European Accessibility Act: What US Ecommerce Must Do

You run a store in Ohio. You have never had an office in Europe, never filed a European tax return, never thought about Brussels for a single working day. And since 28 June 2025, a European law has applied to your website.

That catches most US sellers off guard. It caught a lot of European ones off guard too.

Here is what the European Accessibility Act actually requires, who it actually covers, and what to do if you are reading this and realising you are already late.

Why an EU law reaches a US business

The EAA does not follow your company. It follows your customers.

If you sell to consumers in the EU, the law applies — whatever your incorporation, wherever your servers sit, whoever hosts your checkout. The test is whether you offer a service into that market. A Shopify store in Texas that ships to Ireland offers a service into that market.

This is the same logic as GDPR. Most US businesses eventually understood that GDPR followed the data subject rather than the company. The EAA follows the consumer in exactly the same way, and a lot of the businesses that adjusted for GDPR have not connected the two.

So the first question is not “are we a European company.” It is: do EU consumers buy from us? Check your order data. If the answer is yes, keep reading.

What the deadline actually was

28 June 2025. Not a phase-in, not a grace period. That was the date the requirements became enforceable across EU member states.

There are narrow transition provisions for service contracts agreed before that date, and for certain self-service terminals already in use. Those are genuinely narrow. If you are hoping one applies to your ecommerce site, you almost certainly need a lawyer to tell you so, not a blog post.

The practical position for most online sellers: the deadline has passed, and the obligation is live.

The standard you are measured against

The EAA is a directive. It sets out functional requirements — information must be perceivable, operable, understandable, robust — without listing every technical rule.

In practice, conformance is assessed against EN 301 549, the European accessibility standard, which incorporates WCAG 2.1 Level AA.

If you have already done ADA work in the US against WCAG 2.1 AA, a good deal of that effort carries over. The technical requirements overlap heavily. What does not carry over is the documentation, which the EAA treats far more seriously than US practice generally does.

What this means page by page

Abstract standards are hard to act on, so here is what actually fails on ecommerce sites, in the order I tend to find it.

Product images with no real alternative text

Not “IMG_4471.jpg.” Not “product photo.” A description that tells someone who cannot see the image what they need to know to decide whether to buy it. Colour, material, what is actually shown. This is SC 1.1.1, and it is the most common failure in online retail by a wide margin.

Checkout that cannot be completed with a keyboard

Try it yourself. Unplug your mouse, load your own site, and buy something. Tab through it. Most people who do this for the first time do not reach the payment step. Custom dropdowns, date pickers and payment iframes are where it usually breaks.

Form errors nobody can hear

A red border around a field communicates nothing to a screen reader user. Errors need to be announced, identified in text, and connected to the field they describe — SC 3.3.1 and SC 3.3.3. On a checkout form, this is the difference between a completed order and an abandoned one.

Contrast that fails on your own brand colours

Body text needs 4.5:1 against its background under SC 1.4.3. Light grey on white is the usual offender, and it usually comes from a designer who was never told the threshold. Sale prices in a pale accent colour are another frequent one.

Focus you cannot see

Many themes remove the browser’s default focus outline because someone thought it looked untidy. For a keyboard user, that is the cursor. Removing it without a visible replacement fails SC 2.4.7 and makes the site genuinely unusable.

Video without captions

Product demonstrations, brand films, anything with speech. Auto-generated captions are a starting point, not a finish line — they mangle product names and technical terms reliably.

What this looks like in practice

Three examples, anonymised, of sites that looked fine until someone tested them properly.

A Shopify retailer came to us thinking their site was mostly ready — the homepage looked clean and the scanner report showed nothing serious. The problem was inside the checkout. A keyboard user could add a product to the cart but could not reliably move through the payment and shipping fields. That is not cosmetic. It was stopping some customers from completing a purchase.

Another eCommerce brand had alt text on product images across the whole site, so on paper the task looked done. Most of it repeated the same few words — “product image”, “photo” — with no colour, style, size or description of the actual item. Technically the page had alt text. It still gave a screen reader user nothing they could choose a product with.

A third client had straightforward forms: name, email, address, payment. Under manual testing the error messages appeared on screen but were not announced properly to screen reader users, so someone could make a mistake and never learn what needed fixing. Easy to miss in a quick review, and it decides whether a customer can complete the task on their own.

Are you exempt? Probably not

Article 4(5) exempts microenterprises from the service requirements. People latch onto this, so be precise about it.

A microenterprise has fewer than 10 employees and an annual turnover under €2 million. Both. Nine employees and €3 million in revenue is not exempt. Twelve employees and €500,000 is not exempt.

Two further points that get missed:

• The exemption covers services, not products. If you manufacture or distribute a covered product, the product requirements still apply.
• It is assessed on your current position. Grow past either threshold and the obligation arrives with the growth.

Most businesses that ask me whether they are exempt are not exempt. It is worth checking properly rather than hoping.

What enforcement looks like

The EAA is implemented separately by each member state, so penalties and procedures vary. Broadly, national authorities can investigate complaints, require remediation, impose fines, and in serious cases restrict a service in that market.

I would be cautious about anyone quoting you a single scary number. The penalties genuinely differ country by country, and a consultant who tells you otherwise is selling on fear rather than fact.

The more realistic risk for most sellers is quieter. A complaint from a customer. A procurement process that asks for conformance documentation you do not have. A marketplace or platform partner tightening its own requirements. These arrive sooner than regulators do.

And there is the plainest cost of all, which has nothing to do with law: customers who cannot complete a purchase do not complete it. They leave. They rarely tell you why.

What to do if you are behind

Being late is not unusual. It is recoverable. What matters is that you are moving and can show it.

1. Establish where you stand

You cannot plan against a site you have not tested. That means manual testing, not just a scanner — automated tools reliably catch around 30% of WCAG failures and are blind to most of what breaks a checkout. This is the work I do through EcomBack, a court-approved accessibility provider.

2. Fix the purchase path first

Search, product page, cart, checkout, account creation. If a customer cannot complete those, nothing else you fix matters commercially.

3. Fix components, not pages

Ecommerce sites are templated. One broken form component is broken on every page that uses it. Fix it at source and the defect disappears everywhere at once — and stops reappearing on the next page you build.

4. Write it down

The EAA expects documentation. Keep an accessibility statement that honestly describes your current conformance, a record of what you have fixed and when, and a plan with dates for what remains. Demonstrable progress is a far stronger position than silence.

5. Do not install an overlay

Overlay widgets promise compliance from a line of JavaScript. They have been named in US ADA litigation rather than preventing it, and many people who use assistive technology report that overlays actively interfere with the tools they already rely on. An overlay does not fix your markup. It sits on top of it.

The part worth saying plainly

Compliance is the reason most businesses start. It is rarely the reason they are glad they did.

The work that satisfies WCAG is the same work that makes a site clearer: labelled forms, visible focus, readable contrast, sensible structure, images described properly. Those changes help the customer on a phone in bright sunlight, the customer with a trackpad they find fiddly, the customer who is sixty-eight and does not describe themselves as disabled.

Around one in four adults has a disability. On an ecommerce site, they are not an edge case. They are a segment you are currently turning away at checkout without knowing it.

Where to start

If you sell into the EU and have not tested your site against WCAG 2.1 AA, start with an audit. You will get findings mapped to specific success criteria, ordered by what actually blocks a purchase, with the changes required to fix them.

See accessibility services or book a consultation. If you have had a complaint or a legal letter, say so when you write — those move to the front.

I am a web accessibility specialist and ADA compliance consultant, a participant in the W3C Accessibility Guidelines Working Group and a DHS Trusted Tester. I am not an attorney and this is not legal advice. For your specific exposure under the EAA or the ADA, speak to qualified counsel — I work alongside legal teams and supply the technical evidence they need. More about my background.