Probably yes, if you sell to consumers online and are not a micro-enterprise. Article 2(2)(f) of the European Accessibility Act (Directive (EU) 2019/882) names e-commerce services as one of the services it covers.

Two things can change the answer for you: the micro-enterprise exemption and the question of which country's law you start with. The sections below take them in turn.

Does the directive name online shops as a sector?

Yes. Article 2(2)(f) of Directive (EU) 2019/882 lists e-commerce services among the covered services, and Article 3(30) defines them 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. Recital 43 adds that the e-commerce obligations apply to the online sale of any product or service, so what you sell does not decide it.

The definition speaks of consumer contracts. A shop that sells only to businesses is not described by it on its face, and a shop that serves both consumers and businesses should read the national act with that in mind; for a mixed or cross-border case, ask a lawyer. The directive has applied since 28 June 2025.

Which national law do I start with?

Start with the national act of each country where you offer your service to consumers, not with the language of your site. A shop selling to consumers in Germany starts with the German BFSG, a shop selling to consumers in Austria with the Austrian BaFG, and a shop selling in both checks both.

Where your company is based can matter too; for a cross-border case, ask a lawyer which acts bind you. The directive itself defines a service provider as anyone who provides a service on the Union market or makes offers to provide it to consumers in the Union (Art. 3(4)).

For Germany, § 1 Abs. 3 Nr. 5 BFSG applies the act to „Dienstleistungen im elektronischen Geschäftsverkehr“ provided to consumers after 28 June 2025. § 2 Nr. 26 BFSG defines them in terms that follow the directive: digital services offered through websites and mobile applications, provided electronically at the individual request of a consumer with a view to concluding a consumer contract. Czechia, Poland, Slovakia and Austria have their own acts, and we cite each one in its own page.

Which parts of an online shop does it cover?

The directive covers the service, not one page: everything a consumer uses to look at, choose, buy and manage an order. Annex I, Section IV, point (g) singles out the accessibility information about what you sell, the identification, security and payment functions, and the payment services themselves.

SurfaceWhat the directive text saysWhat to look at
Shop and category pagesPart of the service. Art. 4(3) points to Annex I, Sections III and IV.Navigation, search, filters, headings, colour contrast.
Product pagesAnnex I, Section IV(g)(i): accessibility information about the products and services sold, when the responsible economic operator provides it.Text alternatives for images, variant selectors, the accessibility information you hold from your suppliers.
CartPart of the service as a whole.Quantity fields, remove and update buttons, price changes announced to assistive technology.
Checkout and payment stepAnnex I, Section IV(g)(ii) and (iii): the functionality for identification, security and payment, and the payment services.Form labels, error messages, card and wallet widgets, bank redirects, one-time codes.
Customer accountIdentification methods fall under Annex I, Section IV(g)(ii) and (iii).Login, password reset, two-step checks, order history.

Article 2(4)(d) leaves out third-party content that you neither fund, develop nor control. Whether an embedded payment or chat widget fits that wording is a question for the national act or a lawyer, because the payment services themselves are named in Section IV(g)(iii).

Does the micro-enterprise exemption cover my shop?

It can, if you meet both conditions: fewer than 10 persons employed, and either annual turnover or annual balance sheet total of EUR 2 million or less. Article 4(5) exempts microenterprises providing services, and Article 3(23) defines the term.

Germany repeats the exemption for services in § 3 Abs. 3 Satz 1 BFSG and defines a Kleinstunternehmen in § 2 Nr. 17 BFSG on the same figures. The exemption covers services only; the directive handles microenterprises that deal with products through lighter requirements instead (recital 71).

Recital 53 says a company has to actually meet the definition in Commission Recommendation 2003/361/EC to benefit, so count staff and figures the way that Recommendation does. Recital 72 encourages exempt shops to be accessible anyway.

What should I check first?

Start with the path from a product page to a paid order, using only a keyboard. If a customer cannot get through it, nothing else on the list matters yet.

  1. Walk product page, cart, checkout, payment and order confirmation with the Tab, Shift+Tab, Enter and Space keys. Note every place where focus is lost or invisible.
  2. Open every form field and error message with a screen reader or read them in the page source: each field needs a label, each error needs text that says what went wrong and where.
  3. Check product images and variant pickers for text alternatives and names that make sense out of context.
  4. Test the login, password reset and any one-time code or bank redirect, because these are the identification and payment functions Section IV(g) names.
  5. Find the accessibility information for your service. Article 13(2) asks service providers to prepare information under Annex V and explain how the service meets the requirements, made public in written and oral format.

What can automated testing show, and what can it not show?

It can show machine-detectable issues on the pages it reads, such as missing form labels, missing text alternatives and low colour contrast. Automated testing catches roughly 30 to 40 percent of WCAG success criteria, not 30 to 40 percent of a site's failures.

The rest needs a person: whether a checkout makes sense with a screen reader, whether focus lands in a sensible place after an error, whether a wallet widget can be operated at all. A scan also reads only the pages it reaches, and states that depend on a basket, a login or a payment provider need hands-on testing.

EN 301 549 is the technical yardstick used here; no version is cited in the Official Journal under Directive (EU) 2019/882, so it gives no presumption of conformity under the EAA (Art. 15(1)).

How does Inkluso help?

Inkluso offers a free scan of your homepage, a one-time audit of up to 100 pages for EUR 149, and a draft accessibility statement for you to review before you publish it. We do not claim to find what other automated tools miss.

  • The free scan tests the homepage against WCAG 2.1 AA with axe-core. No signup, no card.
  • The audit crawls up to 100 pages and maps each finding to the WCAG criterion, the EN 301 549 clause and the paragraph of the national act you select. The PDF carries a timestamp, the engine version and a SHA-256 hash.
  • The statement draft is a starting text for the accessibility information that Article 13(2) asks for. You review it and publish it.

None of this makes a shop accessible. It gives you dated findings to act on, and an Inkluso report is not a certification.

What else do shop owners ask?

Does the European Accessibility Act apply to my online shop?

Probably, if you sell to consumers online and are not a micro-enterprise. Article 2(2)(f) of Directive (EU) 2019/882 names e-commerce services, and the national act of each country where you sell to consumers sets the details.

Is a very small online shop exempt?

A shop run by a micro-enterprise is exempt under Article 4(5): fewer than 10 persons employed, and either annual turnover or annual balance sheet total of EUR 2 million or less. Both conditions have to be met, and the exemption covers services, not products.

Does the EAA cover only the checkout?

No. The directive covers the e-commerce service as a whole, and Annex I, Section IV, point (g) adds specific lines for accessibility information, identification, security and payment. The checkout is one part of the service, not its limit.

Can a free scan tell me that my shop is fine?

No. A scan of the homepage with axe-core shows what a machine can detect on that page. Automated testing catches roughly 30 to 40 percent of WCAG success criteria, and the cart, checkout, payment step and customer account need a person.

Where do these statements come from?

See where your shop stands

The free scan tests your homepage against WCAG 2.1 AA with axe-core and shows the first findings with the matching reference. No signup, no card.

Run the free scan

Czech version of this topic: Přístupnost e-shopu podle zákona č. 424/2023 Sb. (in Czech) · German version: Gilt das BFSG für meinen Onlineshop? · Other sectors: Travel and transport websites · Ticketing websites · Banks and fintechs

Orientation, not legal advice.