Regulatory context
E-commerce is explicitly listed in Article 2 of the EAA (Directive 2019/882) as an in-scope service. This means any online store selling to EU consumers must meet the accessibility requirements defined in EN 301 549, which incorporates WCAG 2.1 Level AA. The Web Accessibility Directive (WAD) also applies to public sector e-commerce sites. For online retailers, virtually every part of the customer journey is in scope - from browsing and search, through product pages and checkout, to account management and returns.
Common issues Lumi finds in e-commerce websites
Inaccessible checkout flows
Multi-step checkouts, address forms, payment entry, and order confirmation pages frequently have missing form labels, poor error handling, and broken keyboard navigation. The checkout is the highest-stakes accessibility failure point - users can browse the entire site but can't complete a purchase.
Product image alt text
Product images are the primary way customers evaluate items online. Missing or generic alt text (like filenames or SKU numbers) means screen reader users can't assess products. Every product image needs descriptive alt text that conveys what the image shows.
Filter and sort controls
Product category pages rely on filters (size, colour, price range) and sort controls that are frequently built as custom UI components without proper ARIA markup, keyboard support, or screen reader announcements.
Cart and quantity interactions
Add-to-cart buttons, quantity selectors, cart drawers, and mini-carts often use custom JavaScript components that lack keyboard accessibility and don't announce state changes to screen readers.
Colour and size selectors
Product variant selectors (colour swatches, size buttons) frequently rely on colour alone to convey selection state, and lack text labels or ARIA attributes that screen readers can announce.
Search autocomplete and results
Product search with autocomplete suggestions is almost always built without proper ARIA combobox patterns. Screen reader users can't navigate suggestions or understand when results update.
E-commerce-specific challenges
E-commerce sites face unique accessibility challenges because of the complexity of the shopping experience. Product catalogues can have thousands of items, each needing alt text. Promotional content changes frequently, introducing new accessibility issues with every campaign. Third-party integrations (payment processors, review widgets, chat tools, recommendation engines) inject markup that the retailer doesn't control. Dynamic pricing, stock levels, and delivery estimates need to be announced to screen readers when they update. Multi-currency and multi-language support adds further complexity.
Compliance timeline
The EAA is enforceable from 28 June 2025 for new e-commerce services. Existing services have until 28 June 2030 to comply with transitional provisions. However, many EU member states have consumer protection laws that already require accessible online services, and enforcement is expected to ramp up significantly from 2025.
Check your e-commerce site now
Lumi scans against WCAG 2.2 and EN 301 549 using five scanning engines - free, no signup required.
Frequently asked questions
Does the EAA apply to e-commerce?
Yes. E-commerce is explicitly listed as an in-scope service in Article 2 of the EAA. Any online store selling products or services to EU consumers must meet EN 301 549 accessibility requirements, regardless of where the business is based.
What WCAG level does e-commerce need?
The EAA references EN 301 549, which incorporates WCAG 2.1 Level AA as the minimum for web content. This covers all aspects of the e-commerce experience including browsing, search, product pages, checkout, account management, and customer service.
Are payment pages covered by the EAA?
Yes. The entire purchasing flow is in scope, including payment entry, address forms, and order confirmation. If you use a third-party payment processor (like Stripe or PayPal), both your site and the payment interface need to be accessible.
What are the fines for non-compliance in e-commerce?
Fines vary by EU member state. For example, Spain can fine up to €1,000,000 for very serious infringements, Germany up to €100,000, and Ireland includes criminal sanctions with potential imprisonment. The specific penalty depends on the country where enforcement action is taken.
Related resources
Last reviewed: April 2026. Content is reviewed quarterly for accuracy.