EU Accessibility Act for ecommerce websites

Directive (EU) 2019/882 defines e-commerce services 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. That makes the scoping question practical: identify every consumer journey where a user can select, configure, order, subscribe, reserve, pay for, or otherwise conclude a contract online.

The directive also says ecommerce accessibility obligations apply to the online sale of any product or service, including items that are themselves covered elsewhere in the directive. A retailer should therefore avoid limiting the review to regulated product categories; the online sales service is the trigger.

Record the service provider and every Member State in which the service is offered to consumers. The service-provider duty is to design and provide the covered service in accordance with the applicable requirements, publish the Annex V information, monitor continued conformity, correct non-conformity, and inform the competent national authorities when the Directive requires it.

Annex I requires covered services to provide accessible information about how the service functions and to make websites, online applications, mobile services, and mobile applications perceivable, operable, understandable, and robust. For an ecommerce team, that means the audit must follow the buying task, not only isolated page templates.

The ecommerce-specific requirements add three concrete workstreams: provide accessibility information about the products and services being sold when the responsible economic operator provides that information; make identification, security, and payment functionality accessible when delivered as part of the service; and make identification methods, electronic signatures, and payment services perceivable, operable, understandable, and robust.

Article 13 requires service providers to prepare information explaining how their services meet the applicable accessibility requirements, make that information public in written and oral format, and keep it for as long as the service operates. Annex V says the information belongs in the general terms and conditions or an equivalent document and must describe the service, the operation of the service, and how the relevant Annex I requirements are met.

The evidence file should be usable by product, legal, support, procurement, and authority-response teams. It should show the journey tested, requirements applied, standards or technical specifications used, defects found, remediation decisions, vendor evidence relied on, and how monitoring keeps the service conformant when the service, standards, or accessibility requirements change.

The directive allows accessibility requirements to apply only to the extent that compliance does not fundamentally alter the basic nature of the product or service and does not impose a disproportionate burden. For ecommerce services, that is an evidence-backed assessment, not a shortcut: service providers relying on disproportionate burden must renew the assessment when the service changes, when authorities request it, and at least every five years.

Microenterprises providing services are exempt from the service accessibility requirements and related obligations in Article 4(5). The Directive defines a microenterprise as employing fewer than 10 people and having annual turnover or an annual balance-sheet total no higher than EUR 2 million. Other ecommerce providers should not use that exemption. The Directive also includes transitional rules for products already used to provide similar services until 28 June 2030 and for service contracts agreed before 28 June 2025 until expiry or, at the latest, 28 June 2030. Those rules do not create a general extension for an existing website or app. Document the exact product or unaltered contract relied on and the national implementation.

Base the ecommerce implementation plan on the transaction path and require a release decision. Each release that can affect the consumer's ability to conclude a contract should carry accessibility acceptance criteria and evidence before it ships.