European Accessibility Act for e-commerce: what WCAG 2.1 AA requires

The European Accessibility Act (Directive 2019/882) applies to e-commerce services placed on the market from 28 June 2025. For the web part of an online store, the operative technical standard is WCAG 2.1 Level AA. Storefronts above the microenterprise threshold must satisfy these requirements.

The Directive does not name a technical standard by reference to WCAG. National implementations point at EN 301 549, which in turn references the W3C Web Content Accessibility Guidelines. For the web part of e-commerce, WCAG 2.1 Level AA is the operative bar.

What does WCAG 2.1 AA actually require of a storefront?

A storefront satisfying WCAG 2.1 AA has, at minimum, the following properties.

• Every non-decorative image carries alt text that conveys its function or content.
• Every form input has a programmatic label associated with it (a label element with a matching for attribute, or aria-label).
• The page declares its language via the lang attribute on the html element.
• Text colour contrast against background is at least 4.5:1 for normal text and 3:1 for large text.
• Every interactive element is reachable and operable by keyboard alone.
• Headings follow a sensible hierarchy (h1, then h2, then h3, no skipped levels).

There are other criteria (focus indicators, error identification, meaningful link text, no keyboard traps, audio controls, motion-induced seizure thresholds) but the items above account for the majority of automated and manual findings on e-commerce storefronts.

Who is in scope under the European Accessibility Act?

Article 4 of Directive 2019/882 applies the obligations to e-commerce services without a threshold. Article 4(5) creates a narrower exemption for microenterprises providing services, defined as fewer than 10 employees and turnover or balance sheet under 2 million euros annually.

Above that threshold the obligation applies. The Act is enforced by national market surveillance authorities. In France, that is the DGCCRF. In Germany, the Bundesnetzagentur and state authorities. In Italy, AgID and AGCOM share competence.

Early EAA enforcement: what authorities are citing

Authorities have been clear that they expect storefronts to have at least an accessibility statement on the site by mid-2026, and an internal audit log of remediation steps.

First three actions

Add alt text to every product image. Make sure every checkout input has an explicit label element. Set the lang attribute on the html element to the primary language of the page. Those three changes will not make a store fully WCAG-compliant but they close the findings most commonly cited in early EAA enforcement.