European Accessibility Act for WooCommerce: What to Fix, What It Costs

The EAA has applied to e-commerce since 28 June 2025. What it requires from a WooCommerce store, who is exempt, what usually fails, and how to budget for fixes.
Valentin Shtefan
CEO of Artilab

Yes, the European Accessibility Act (EAA) applies to most WooCommerce stores that sell to consumers in the EU, and it has applied since 28 June 2025. In practice, that means your shop, product pages, cart, checkout and account area should meet WCAG 2.1 Level AA, and you need to publish information on how your store meets the requirements. Microenterprises that provide services are exempt.

Below is what the law says, based on the directive text itself, what usually fails on WooCommerce stores, and how to think about the cost of fixing it.

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What is the European Accessibility Act?

The EAA is Directive (EU) 2019/882 on accessibility requirements for products and services. As a directive, it does not apply directly. Each Member State had to write it into national law by 28 June 2022 and apply those measures from 28 June 2025 (Article 31).

E-commerce is one of the services listed in Article 2(2). The directive 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" (Article 3(30)). A WooCommerce store selling to consumers fits that definition.

Does the EAA apply to my WooCommerce store?

Work through these questions:

  1. Do you sell to consumers? The directive covers services "provided to consumers". A purely B2B wholesale store with no consumer sales is generally outside the e-commerce definition. Many B2B stores also sell to individuals, though, so check your real customer base.
  2. Do you sell to consumers in the EU? A service provider is anyone who provides a service on the Union market "or makes offers to provide such a service to consumers in the Union" (Article 3(4)). That wording can include UK and US stores that actively sell and ship to EU customers.
  3. Are you a microenterprise? See the next section.

If you answered yes, yes and no, you should assume the EAA applies.

Who is exempt? The microenterprise rule

Article 4(5) states that "microenterprises providing services shall be exempt" from the service accessibility requirements. Article 3(23) defines a microenterprise as an enterprise that "employs fewer than 10 persons and which has an annual turnover not exceeding EUR 2 million or an annual balance sheet total not exceeding EUR 2 million".

Both conditions matter: under 10 staff, and turnover or balance sheet total of EUR 2 million or less. A small team with a larger turnover and a lean balance sheet can still qualify, but check with your accountant how your country counts staff and linked companies.

Two other points from the directive are often misread:

  • The disproportionate burden exception (Article 14) is not a general opt-out. You must carry out and document an assessment using the criteria in Annex VI, keep it for five years, and service providers must renew it at least every five years or when the service changes.
  • The transitional period to 28 June 2030 (Article 32) covers service contracts agreed before 28 June 2025 and products you already used to provide the service. It does not mean your website can wait until 2030. Your checkout is the service itself.

Which standard do you have to meet?

The directive sets functional requirements, not a technical checklist. For websites, Annex I asks providers to make websites and online applications accessible "in a consistent and adequate way" by making them perceivable, operable and understandable (the POUR principles of WCAG). For e-commerce, Section IV adds accessible identification, security and payment functions, and information about the accessibility of the products you sell when the manufacturer provides it.

For the technical detail, the directive gives a presumption of conformity to harmonised standards. In practice the reference is EN 301 549. According to the European Commission's AccessibleEU centre, the current legal reference is still EN 301 549 v3.2.1 (2021), "which is based on WCAG 2.1 Level AA". A new version, v4.1.1, was published in September 2026 and adopts WCAG 2.2, but it is not yet the legal reference until the Commission cites it in the Official Journal.

Our advice: fix to WCAG 2.1 AA now, and pick up the WCAG 2.2 additions (target size, accessible authentication, not asking for the same data twice) in the same project, since they are small and will likely become the reference.

What happens if you don't comply?

Enforcement is national. Article 30 requires Member States to set penalties that are "effective, proportionate and dissuasive" and that take into account the seriousness of the non-compliance and the number of people affected. So fines differ by country. Two examples we verified in the national legislation:

CountryLawMaximum penalty
GermanyBFSG, ยง 37Up to EUR 100,000 for offering or providing a non-compliant service; up to EUR 10,000 for most other breaches, such as missing information
IrelandS.I. No. 636 of 2023, Regulation 32On conviction on indictment, a fine up to EUR 60,000 and/or up to 18 months in prison

Fines are not the only risk. Authorities can order corrective action, and Article 13(4) requires a provider who knows the service is non-compliant to fix it and inform the national authority. For most stores, the practical risk is a complaint from a customer or a consumer organisation leading to an order to fix within a deadline.

What usually fails on WooCommerce stores?

WooCommerce states that the front end of the core plugin is "substantially conformant with WCAG 2.2 level AA". That is a good base, but most problems we find come from the theme, page builders, and third-party plugins layered on top. These are the issues we see most often, mapped to the WCAG 2.1 criteria they break:

AreaTypical problemWCAG 2.1 criterion
Checkout formsPlaceholder text used instead of labels; custom fields added by plugins without labels3.3.2 Labels or Instructions (A)
Checkout formsMissing autocomplete attributes on name, address and email fields1.3.5 Identify Input Purpose (AA)
Error messagesErrors shown only in red, only at the top of the page, or not announced to screen readers3.3.1 Error Identification (A), 4.1.3 Status Messages (AA)
Variation selectorsColour and size swatches built as clickable divs with no keyboard support or name2.1.1 Keyboard (A), 4.1.2 Name, Role, Value (A)
Add to cart"Added to cart" notice or mini cart update not announced4.1.3 Status Messages (AA)
ContrastLight grey text, sale badges, placeholder text and outline buttons below 4.5:11.4.3 Contrast (Minimum) (AA)
ContrastInput borders and focus rings below 3:1 against the background1.4.11 Non-text Contrast (AA)
KeyboardMenus, filters, quick view popups and cookie banners that trap focus or cannot be closed2.1.1 Keyboard (A), 2.1.2 No Keyboard Trap (A)
FocusTheme removes the focus outline for design reasons2.4.7 Focus Visible (AA)
ImagesProduct images with empty or file-name alt text; decorative icons read aloud1.1.1 Non-text Content (A)
PaymentEmbedded payment or card fields from a gateway plugin that cannot be used by keyboard or screen readerAnnex I Section IV (g) of the directive

Don't forget the information requirement. Article 13(2) and Annex V require you to publish how your service meets the accessibility requirements, in your terms and conditions or an equivalent document. Many stores publish an accessibility statement page for this.

Will an accessibility overlay plugin make you compliant?

No. Overlay widgets add a toolbar on top of the site, but they do not fix the underlying markup of your checkout, forms or variation selectors. WooCommerce's own developer blog put it plainly: overlay plugins and automated solutions "don't actually account for everything necessary in accessibility standards, and can still lead to fines and remediation". Automated scanners are useful for finding contrast and missing alt text, but many checkout problems only show up when a person tests with a keyboard and a screen reader.

What does WooCommerce accessibility work cost?

Cost depends less on the size of your catalogue and more on how your front end was built. The main drivers are:

  • Theme type. A block theme or a well-coded classic theme needs fewer fixes than a heavily customised page builder theme.
  • Number of custom templates. Every custom product page, filter or checkout step has to be tested and fixed.
  • Third-party plugins in the buying path. Swatches, filters, upsell popups and payment gateways you cannot edit directly may need replacing.
  • Content. Writing alt text for thousands of product images is often a content task, not a developer task.
  • Ongoing process. New products, plugins and design changes can break accessibility again.

A realistic project has three parts:

StageWhat it includesOur pricing
AuditManual testing of key templates and the full checkout with keyboard and screen reader, plus automated scans, with a prioritised issue listAccessibility audit from $1,200
RemediationTheme and template fixes, replacing or patching problem plugins, re-testingHourly from $35/hour, or a fixed price after the audit
Documentation and upkeepAccessibility statement, content guidelines for your team, checks after updatesPart of a support plan, from $300/month

If you also need to check other EU rules for your store, such as consumer information and checkout wording, our EU compliance review starts from $1,500. We give a fixed scope and price before any remediation work starts, because the audit tells us exactly what needs to change.

A practical order of work

  1. Confirm the EAA applies to you (consumers, EU, not a microenterprise).
  2. Test the buying path first: product page, variation selection, cart, checkout, payment, order confirmation, account login.
  3. Fix blockers in that path before cosmetic issues elsewhere.
  4. Fix global issues once: contrast in the theme, focus styles, header menu, cookie banner.
  5. Publish your accessibility information and a contact route for accessibility problems.
  6. Add an accessibility check to your update and release process.

When to get help

If you are not sure whether your checkout works with a keyboard and a screen reader, start with an audit rather than a plugin. Our WooCommerce accessibility service covers the audit, the fixes and re-testing against WCAG 2.1 AA. If you want the wider legal picture for selling in the EU, see our WooCommerce EU compliance review.

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