Since June 28, 2025, the European Accessibility Act (EAA) has applied – in Germany through the Accessibility Strengthening Act (BFSG), which entered into force on that date. For online shops, this means: Those who are not accessible risk warnings and fines. But what exactly does the law require? And how do you ensure your online shop meets the requirements?
What is the European Accessibility Act?
The European Accessibility Act (EAA) is a directive that aims to provide people with disabilities equal access to digital products and services. All EU member states must implement it into national law.
For e-commerce, this means concretely: Online shops must be designed accessibly. This affects not only the website itself but the entire purchase process – from product search to shopping cart to payment.
Violations of the German implementation (BFSG) can result in fines up to 100,000 euros. Additionally, competitors and associations can issue warnings. Our article on the enforcement wave around accessibility shows how enforcement has developed since 2026.
Who Does the EAA Affect?
The EAA covers specific products and services offered to consumers – explicitly including e-commerce services. This includes:
- Online shops with B2C business
- Service portals and booking platforms
- Banking and financial services
- E-books and digital publications
- Streaming services and media platforms
Microenterprises with fewer than 10 employees and an annual turnover or balance sheet total of no more than 2 million euros are exempt from the accessibility requirements as service providers. Whether your company qualifies should be reviewed legally.
WCAG 2.1 AA: The Technical Standard
The German implementation (BFSG) does not name a WCAG version itself. In practice, the technical benchmark is the Web Content Accessibility Guidelines (WCAG) 2.1 at conformance level AA, on which the European standard EN 301 549 also builds. These international guidelines define four principles for accessible web content:
Perceivable
Content must be accessible to all senses (e.g., alternative texts for images)
Operable
Navigation and interaction must be possible without a mouse
Understandable
Content and operation must be comprehensible
Robust
Content must work with various technologies
The technical implementation of these principles is complex. WCAG 2.1 AA comprises 50 success criteria at levels A and AA that must be met for conformance. Without specialized accessibility expertise, gaps are easily left open.
Common Accessibility Problems in Online Shops
When analyzing online shops, we regularly find the same problems. These may seem secondary at first glance but are often insurmountable barriers for people with disabilities:
| Problem | Impact | Affected Users |
|---|---|---|
| Missing alt texts | Images not detectable | Visually impaired |
| Poor color contrast | Text not readable | Visually impaired |
| No keyboard navigation | Shop not operable | Motor impaired |
| Missing form labels | Inputs unclear | Screen reader users |
| Autoplay videos | Distraction/Overwhelm | Cognitively impaired |
Screen Reader Compatibility
Blind and severely visually impaired people use screen readers – software that reads screen content aloud. For an online shop (Shopware agency) to be usable with screen readers, the HTML code must be semantically correct.
This means: Headings must be marked as such, images need descriptive alternative texts, forms need labels, and interactive elements must have ARIA attributes. If even one of these elements is missing, the shop becomes an obstacle course for screen reader users.
Keyboard Navigation
People with motor impairments often cannot operate a mouse. They navigate exclusively with the keyboard. An accessible online shop must be fully operable via keyboard.
- All interactive elements reachable via Tab
- Visible focus indicator
- Logical tab order
- Dropdown menus operable via arrow keys
- Modal dialogs closable via Escape
Many shop systems have inherent deficits in keyboard navigation. Custom developments like mega menus, filter widgets, or interactive product configurators are often not keyboard accessible.
Contrasts and Readability
WCAG 2.1 AA requires a contrast ratio of at least 4.5:1 for normal text and 3:1 for large text. Many modern shop designs with subtle gray tones or pastel colors do not meet this requirement. Our article on the accessibility audit for shops describes how to test these criteria in practice.
Placeholder text in forms often has too little contrast. The same applies to disabled buttons or secondary information. These must also meet contrast requirements.
The Path to EAA Compliance
A professional accessibility optimization follows a structured process:
- As-is analysis: Automated and manual review of all accessibility criteria
- Prioritization: Critical issues first, identify quick wins
- Implementation: Technical adjustments in frontend and backend
- Testing: Review with real users and assistive technologies
- Documentation: Create accessibility statement
Depending on shop size and starting situation, a complete accessibility optimization usually takes several weeks, and considerably longer for extensive shops. If gaps remain, tackle them by priority – critical barriers in navigation and checkout first.
What Does EAA Compliance Cost?
The costs for accessibility optimization depend on the scope of necessary adjustments. Shops with modern, semantic HTML require less effort than those with outdated templates.
Typical cost drivers are individual JavaScript components, complex filters and product configurators, and legacy code. A realistic estimate is only possible after an analysis of the current state.
Accessibility can reach more people and usually benefits usability for all users. Clear structure and text alternatives also help search engines understand the content.
Accessibility for Different Shop Systems
The accessibility requirements apply regardless of the shop system in use. Implementation, however, differs from platform to platform:
- Shopware: solid basis, but adjustments in the storefront theme are needed
- WooCommerce (WooCommerce agency): theme-dependent, often extensive adjustments
- Magento: solid basis, but complex adjustments in the admin
- TYPO3: good accessibility features, extension-dependent
Existing Shops: What You Should Do Now
The BFSG has applied since June 28, 2025. Its transitional provisions (§ 38 BFSG) cover, among other things, service contracts: if they were concluded before that date, they may continue unchanged until June 27, 2030 at the latest. Whether a transitional rule applies to your shop is a matter for a legal review of the individual case. Either way, it pays to close gaps now:
- Have your shop's current state analyzed
- Clarify effort and budget
- Commission implementation partner
- Adjust internal processes (e.g., content creation)
- Prepare accessibility statement
The EAA focuses on B2C offerings. Pure B2B shops may be exempt under certain circumstances. A legal review is recommended.
Automatic tools find only a portion of accessibility problems. Manual tests by experts and real users are indispensable.
Under the BFSG, service providers state in their terms and conditions or in another clearly perceivable way how their service meets the accessibility requirements – including a general description of the service and the competent market surveillance authority. Many shops bundle this information in an accessibility statement.
The duration depends on size, starting situation and complexity. An audit is usually completed considerably faster than the subsequent implementation of measures, which can take several weeks depending on scope. Shops with many custom developments need more time. We set the concrete schedule after the initial analysis.
Violations of the German implementation (BFSG) can result in fines up to 100,000 euros as well as warnings from competitors and associations.
As a rule, yes: An accessible shop is typically also better structured for SEO, easier to operate, and reaches a larger audience. Around 16% of the world's population (WHO) experiences a significant disability – accessible online shops specifically address these people.
This article is for general information purposes only and does not constitute legal advice. The mentioned fines and deadlines reflect the legislation as of September 2026. For a binding assessment of your individual situation, please consult a lawyer specializing in IT law.