---
title: "The European Accessibility Act and online stores: what it requires and who is exempt"
description: "Since 28 June 2025 the European Accessibility Act requires consumer-facing online stores in the EU to be accessible to people with disabilities. Microenterprises that provide services are exempt, but the test is narrower than most summaries say: fewer than 10 persons and a turnover or balance sheet not exceeding 2 million euro. We checked the claims in an AI research report against the directive text and found the threshold misstated."
date: 2026-10-11
lang: en
canonical: https://goingstellar.ro/research/european-accessibility-act-online-stores/
author: Going Stellar
publisher: GOING STELLAR S.R.L.
topic: Desk research / accessibility law
license: CC BY 4.0
alternate_ro: https://goingstellar.ro/ro/cercetare/actul-european-accesibilitate-magazine-online/
---

# The European Accessibility Act and online stores: what it requires and who is exempt

*Since 28 June 2025 the European Accessibility Act requires consumer-facing online stores in the EU to be accessible to people with disabilities. Microenterprises that provide services are exempt, but the test is narrower than most summaries say: fewer than 10 persons and a turnover or balance sheet not exceeding 2 million euro. We checked the claims in an AI research report against the directive text and found the threshold misstated.*

> Desk research · accessibility law · 2026-10-11 · https://goingstellar.ro/research/european-accessibility-act-online-stores/

## Key points

- The European Accessibility Act has applied to e-commerce services offered to consumers in the EU since 28 June 2025, whatever the store sells.
- A microenterprise under the European Accessibility Act employs fewer than 10 persons and has a turnover or a balance sheet total not exceeding 2 million euro; microenterprises providing services are exempt.
- The microenterprise exemption covers services only; microenterprises dealing with products get lighter documentation duties, not an exemption.
- A covered online store must publish, in its terms and conditions or an equivalent document, how its service meets the accessibility requirements.
- An accessibility overlay script does not make a store compliant; login, checkout and payment have to be accessible in the store's own code.

## The short answer

The European Accessibility Act, Directive (EU) 2019/882, requires an online store that sells to consumers in the EU to make its website and app accessible to people with disabilities from 28 June 2025. A store run by a **microenterprise**, defined as an enterprise that employs fewer than 10 persons and has an annual turnover *or* an annual balance sheet total not exceeding 2 million euro, is exempt from the accessibility requirements for services.

Everyone else selling online to consumers must meet the requirements, publish information on how the store meets them, and correct non-conformities. Penalties are set by each Member State. In Romania the directive was transposed by Law 232 of 19 July 2022.

## Why online stores are covered

The European Accessibility Act lists the services it covers in Article 2(2). Point (f) of that list is **e-commerce services**, which Article 3(30) defines as services provided at a distance, through websites and mobile device-based services, by electronic means and at the individual request of a consumer with a view to concluding a consumer contract. A web shop or a shopping app aimed at consumers fits that definition directly.

Recital 43 of the directive adds that the e-commerce obligations apply to the online sale of *any* product or service. An online store is therefore in scope because of how it sells, not because of what it sells. A shop selling garden furniture is covered in the same way as a shop selling e-readers.

The directive is aimed at business-to-consumer selling. A purely business-to-business shop does not meet the definition, because the definition requires a consumer contract.

## What the European Accessibility Act requires of an online store

Annex I of the directive sets the accessibility requirements. For websites and mobile apps the core requirement is that they are made accessible in a consistent and adequate way by making them **perceivable, operable, understandable and robust**. These four principles are the same ones used by the Web Content Accessibility Guidelines (WCAG) and by the EU Web Accessibility Directive for public sector sites.

Annex I, Section IV, point (g) adds three requirements specific to e-commerce services: providing the information on the accessibility of the products and services being sold, when the responsible economic operator provides it; ensuring the accessibility of identification, security and payment functionality when delivered as part of a service; and providing identification methods, electronic signatures and payment services that are perceivable, operable, understandable and robust. In practice this puts login, checkout and payment at the centre of the obligation.

Article 13 sets the duties of service providers. A store must prepare information explaining how its service meets the accessibility requirements and make it available to the public in written and oral format, in a way that is itself accessible. Annex V says this information goes into the **general terms and conditions or an equivalent document**, and should include a description of the service, how it operates, and how the requirements of Annex I are met. This is the legal basis for the accessibility statement many stores now publish.

Article 13 also requires procedures that keep the service conforming as it changes, corrective measures when it does not conform, and, where the service is not compliant, informing the competent national authorities with details of the non-compliance and the corrective measures taken.

## Who is exempt, and what the exemption does not cover

Article 4(5) states that **microenterprises providing services** are exempt from complying with the accessibility requirements and from any obligations relating to compliance with those requirements. An online store is a service under the directive, so a microenterprise running an online store is outside these duties.

The definition in Article 3(23) has two parts, and both matter. The enterprise must employ fewer than 10 persons. And it must have an annual turnover not exceeding 2 million euro *or* an annual balance sheet total not exceeding 2 million euro. A business with 8 people and a turnover above the cap can still be a microenterprise if its balance sheet stays under the cap.

The exemption for services is not an exemption for products. For microenterprises dealing with products, Article 14(4) only removes the requirement to document a disproportionate-burden assessment, and Article 14(8) removes the duty to notify authorities. A small business that manufactures, imports or distributes a product covered in its own right by the directive, such as an e-reader, still has product obligations.

Larger stores have a separate escape route that is often misunderstood. Under Article 14, the requirements apply only to the extent that compliance does not fundamentally alter the service or impose a **disproportionate burden**. A store relying on this must document its assessment against the criteria in Annex VI, keep the results for five years, renew the assessment at least every five years for services, and inform the authorities. It cannot rely on it if it received funding for improving accessibility.

## Dates, transition and what is excluded from scope

Member States had to transpose the directive by 28 June 2022 and apply it from 28 June 2025. Article 32 allows service contracts agreed before 28 June 2025 to continue without alteration until they expire, but for no longer than five years from that date, and sets a transitional period ending on 28 June 2030 for services provided using products already lawfully used before that date.

Article 2(4) excludes some website content: pre-recorded time-based media and office file formats published before 28 June 2025, certain online maps, archived content, and third-party content that is neither funded, developed by, nor under the control of the economic operator. Content a store commissions or controls, including its theme and its checkout, is not third-party content in that sense.

## Which standard to test against

Article 15 gives a **presumption of conformity** to services that follow harmonised standards whose references are published in the Official Journal of the EU. The European standard for digital accessibility is EN 301 549. ETSI published version 4.1.1 on 2 September 2026, which moves the web requirements to WCAG 2.2 Level AA and adds material mapping the standard to the European Accessibility Act.

On 11 October 2026 we could not confirm that any version of EN 301 549 has been cited in the Official Journal under the European Accessibility Act. Until a citation is published, following the standard is good evidence of effort but does not by itself give the legal presumption. Testing against WCAG 2.2 Level AA is the practical target either way.

## What enforcement looks like so far

The Dutch consumer authority, ACM, published results on 24 March 2026 from tests on about 100 of the largest Dutch online stores and the sites of the largest telecom and energy providers. ACM found that at **61%** of the largest online stores a customer using assistive technology could not place an order, for example because the order button could not be reached by keyboard or the CAPTCHA was inaccessible. A further 33% had serious problems. ACM said companies that do not improve enough risk enforcement action.

Accessibility overlays are not a shortcut. In April 2025 the US Federal Trade Commission approved a final order against the widget vendor accessiBe, after alleging that its product did not make all user websites WCAG-compliant. The order bars the company from claiming its automated products make any website compliant unless it has evidence. The case is American, but the finding about what a script can and cannot fix applies anywhere.

## Method

We started from an AI deep-research report on web accessibility and the European Accessibility Act. We read it in full, selected the claims that matter to a store owner, and checked each one on 11 October 2026 against the directive text on EUR-Lex, the ETSI publication record, the Dutch regulator's announcement, the US FTC press release and the EU AccessibleEU record of the Romanian law. Only claims we could confirm at those sources are kept.

We dropped the report's market and pricing material, its figures on vendor revenue and lawsuits, its company-size statistics and its French enforcement details. The French regulator's pages refused automated access, so we could not confirm the fine amounts and inspection counts the report gave.

## Where the report was wrong

**The microenterprise threshold was misstated.** The report described the exemption as fewer than 10 employees and turnover below 2 million euro, and elsewhere as applying to providers below both thresholds. The directive uses persons, not employees, and the financial test is turnover *or* balance sheet, each not exceeding 2 million euro. The report then advised targeting stores that exceed either threshold, which would wrongly include some microenterprises.

**It relied on regulators' summaries instead of the law.** The Dutch regulator describes covered businesses as having 10 or more employees and/or turnover above 2 million euro. Read literally, that short summary omits the balance-sheet alternative. The directive text is the reference.

**It treated the exemption as general.** The report did not say that the exemption covers microenterprises providing services only. Microenterprises dealing with products get lighter paperwork, not an exemption.

**It left out the parts a store needs to act on:** the accessibility information required in the terms and conditions, the transitional rules, the disproportionate-burden procedure and the status of the harmonised standard.

## Limitations

This is a reading of the directive, not legal advice. National transpositions can add detail, including penalties, authorities and how the size test is calculated, and we checked only the existence and date of the Romanian law, not its text.

We did not verify whether EN 301 549 has been cited in the Official Journal since our check, and that status may change soon after publication. We report one regulator's test results; they describe the largest Dutch stores, not stores in general.

## Sources

1. [Directive (EU) 2019/882 on the accessibility requirements for products and services (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019L0882)
2. [ETSI EN 301 549 publication record (versions up to V4.1.1)](https://www.etsi.org/deliver/etsi_en/301500_301599/301549/)
3. [Deque: EN 301 549 v4.1.1 is final](https://www.deque.com/blog/en-301-549-v4-1-1-is-final-what-changed-what-it-means-and-what-you-should-do/)
4. [ACM: customers with a disability cannot shop at most large webshops (24 March 2026)](https://www.acm.nl/nl/publicaties/acm-klant-met-beperking-kan-bij-merendeel-grote-webwinkels-niet-terecht)
5. [FTC approves final order requiring accessiBe to pay (April 2025)](https://www.ftc.gov/news-events/news/press-releases/2025/04/ftc-approves-final-order-requiring-accessibe-pay-1-million)
6. [AccessibleEU: Romanian Law 232 of 19 July 2022 on accessibility requirements for products and services](https://accessible-eu-centre.ec.europa.eu/content-corner/digital-library/lege-nr-232-din-19-iulie-2022-privind-cerintele-de-accesibilitate-aplicabile-produselor-si_en)

## Questions and answers

### Does the European Accessibility Act apply to my online store?

The European Accessibility Act applies to an online store that sells to consumers in the EU, because e-commerce services are listed in Article 2(2)(f) of Directive (EU) 2019/882. It has applied since 28 June 2025 and covers the online sale of any product or service. A store run by a microenterprise is exempt from the service requirements, and a purely business-to-business shop falls outside the definition of e-commerce services.

### What counts as a microenterprise under the European Accessibility Act?

Under Article 3(23) of the European Accessibility Act, a microenterprise employs fewer than 10 persons and has an annual turnover not exceeding 2 million euro or an annual balance sheet total not exceeding 2 million euro. Both conditions apply: the headcount test and one of the two financial tests. Microenterprises providing services, including online stores, are exempt from the accessibility requirements for services.

### Are small businesses that sell products exempt from the European Accessibility Act?

Small businesses that sell products are not fully exempt from the European Accessibility Act. The exemption in Article 4(5) applies to microenterprises providing services. Microenterprises dealing with products covered by the directive, such as e-readers, only get lighter duties: they do not have to document a disproportionate-burden assessment or notify authorities about it. Their online store, as a service, falls under the services exemption if they qualify as a microenterprise.

### Which standard should an online store test against for the European Accessibility Act?

Online stores usually test against EN 301 549, the European standard for digital accessibility. Version 4.1.1, published by ETSI on 2 September 2026, uses WCAG 2.2 Level AA for web content. A legal presumption of conformity under Article 15 needs the standard to be cited in the Official Journal under the European Accessibility Act, which we could not confirm on 11 October 2026.

### Does an accessibility widget make a store compliant with the European Accessibility Act?

An accessibility widget does not make a store compliant with the European Accessibility Act on its own. The directive requires the service itself, including checkout, identification and payment, to be perceivable, operable, understandable and robust. In April 2025 the US Federal Trade Commission finalised an order against the widget vendor accessiBe after alleging its product did not make all user websites WCAG-compliant.

### What must an online store publish under the European Accessibility Act?

A covered online store must publish information explaining how its service meets the accessibility requirements, under Article 13 and Annex V of the European Accessibility Act. Annex V places this information in the general terms and conditions or an equivalent document, with a description of the service, how it operates and how the Annex I requirements are met. The information must itself be accessible.

## How to cite

**Cite this as:** Going Stellar (2026). *The European Accessibility Act and online stores: what it requires and who is exempt*. GOING STELLAR S.R.L.. https://goingstellar.ro/research/european-accessibility-act-online-stores/

```bibtex
@misc{goingstellar2026european,
  title  = {The European Accessibility Act and online stores: what it requires and who is exempt},
  author = {{Going Stellar}},
  year   = {2026},
  url    = {https://goingstellar.ro/research/european-accessibility-act-online-stores/},
  note   = {2026-10-11}
}
```

Licence. Free to quote with attribution.

## Also available

- This page as HTML: https://goingstellar.ro/research/european-accessibility-act-online-stores/
- Same article in Romanian: https://goingstellar.ro/ro/cercetare/actul-european-accesibilitate-magazine-online/