In short
- The obligation has applied since 28 June 2025 to e-commerce services. Companies with fewer than ten staff that provide services, and whose annual turnover or balance sheet total does not exceed two million euros, are exempt.
- The 2030 deadline does not exempt your website. It is a transitional period letting service providers carry on delivering their services with products they lawfully used before 28 June 2025. It covers that equipment, not the accessibility of the site.
- The technical reference is EN 301 549, which incorporates WCAG 2.1 level AA. In France the RGAA aligns with it.
- The blind spot is the checkout. Audits concentrate on the home page because it is easy to test, while the blockage happens at payment, and it leaves no trace in your statistics.
A visitor who cannot confirm their basket does not fill in a complaint form. They leave, and their visit looks like every other visit that did not convert. That is what makes this subject unusual: unlike a slow page or a payment bug, an accessibility defect produces no signal. A slow page at least gets measured, and the assessment reads the 75th percentile of your real visitors over 28 days, so it eventually surfaces in a report. Nothing of the kind exists here.
It explains an anomaly we find in almost every audit: companies first fix what is visible, the home page and the content pages, and leave untouched what actually blocks a sale.
What the rule asks, without the jargon
The European Accessibility Act, applicable since 28 June 2025, covers e-commerce services alongside banking and transport. It targets services provided to consumers, and it does not stop at your website: the text also covers services embedded in mobile devices, mobile applications included. France transposed it through a series of texts in 2023, introducing accessibility principles into consumer law and setting out enforcement procedures.
Neither the directive nor the French order of 9 October 2023 names a standard. Presumption of conformity runs through harmonised standards cited in the Official Journal, and none has been cited yet under this directive. In practice the working reference remains the EN 301 549 standard, which incorporates the WCAG 2.1 criteria at levels A and AA. The French RGAA rests on the same criteria but belongs to a separate regime: it binds public bodies and private companies with at least 250 million euros of turnover. Technically the work is the same; legally these are two distinct obligations.
The most widespread misunderstanding Many companies took away that a deadline ran until 2030. That period is indeed a transitional measure for service providers, but it covers the products they lawfully used before 28 June 2025 to deliver similar services, a self-service terminal for instance. It suspends nothing on the site itself. Two further allowances exist, and they do not cover you either: service contracts agreed before 28 June 2025 may run to expiry within a five-year limit, and self-service terminals already in use may stay in use for up to twenty years from commissioning.
Enforcement started quickly. Within days of the deadline, disability advocacy organisations issued formal notices to several major grocery retailers. So the subject does not rest on the authorities alone: it can be raised by an association, or by a customer.
And if you sell outside Europe
The European text is the most commented on, it is not the only one, and above all it is not built like the others. The five main markets of a European online retailer fall under three distinct legal logics, and that difference decides how the problem reaches you.
| Territory | The text | Technical standard written into law | What triggers it |
|---|---|---|---|
| European Union | European Accessibility Act, applicable since 28 June 2025 | No harmonised standard cited to date; EN 301 549 serves as the working reference | A national authority, on a date everyone knows, and a customer or an association as well |
| United Kingdom | Equality Act 2010, outside the European act since Brexit | None for the private sector; the 2018 regulations bind public sector bodies only | A customer’s complaint, at any time |
| United States | Americans with Disabilities Act, Title III, applied by the courts | None for private businesses; the 2024 federal rule sets WCAG 2.1 AA for public entities only | A filing by a specialist law firm |
| Australia | Disability Discrimination Act 1992 | None; the Commission’s guidelines point to WCAG in its latest published version, with no binding force | A complaint to that Commission |
| Canada, Ontario | Accessibility for Ontarians with Disabilities Act 2005 and O. Reg. 191/11 | WCAG 2.0 Level AA, written into the regulation, for organisations with fifty or more employees in the province | A deadline that passed in 2021, and a report to file |
Europe regulates a service placed on the market. It sets a date, requirements, authorities tasked with checking the conformity of services, and penalties, each member state naming its own. You are compliant or you are not, on a deadline everybody knows. That is uncomfortable, and it is legible.
The United Kingdom, the United States and Australia regulate a discrimination. There is no date and no authority: there is a person who could not place an order, and who goes to a court or a commission. Do not conclude from this that Europe shields you from a complaint: the directive in fact requires member states to open the courts to consumers, and to associations acting in their support. The difference is not the existence of an individual remedy, it is what Europe adds on top, a deadline and an authority.
The United Kingdom, for its part, takes the discrimination logic further than the other two, and it is the point companies most often miss: the duty to make reasonable adjustments is owed to disabled persons generally, not only to the one who complains. In other words, waiting for the complaint is already the breach.
In the United States the risk is not administrative, it is judicial. 3,117 website accessibility actions were filed in federal court in 2025, up 27 % year on year, making up 36 % of all Title III litigation. No federal text imposes a technical standard on private businesses: the rule published by the Department of Justice in 2024, which adopts WCAG 2.1 AA, covers public entities only, with deadlines pushed back to April 2027 and April 2028. That gap between the absence of a rule and the abundance of lawsuits is exactly what makes this market formidable.
In Australia the question was settled in 2000. Ruling on a complaint brought by a blind claimant against the Sydney Olympics organising committee, the Commission held on 24 August 2000 that providing information through a website is a “service” under the 1992 act, and rejected the unjustifiable hardship defence, expert evidence putting the remediation at four weeks. Twenty-six years on, the Australian act still contains no technical standard, and that defence remains the only one available.
In April 2025 the Commission published guidelines on equal access to digital goods and services, replacing its 2014 advisory note. Two details are worth reading closely if you sell there. They freeze no version of WCAG: they point to the latest published version, which moves the target with every update to the standard, where the Union and the US Department of Justice both rest on a dated version. And they are no safe harbour: the Commission writes that an organisation may not be protected from a finding of unlawful discrimination by claiming it conformed with, or relied on, the guidelines. Meeting them is a minimum, not a guarantee.
Ontario, finally, stands apart. In Canada the rule that concerns a retailer is provincial, and Ontario wrote the most demanding one. Its O. Reg. 191/11 requires “large organizations”, defined as those employing fifty or more people in the province, to make their websites conform to WCAG 2.0 Level AA. The deadline passed on 1 January 2021, bar two criteria, live captions and audio description of pre-recorded content. Below fifty employees the obligation does not apply.
Two features deserve attention. The version named is WCAG 2.0, older than the one adopted by the Union and by the US Department of Justice: this panorama therefore has three versions of the same standard running side by side, without counting Australia, which requires the latest published one. And Ontario is the only one of the five to ask for anything unprompted: the 2005 act requires an accessibility report to be filed with a director, annually or at such other times as the director specifies, and made available to the public. Everywhere else, nobody asks you for anything until something happens.
What this changes for you: nothing, technically. The work is the same across all five territories, and it concentrates in the same place, your checkout. What changes is the calendar, and only one matters, the shortest. If you ship into Europe, your deadline passed in June 2025. If you ship only elsewhere, you have no date, which is no more comfortable: you have permanent exposure.
Your place of establishment protects you from nothing. The European text defines a service provider as “any natural or legal person who provides a service on the Union market or makes offers to provide such a service to consumers in the Union”. A US shop delivering to France is therefore in scope, exactly as a French shop delivering to London falls under the Equality Act. The regime follows the customer, not the company address.
Where it actually blocks
Here is what ten years of checkouts have taught us, and what automated audit reports do not say.
| Step | The typical defect | What happens for the visitor |
|---|---|---|
| Product page | Size or colour selection built from clickable blocks with no state announced | A screen reader reads out a list of links without saying which one is selected |
| Basket | Updating the quantity reloads the area without announcing it | The total changes, nothing signals it, the person cannot tell whether their action registered |
| Address form | Error messages in red, with no text tied to the field | The error is invisible to a screen reader, and to a colour-blind person |
| Delivery choice | Options are styled blocks, not radio buttons | Impossible to move through the choices by keyboard, therefore impossible to order |
| Payment | The card field sits in an external frame you do not control | The hardest point, and the one that depends on your provider rather than on you |
| Mobile app | It was never audited, because the audit covered the website | The same checkout, with the same defects, on the device that often carries most of the orders |
Note the last one: your checkout’s compliance depends in part on your payment provider. It is a question to ask before signing, and to ask again of the one you already have.
The method, in four steps
- Place a full order using the keyboard only. Unplug the mouse, trackpad included, and go all the way to the order confirmation. You will know within fifteen minutes whether your site is usable, and you will generally find the blockage before payment.
- Do it again with the screen reader built into your system. VoiceOver on Mac, Narrator on Windows, both free and already installed. The experience teaches more than compliance.
- Check the contrast of your action buttons. An add-to-basket button in light grey on white fails the criterion, and it costs sales from everyone, not only from the people concerned.
- Ask your payment provider for their accessibility statement. If they do not have one, you know where your ceiling sits.
These four steps require no paid tooling and take half a day. They cover the part of the subject that decides a sale, which a two-hundred-page automated report does not.
The document almost nobody has written
The four steps above test your website. The European text also asks for a written statement, and it is at once the easiest obligation to meet and the easiest to forget.
Article 13 requires the service provider to prepare the information explaining how the service meets the accessibility requirements. It sits in the general terms and conditions or an equivalent document, it is made available to the public in written and oral form, including in a way accessible to people with disabilities, and it is kept for as long as the service is available. Annex V sets out the content: a general description of the service in accessible formats, the explanations needed to understand how it works, and a description of how the requirements are met.
In plain terms: a public page saying what you have done, what is still outstanding, and how to reach you if a barrier remains. It needs no development work and takes half a day to write. It is also the first thing an authority will ask for, and what separates, when a complaint arrives, the company that dealt with the subject from the one that ignored it.
The options, and what they are worth
| Option | What you get | Who it suits |
|---|---|---|
| Fix the checkout first | Handles the part with an immediate commercial effect, and the most exposed if a complaint is made | Everyone, and it is where we start |
| Install an accessibility overlay | Improves some criteria, contrast and text size in particular, and fixes neither a badly marked-up field nor a form that cannot be used by keyboard. Useful alongside, never as the whole answer | As support, while the underlying fixes progress |
| Rebuild the site | Solves everything, costs a lot and takes months. Often invoked as a reason to do nothing meanwhile | When a rebuild was already planned for other reasons |
| Wait for 2030 | Rests on a misreading: the deadline does not cover digital services | No case at all |
Tooling
Part of the work is repetitive and can be handled in code: missing attributes, field labels, contrast, tab order, state change announcements. That is tooling. The rest, the journeys and the business components, is fixed by hand.
On PrestaShop we deploy the module published by Datafirefly Limited, our agency’s sister company: Accessibility EAA applies the automatable WCAG fixes and provides the comfort overlay. One-off purchase · 12 months of updates.
One caveat applies to shops still on PrestaShop 1.7: that version has received no fixes since 10 June 2025, and the default theme of current versions is built around the accessibility requirements. On those shops, upgrading handles both subjects at once, which we cover in our article on the end of maintenance for PrestaShop 1.7.
Method beats tooling, here more than anywhere: no module makes a badly built size selector orderable by keyboard. The four-step test comes before installation, and it is what tells you what remains to be done by hand.
What this says more broadly
Accessibility is presented as a constraint for a minority. That is a short reading. A form whose errors are explicit, a legible button, a journey usable by keyboard: these are ergonomic improvements that benefit every visitor, and particularly those ordering from a phone on a train.
It is exactly the ground of our UX and CRO practice, and the reason we treat this subject with the same tools as conversion rather than as a separate compliance file. Journey friction and accessibility defects often point at the same screens.
Sources
The verifiable claims in this article link to their primary source, opened on 11 August 2026. We do not cite a source we have not read.
- Directive (EU) 2019/882 of the European Parliament and of the Council of 17 April 2019 on the accessibility requirements for products and services, Articles 2, 3, 4, 14, 15, 23, 29, 30, 31 and 32. Read the source
- French Consumer Code, Article L412-13, exemption for companies with fewer than ten staff providing services. Read the source
- Decree No. 2023-931 of 9 October 2023 on the accessibility of products and services to persons with disabilities. Read the source
- Order of 9 October 2023 setting the accessibility requirements applicable to products and services. Read the source
- European Commission, status of EN 301 549 versions and their citation in the Official Journal. Read the source
- Référentiel général d’amélioration de l’accessibilité, scope of application and WCAG level applied. Read the source
- Equality Act 2010, section 29(7) and Schedule 2 paragraph 2(2), duty to make reasonable adjustments owed to disabled persons generally. Read the source
- Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018, regulation 3, scope limited to public sector bodies. Read the source
- Department of Justice, Title II web accessibility rule: WCAG 2.1 AA standard, scope limited to public entities, compliance dates of April 2027 and April 2028. Read the source
- Seyfarth Shaw, annual count of federal Title III filings, published 25 March 2026. Read the source
- Disability Discrimination Act 1992, section 24 on goods and services and section 29A on unjustifiable hardship. Read the source
- Maguire v Sydney Organising Committee for the Olympic Games, Commission decision of 24 August 2000. Read the source
- Australian Human Rights Commission, Guidelines on equal access to digital goods and services, April 2025, issued under section 67(1)(k) of the Disability Discrimination Act and not legally binding. Read the source
- Ontario, O. Reg. 191/11 Integrated Accessibility Standards, section 14 (websites and web content, WCAG 2.0 Level AA, 1 January 2021 deadline) and section 1 (definitions of large and small organization, fifty-employee threshold). Read the source
- Accessibility for Ontarians with Disabilities Act 2005, section 14, annual filing of the accessibility report and its availability to the public. Read the source
FAQ
I also sell in the UK and the US, do I have to redo everything for each country?
No. The technical work is the same everywhere, WCAG level AA applied first to the checkout. What differs is the trigger: an authority on a fixed date in Europe, a deadline already passed and a report to file in Ontario, a customer’s complaint at any time in the UK, the US and Australia. You are not running five projects, you are running one, and the shortest calendar governs you.
My company is small, am I really in scope?
The exemption is clear-cut, not discretionary: a company with fewer than ten staff providing services, whose annual turnover or balance sheet total does not exceed two million euros, is exempt from the accessibility requirements and from every obligation attached to them. Do not confuse it with disproportionate burden, which is a case-by-case assessment open to every operator and which has to be documented to be relied on: we set out what the text demands before it believes you, and why that file often costs more than the fixes it seeks to avoid. But the reverse reasoning is more useful: the four steps above cost half a day and improve your conversion rate. The exemption question comes afterwards, not before.
I only sell to businesses, am I in scope?
Not under the European act. It targets services provided to consumers, and the text defines a consumer as a natural person acting for purposes outside their trade, business, craft or profession. A strictly B2B shop falls outside it. Two caveats though. Many sites presented as B2B in fact accept orders from private individuals, which is enough to bring them into scope. And the UK, US and Australian regimes rest on discrimination, not on consumer status: they carry no such limit, so a B2B site selling into London or New York remains exposed.
Is an accessibility overlay enough?
No. It handles some visual criteria and fixes neither an unlabelled field, nor a component unusable by keyboard, nor an error message not tied to its field. It has a place alongside, not as the answer.
Does the 2030 deadline apply to me?
It targets physical products already placed on the market before June 2025, not digital services. An online shop is a service: it falls under the June 2025 deadline.
Where do I start with only half a day?
A full order by keyboard alone, from product page to confirmation. It is the highest-return test: it finds the blockages that prevent a sale, and it needs no tooling.
Can Dotsland help?
Yes. An audit of the checkout against the criteria that block a sale, fixes ranked by impact, and a check on the payment link with your provider. It is part of our UX and CRO practice. Let’s talk, or start with the keyboard order: it is free and often eye-opening.