EAA Outside the EU: Does the European Accessibility Act Apply to Your Store?

Details

Does the EAA reach a store outside the EU?

The EAA applies to covered services provided in the EU, including e-commerce services, from 28 June 2025. It is not limited solely by where a business is established. For a seller based in the US, UK, India or elsewhere, whether a particular service falls in scope depends on the service and the facts of how it is offered to consumers in the EU. The Directive is implemented and enforced through national rules, so confirm your position with a lawyer familiar with the countries where you operate. See the official summary of Directive (EU) 2019/882.

• Identify the service. The EAA covers specified products and services; e-commerce is one of the covered service categories.
• Confirm where and to whom it is provided. Selling from outside the EU does not automatically exclude a service, while merely having a website accessible from the EU does not by itself settle the legal analysis.
• Check the exemption carefully. A microenterprise providing services is exempt if it has fewer than 10 persons and its annual turnover or annual balance sheet total does not exceed €2 million.
• Check the national law. Member States enforce the requirements under their own implementing laws and procedures.

What it asks of an online store

• Accessible service and website features, including key shopping tasks such as finding products, choosing options, using the cart and completing checkout.
• Information about the service, its accessibility features and how it meets the applicable requirements.
• Support channels and processes that address accessibility requests and barriers.

A manual review against WCAG helps assess web content and interactions, and findings can be mapped to relevant EN 301 549 clauses. That technical review is one part of compliance work: it does not replace assessment of the service-specific requirements, documentation or national legal duties.

Which EN 301 549 version should I use?

ETSI published EN 301 549 V4.1.1 in September 2026, updating the web accessibility baseline to WCAG 2.2. The European Commission's AccessibleEU centre says V4.1.1 is not yet the legal reference for demonstrating conformity with the EAA until formally cited in the Official Journal; V3.2.1 remains the cited reference in the meantime. Teams can use WCAG 2.2 for forward-looking testing, while clearly identifying the version used and checking the current legal reference before making a conformance claim. See the AccessibleEU update on EN 301 549 and ETSI's published standards list.

Penalties differ by country

Each Member State has its own enforcement procedures and penalties under its implementing law. Confirm the rules for the countries and services in scope; a single Europe-wide penalty estimate is not a reliable guide.

A realistic plan for a store outside the EU

1. Check scope. List the EU countries you sell to.
2. Audit the key journeys. Home, search, product, cart, checkout, account and contact, tested by hand.
3. Fix what blocks purchases first. Keyboard access, labels, announcements and contrast.
4. Publish accessibility information and a contact route for barriers.
5. Retest and keep dated records.

What my audit gives you

• Every finding mapped to its EN 301 549 clause (web content is clause 9) as well as its WCAG criterion
• The same audit also covers the ADA and Section 508 if you sell in the US
• An optional ACR in the EN 301 549 edition as a $300 to $500 add-on
• A free retest after your fixes, and the same prices for US and EU work

Start with the 13-step EAA checklist or see what changed in EN 301 549 V4.1.1.

For audit scope and rates, see website accessibility audit pricing or review a sample accessibility audit report.

Who does the work

I'm Rohit Yadav, a DHS Trusted Tester (Section 508) and accessibility auditor with about five years of hands-on testing. Every audit is done by me, by hand, with a keyboard and NVDA, JAWS and VoiceOver, against WCAG 2.2 AA. About me · See a sample report

Common questions

Does the European Accessibility Act apply to my US store?

If you sell to consumers in EU countries, it may. If you don't sell to the EU, it likely doesn't. Ask a lawyer who knows the rules of the countries you sell to.

Do I need an accessibility statement?

The Act expects providers to give consumers information about how the service meets the accessibility requirements, and several countries expect a published statement. Ask your lawyer what each country you sell to requires.

Will an accessibility widget make my store comply?

No. Widgets don't fix the underlying code. Read why.

Which version of EN 301 549 should I test against?

ETSI published V4.1.1 in September 2026 and it is based on WCAG 2.2. Until the European Commission cites it in the Official Journal for the EAA, V3.2.1 remains the cited harmonised reference. A WCAG 2.2 audit is useful preparation, but do not describe it alone as proof of EAA conformity.

Do EU audits cost more?

Not with me. The audit and the price are the same, and each finding is mapped to its EN 301 549 clause.