By Ariel Yosefi and Yuval Ram

In just 4 months, effective 28 June 2025, the European Accessibility Act (“EAA”) will apply across the European Union through national implementing legislation in each member state.

Scope of Application

The EAA imposes harmonized accessibility requirements on a wide spectrum of products and services, including e-commerce services, as well as other consumer-facing digital services, such as online retail websites and subscription-based digital services. Payment service providers and checkout systems integrated into digital platforms are also covered.

The EAA 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.” Its provisions apply to services provided on the EU market or to consumers in the EU, regardless of whether the provider is located inside or outside the EU.

B2B platforms that exclusively serve professional users are generally exempt. However, mixed-use platforms operating in both B2B and B2C environments must assess their obligations carefully. Since national transposition rules vary, businesses should evaluate jurisdiction-specific requirements.

Key Requirements for E-Commerce Services

Accessible digital platforms – e-commerce service providers must design and maintain websites and mobile apps in line with recognized accessibility standards (including WCAG 2.1 or EN 301 549). This entails ensuring that layout structures, color contrasts, navigation elements, and interactive features accommodate users reliant on assistive technologies such as screen readers or keyboard-only navigation.

Transparent product and service information – all consumer-facing materials – ranging from product descriptions and pricing details to terms of service – should be provided in formats that are perceivable, understandable, and easily navigable by users with different forms of disabilities.

Transaction flows and customer support – E-commerce functionalities covering user registration, account management, payment processing, authentication and post-sale support shall address accessibility considerations. This includes clear error messages, alternative text or labels for essential fields, and user support channels that can effectively respond to accessibility-related inquiries.

Exemptions

The EAA includes several exemptions, including:

• Microenterprises, defined as those employing fewer than 10 persons and having an annual turnover or balance sheet total not exceeding EUR 2 million, are generally exempt from complying with the accessibility requirements for services;
• Several types of content predated to the applicability date;
• Third-party content that is neither funded, developed by, or under the control of the service provider.

The EAA also permits an exemption in cases where compliance would result in a “disproportionate burden.” To rely on this exemption, companies must perform a detailed, evidence-based assessment, documenting technical feasibility, financial impact and mitigation strategies. Providers invoking this exemption should maintain comprehensive records, including justifications and attempted compliance measures.

Implementation and Enforcement

Under the EAA, each member state implements the directive via its own national legislation. Consequently, grace periods, transitional measures (i.e., extension periods subject to specific requirements), as well as penalties for non-compliance, vary depending on the local legislation’s approach.

The rules on penalties applicable to infringements of the EAA’s principles as adopted by national legislation should be also laid down by each member state, which are required to “take all measures necessary to ensure that they are implemented.” The penalties shall be effective, proportionate and dissuasive, and accompanied by effective remedial action in case of non-compliance.

With the compliance date swiftly approaching and national transposition measures varying among member states, e-commerce businesses should promptly assess their obligations to minimize compliance risks, monetary penalties and potential reputational harm. Feel free to contact us if you have any questions regarding the upcoming regulatory requirements and their practical implications.