European Accessibility Act for Ecommerce Stores in 2026: WCAG, Checkout and Microenterprise Rules

European Accessibility Act: key takeaways for ecommerce stores

• The EAA has applied to covered ecommerce services since June 28, 2025.
• The accessible journey includes search, product selection, identification, login, checkout and payment.
• Businesses remain responsible when a theme developer, agency, app or payment provider supplies part of the experience.
• Service microenterprises can be exempt when they have fewer than 10 employees and annual turnover not exceeding €2 million.
• Product images, videos, forms, error messages, CAPTCHA, navigation and customer support can all create barriers.
• An accessibility statement and information about how the service works with assistive technology may be required.
• Accessibility must be maintained after theme, app, product-page and checkout changes.
• Automated scans can help find issues but cannot prove that a real purchase journey works with assistive technology.

What is the European Accessibility Act?

The European Accessibility Act is the common name for Directive (EU) 2019/882. It establishes accessibility requirements for specified products and services, including ecommerce services. Member States implemented the directive through national law, so enforcement procedures and penalties can vary by country.

The EU’s current business guidance on digital accessibility says covered products and services placed on the market after June 28, 2025 must meet the relevant requirements, subject to exemptions and transition provisions.

For a dropshipping store, accessibility is not limited to publishing alt text. It concerns whether a consumer with a visual, hearing, motor or cognitive disability can independently:

• find the product;
• understand the offer;
• choose the correct variant;
• review delivery and return information;
• create an account or continue as a guest;
• complete verification and payment;
• receive necessary documents and support.

Which ecommerce businesses are covered?

An ecommerce service is an online service through which a consumer can conclude a contract. This includes websites and apps where consumers buy, rent, order, subscribe or reserve products or services.

The Dutch Authority for Consumers and Markets—ACM—states in its current ecommerce accessibility guidance that businesses with 10 or more employees, annual turnover above €2 million, or both must ensure their ecommerce service is accessible.

A business established outside the EU should not assume the rules are irrelevant when it directs a covered service to EU consumers. Determine which national law and regulator apply to the actual establishment, target markets and service.

Coverage is about the service, not the ecommerce platform

Shopify, WooCommerce, Magento and custom stores can all be in scope. Using a major platform does not automatically make the merchant’s configured store compliant. Themes, apps, custom code, content and operating choices change the final experience.

How the microenterprise exemption works

Service microenterprises are exempt under the EAA framework when they employ fewer than 10 people and have annual turnover not exceeding €2 million. Both parts of that definition matter.

Confirm how employees, linked enterprises and turnover are calculated under the applicable national rules. Do not use monthly headcount or net profit as a substitute for the legal test.

Why an exempt store should still improve accessibility

An exemption from a particular statutory duty does not make an inaccessible checkout commercially sensible. Accessible design can help older customers, keyboard users, mobile shoppers, people with temporary injuries and customers using slow connections or unfamiliar devices.

Accessibility can also support clearer product information and lower friction—the same goals discussed in our high-converting product-page guide.

Which parts of an online store must be accessible?

ACM explains that accessibility applies to everything related to concluding an agreement online, including searching, choosing, logging in and paying. A store should therefore test the complete journey rather than only the homepage.

Discovery and navigation

• navigation menus operable by keyboard;
• logical heading structure;
• visible keyboard focus;
• search controls with clear labels;
• filters and sorting that work without a mouse;
• skip links or another efficient route to primary content;
• consistent navigation across templates.

Selection and product configuration

• color and size choices identified by text, not color alone;
• variant availability announced to assistive technology;
• quantity controls with accessible names;
• error messages connected to the relevant input;
• clear information about what is included.

Contract and payment

• terms, price, taxes and delivery information available before commitment;
• forms with labels and useful instructions;
• enough time to complete the process;
• accessible identity and payment methods;
• an order-review step that can be understood and corrected;
• accessible confirmation emails and essential attachments.

WCAG 2.1 AA and the 2026 move toward WCAG 2.2

ACM organizes accessibility around four principles:

• Perceivable: information can be seen, heard or otherwise interpreted with assistive technology.
• Operable: controls work with a keyboard, voice input and other interaction methods.
• Understandable: content, navigation and error messages are clear and predictable.
• Robust: the service works with different browsers, devices and assistive technologies.

Its current guidance points to WCAG 2.1 level AA and says WCAG 2.2 level AA is expected to become the new standard during 2026. A store planning work now should therefore test against WCAG 2.2 rather than fixing only older criteria and repeating the project later.

WCAG is a technical standard, not a complete substitute for reading the applicable law. Legal requirements can also cover documentation, customer support, product-accessibility information and administrative processes.

How to make dropshipping product pages more accessible

Use meaningful alternative text

Describe information the image contributes to the purchase decision. “Product image 3” is not useful. For a visual variant, include the relevant color, shape or feature. Decorative images should not create repetitive noise for screen-reader users.

Caption and describe product video

Add synchronized captions for spoken information and meaningful sounds. When important visual action is not explained in the audio, provide an audio description or an equivalent text explanation.

Do not communicate through color alone

Sale status, stock warnings, selected variants and validation errors need text or another non-color indicator. Maintain sufficient text and control contrast.

Write factual, structured product information

Use real headings, lists and tables instead of screenshots containing text. Provide dimensions, material, compatibility, package contents, care instructions and delivery information in selectable text.

This also helps machines understand an offer. Our guide to preparing a store for AI shopping explains why accurate, structured data supports both people and automated discovery.

Make disclosures operable

Accordions, tabs, image galleries, size charts, review widgets and sticky purchase bars should work by keyboard and expose their state to assistive technology. Do not hide essential terms inside a hover-only interaction.

Forms, login, CAPTCHA and checkout barriers

In March 2026, ACM reported that 61% of approximately 100 large Dutch online stores it checked were not digitally accessible. On those sites, people using assistive technology could not complete an order. Examples included purchase buttons that could not be activated by keyboard and inaccessible CAPTCHA challenges. Businesses that fail to improve after regulator contact can face enforcement.

Read the regulator’s 2026 accessibility findings.

Common checkout failures

• inputs identified only by placeholder text;
• focus that disappears inside a modal;
• address suggestions that cannot be chosen by keyboard;
• errors announced only by red borders;
• a disabled purchase button with no explanation;
• timers that expire before the user can complete payment;
• drag-and-drop or visual CAPTCHA with no accessible alternative;
• payment iframes without accessible names;
• order confirmation that does not announce success.

Errors should help the customer recover

Identify the field, explain the problem and tell the customer how to correct it. Move focus to a useful error summary or connect each message programmatically to its field. Preserve valid data so the customer does not need to repeat the form.

Themes, apps, payment providers and third-party content

ACM states that the service provider remains responsible even when another company builds the website or app. A merchant should therefore evaluate vendors before installation and include accessibility in procurement and acceptance tests.

Third-party content exceptions are limited

Some third-party content outside the service provider’s control may receive different treatment. Do not treat every supplier image, app or embedded widget as automatically exempt. If the merchant commissioned, selected, paid for or controls the content, the exception may not fit.

An accessibility overlay is not a complete fix

An overlay cannot reliably repair missing structure, broken keyboard interactions, inaccessible payment flows or unclear content. Fix the underlying code, design and process, then verify the result with real testing.

Accessibility statement, product information and customer support

ACM’s guidance requires an easy-to-find, accessible statement explaining how the service meets the accessibility rules, how it works with assistive tools and how compliance is achieved. It also says the information must be available verbally, for example as an audio version.

A useful statement can include:

• the service and templates covered;
• the accessibility standard used;
• known limitations;
• alternative ways to obtain information or complete a task;
• contact details for accessibility feedback;
• the date and method of the latest review;
• the process and target for correcting issues.

Do not claim “fully accessible” because a scanner returned a high score. The statement should accurately describe current performance.

Product accessibility information

Where required, ecommerce services must make information available about the accessibility of products and services offered. The manufacturer or supplier may provide that information, but the store needs a process to request, validate and display it.

Accessible support

Customer service should provide accessibility information through accessible channels. Train support staff to handle a barrier report without forcing the customer to repeat inaccessible steps.

How to test an ecommerce journey

1. Choose representative journeys. Include search, category browsing, a configurable product, cart, guest checkout, account checkout and refund information.
2. Run automated checks. Use them to find missing names, contrast problems and structural errors.
3. Test keyboard-only operation. Verify logical focus order, visible focus and no keyboard traps.
4. Test with screen readers. Cover desktop and mobile combinations relevant to customers.
5. Zoom and reflow. Confirm content remains usable at increased text size and narrow widths.
6. Check media. Review captions, transcripts and visual-only information.
7. Complete real test orders. Include payment validation, confirmation and transactional email.
8. Involve people with disabilities. Usability testing reveals barriers that technical scans miss.
9. Record defects and owners. Prioritize blockers that prevent browsing or purchase.
10. Retest after changes. Theme and app updates can reintroduce issues.

Accessibility testing should sit beside the transparency review in our Merchant Center misrepresentation checklist. Both require the real customer journey to match the store’s claims.

European Accessibility Act ecommerce checklist

• Determine which national EAA implementation and regulator apply.
• Document employee count and annual turnover for the microenterprise analysis.
• Inventory every storefront template, app and payment path.
• Provide logical headings and landmarks.
• Make navigation, filters, variants and dialogs keyboard operable.
• Use visible focus and sufficient contrast.
• Write useful alternative text and caption product videos.
• Label form fields and connect errors programmatically.
• Offer an accessible CAPTCHA or verification alternative.
• Make login, identity verification and payment accessible.
• Ensure essential emails and documents are accessible.
• Publish an accurate accessibility statement.
• Provide an accessible feedback and support route.
• Collect required product-accessibility information from suppliers.
• Test the complete journey with assistive technology.
• Add accessibility requirements to vendor contracts.
• Retest after every theme, app or checkout change.

Frequently asked questions

Does the European Accessibility Act apply to online stores?

Yes. Ecommerce services are among the services covered by the EAA framework, subject to scope, exemptions and the national law implementing the directive.

Are very small ecommerce businesses exempt?

Service microenterprises with fewer than 10 employees and annual turnover not exceeding €2 million can qualify for an exemption. Verify how the test applies to linked businesses and the relevant national implementation.

Is WCAG certification mandatory?

ACM says an independent audit certificate or accessibility label is not mandatory in the Netherlands. The service itself must be accessible. Requirements and evidence expectations may differ across Member States.

Do I need WCAG 2.2?

ACM’s current guidance points to WCAG 2.1 AA and says WCAG 2.2 AA is expected to become the new standard during 2026. Building and testing against WCAG 2.2 now reduces repeat work.

Does an accessibility plugin make my Shopify or WooCommerce store compliant?

No plugin can guarantee compliance across content, theme code, apps, checkout, payment and customer support. Use tools as part of testing, then repair and verify the underlying experience.

Must the checkout be accessible?

Yes for a covered ecommerce service. The online contracting process includes login, identification, payment, error recovery and confirmation.

What about content supplied by a dropshipping vendor?

Do not assume it is automatically outside the store’s responsibility. If the merchant selects, commissions, edits or controls supplier content, a third-party-content exception may not apply.

Can regulators enforce the rules in 2026?

Yes. National regulators are already supervising ecommerce accessibility. ACM’s 2026 checks found serious purchase barriers and warned that businesses failing to improve can face enforcement.