European Accessibility Act Checklist for Online Stores
If you sell to consumers in the EU, the European Accessibility Act has applied to your store since 28 June 2025. Here is a step-by-step checklist you can run, in the order I'd run it.
The short answer
The European Accessibility Act (EAA) has applied since 28 June 2025 to online stores and other consumer services selling in the EU, including businesses based outside the EU. For web content, the technical benchmark is EN 301 549, which is based on WCAG 2.1 AA today and on WCAG 2.2 AA in the new V4.1.1 published in September 2026. This checklist turns that into checks your team can run.
Step 0: check whether it applies to you
- You sell to consumers in the EU: the EAA likely applies, even if your business is outside the EU.
- You are a microenterprise providing services: fewer than 10 employees and an annual turnover or balance sheet of €2 million or less. Microenterprises are exempt for services.
- You sell only to businesses: the EAA focuses on consumers, but public bodies and large buyers often ask for EN 301 549 conformance.
Confirm your own situation with a lawyer who knows EU and national law. See the EU audit page for the overview.
The checklist
1. List your key journeys
Write down the paths that make you money: find a product, filter, open a product page, add to cart, check out, pay, create or log in to an account, and contact support. Test these first.
2. Test everything with a keyboard only
Use Tab, Shift+Tab, Enter, Space, Escape and the arrow keys. Every menu, filter, size picker, cart drawer and checkout step must work without a mouse. (WCAG 2.1.1)
3. Check that focus is visible and in a sensible order
You should always see where you are, and focus should move in the order the page reads. Sticky headers and cookie banners must not hide the focused item. (WCAG 2.4.3, 2.4.7, and 2.4.11 in WCAG 2.2)
4. Test with a screen reader
Use NVDA on Windows or VoiceOver on a Mac or iPhone. Icon buttons need names, form fields need labels, and changes like "added to cart" must be announced. (WCAG 4.1.2, 4.1.3, 1.3.1)
5. Review product images and alt text
Informative images need a short description. Decorative images, or images that only repeat adjacent text, need an empty alt attribute. (WCAG 1.1.1)
6. Fix forms and error messages
Every checkout field needs a visible label. Errors must say what went wrong, be linked to the field, and be announced. Don't ask customers to re-enter information they already gave. (WCAG 3.3.1, 3.3.2, 3.3.7)
7. Check contrast, zoom and touch targets
Normal text needs a contrast ratio of at least 4.5 to 1. The page must work at 200% text size and reflow at 400% zoom without sideways scrolling, and tap targets should be at least 24 by 24 CSS pixels. (WCAG 1.4.3, 1.4.4, 1.4.10, 2.5.8)
8. Test menus, filters, carousels and pop-ups
These custom components cause most checkout-blocking problems. Check that each has a name, announces its state (open, closed, selected), and that pop-ups can be closed with Escape. (WCAG 2.1.2, 4.1.2)
9. Add captions and transcripts to video and audio
Product videos and promotional clips need captions, and audio-only content needs a transcript. (WCAG 1.2.1, 1.2.2)
10. Check PDFs and downloads
Size guides, manuals, invoices and menus in PDF must be tagged and readable by screen readers. Scanned images of text are not accessible. (PDF/UA, WCAG 1.1.1)
11. Include third-party tools in your testing
Payment pages, chat widgets, review apps and consent banners are part of your store from the customer's point of view. Ask each provider for its accessibility conformance report (ACR), and test the flows yourself.
12. Provide accessibility information and a contact route
The EAA expects service providers to give consumers information about the accessibility of their service, and several countries expect a published accessibility statement. Include a way for customers to report a barrier. Ask your lawyer what your countries require.
13. Fix, retest and keep records
Fix the issues in your theme and templates, retest the key journeys, and keep dated notes of what you tested and changed. Repeat the checks whenever you add features or apps.
Why it matters now
Each EU country sets its own penalties. Germany's law allows fines of up to €100,000 per violation, and in November 2025 French disability rights organizations filed the first lawsuits under the EAA, against four large retailers. Enforcement practice changes quickly, so check the current rules in each country where you sell.
What an overlay can't do
Accessibility overlays don't fix the underlying code of your theme or apps, and they are not a substitute for these checks. Read why widgets don't protect you.
Next steps
If you'd like these checks done for you, my audits cover every item above and map each finding to its EN 301 549 clause. See what changed in EN 301 549 V4.1.1, or how the ADA, Section 508, the EAA and EN 301 549 relate.
This article is general information, not legal advice. For questions about your legal obligations or a claim you have received, talk to an attorney.