Accessibility and the European Accessibility Act: what to check on an online shop

In short: Since 28 June 2025 the European Accessibility Act (EAA, Directive (EU) 2019/882, transposed in Italy by Legislative Decree 82/2022) has applied, and it covers e-commerce services aimed at consumers. Microenterprises that provide services are exempt. The technical reference is WCAG level AA, to be checked with manual tests as well as automated tools.

The European Accessibility Act (Directive (EU) 2019/882) is transposed in Italy by Legislative Decree 82/2022. Since 28 June 2025 it has applied to a range of digital products and services. These include e-commerce services aimed at consumers. An accessible website is one that people with visual, motor, hearing or cognitive disabilities can actually use.

This is a practical guide, not legal advice: check your own case with a professional.

Who is covered

• Anyone selling online to consumers in the European Union. In Italy, enforcement is in the hands of AgID, the Agency for Digital Italy.
• There are exemptions for microenterprises that provide services: fewer than ten people and an annual turnover or balance sheet total of no more than €2 million. The exemption covers services, not products, so it needs checking carefully.
• Businesses that sell only to other businesses (B2B) fall outside the directive as far as consumer e-commerce is concerned. An accessible website is still a sound choice.

The technical reference: WCAG

The most widely used technical reference is the WCAG (Web Content Accessibility Guidelines) at level AA, in version 2.1, as cited by the European standard EN 301 549. Version 2.2 adds a few criteria, and it's worth taking them into account. There are four goals: content that is perceivable, operable, understandable and robust.

What to check first on an online shop

Keyboard navigation

Try using the site with nothing but the Tab key, Enter and the arrow keys. Can you reach the menu, search, filters, basket and payment? Can you see where you are at every step (the focus outline)? A menu that opens only with a mouse is a dead end.

Alternative text for images

Every image that carries information has alternative text describing it. Purely decorative images have empty alternative text, so screen readers skip them.

Contrast and size

Text must have enough contrast with its background (at least 4.5:1 for normal text). It must be possible to enlarge it to twice its size without breaking the page.

Forms and checkout

Every field has a visible label linked to it. Errors are described in words next to the field, not just shown in red. Customers can correct mistakes without losing what they've already entered.

Page structure

Headings in order (a single main heading and consistent subheadings) and buttons that say what they do ('Add to basket', not 'Click here'). A correctly declared language.

Video and audio

Subtitles for videos and a transcript for audio-only content.

Animations and pop-ups

No flashing. Respect for the user's setting to reduce motion. Windows that can be closed with the keyboard.

The accessibility statement

For the services covered, you need to tell customers about the accessibility features and known limitations, with a way to report problems. It's a page on the website that has to be kept up to date. Adding a badge isn't enough.

Automated tools aren't enough

Checkers such as Lighthouse or WAVE find many errors but not all of them: they cover only part of the problems. Manual tests with a keyboard and a screen reader are needed too, ideally carried out by people who use them every day. So-called 'overlays' (widgets that promise to make a site accessible with one line of code) are no substitute for work on the site itself.

A four-step plan

1. Check the key pages: home page, category, product page, basket, payment, account and contact.
2. List the problems in order of severity (those that stop someone completing a purchase come first).
3. Fix them in the theme and plugins. Some problems come from third-party components that need replacing.
4. Repeat the check after every major change and publish the statement.

Further reading: mandatory information for an online shop · a slow website sells less · website care and maintenance

Frequently asked questions

When does the European Accessibility Act apply from?

From 28 June 2025. Directive (EU) 2019/882 was transposed in Italy by Legislative Decree 82/2022.

Are microenterprises exempt?

Microenterprises that provide services are exempt from the accessibility requirements for services (Article 4(5) of the directive; in Italy, Article 3(3) of Legislative Decree 82/2022). A microenterprise has fewer than ten people and an annual turnover or balance sheet total of no more than €2 million. The exemption covers services, not products.

What level of accessibility is required?

The reference is WCAG at level AA, as cited by the European standard EN 301 549. It is checked with automated tools and with manual tests using a keyboard and a screen reader.