period
Enforcement examples
Netherlands
The ACM tested ~100 large web shops
On 61% of the sites, a disabled customer could not place an order. Checkout buttons and CAPTCHAs were the most common problems.
Source: ACM, March 2026
France
Caen court, Carrefour
The court gave Carrefour 6 months, then a penalty of €500 per day. It did not accept 71% conformance as enough. Its reasoning: "An e-commerce site cannot be somewhat accessible."
Source: Faire Face, June 2026
US
The FTC and accessiBe
The FTC approved a final order requiring accessiBe, which promised compliance through its overlay tool, to pay $1 million.
Source: FTC, April 2025
We share these examples not to scare you, but to show that enforcement is real.
12-point checklist
Check these first in your sales flow.
- The checkout button has an accessible name
- Form fields have visible labels
- Error messages are in text, next to the field
- The whole flow can be completed with a keyboard alone
- Focus is always visible
- Text contrast is at least 4.5:1
- Product images have meaningful alt text
- Variant pickers can be used with a screen reader
- CAPTCHAs have an accessible alternative
- Pages don't break at 200% zoom
- Users are warned before a session times out
- An accessibility statement is published