EAA compliance for e-commerce: what online retailers need to know
Online retailers are the primary target of EAA enforcement across Germany, Sweden and the Netherlands. If you sell to EU consumers, the first wave of enforcement is already under way.
If your organisation sells to consumers in the EU through a website or app, that is an e-commerce service under the EAA and in scope, unless you are a microenterprise. This is not a future obligation: enforcement has started.
Why e-commerce is the primary enforcement target
Online retail is the sector most likely to receive enforcement attention first, and the three markets moving fastest show why: the Dutch ACM tested roughly 100 major webshops, Sweden’s PTS opened systematic inspections of e-commerce operators, and German law firms began sending warning letters within weeks. Several factors explain the pattern. Consumer-facing websites are easy to test and assess. Disabled consumers are highly active online shoppers. And the financial harm of inaccessible e-commerce is concrete and direct: a purchase not completed, a booking not made, a customer lost.
The Barómetro de Accesibilidad Web 2025 audited the websites of 204 large Spanish companies and found 98% of them not fully conformant. It graded websites, not people: it does not measure how many disabled customers fail to complete a purchase.
Enforcement across each market
Germany
The BFSG (Germany's EAA implementation) took effect in June 2025. Law firms began sending private warning letters (Abmahnungen) to e-commerce businesses within weeks. An Abmahnung is a legal demand: immediate compliance, a signed declaration with a contractual penalty clause, and reimbursement of the sender's legal costs (typically €1,000–3,000). Ignore it and the case goes to court. The MLBF, the market surveillance authority, can additionally impose fines. For a service provided in breach of the accessibility requirements, the ceiling is €100,000 (§ 37 BFSG).
Sweden
PTS (Post and Telecom Authority) has launched 28 supervisory investigations, with named inspections of major online retailers including H&M, IKEA and Coop. Sweden's maximum fine is SEK 10,000,000. The figure that matters legally is the krona amount. PTS can impose a sanktionsavgift for breaching the duties listed in section 37, including the duty to keep a service accessible, and can attach a vite (a conditional fine) to an order to put a breach right. Under section 38 of Lag (2023:254), a sanktionsavgift cannot be imposed for a breach covered by a föreläggande om vite where that breach is the basis of an application to have the vite imposed.
Netherlands
The ACM (Authority for Consumers and Markets) is conducting active audits. Fines can reach 10% of annual turnover and no ceiling is verified. Financial penalties have been legally available since June 2025. None has been issued. The ACM’s published posture is compliance first. There is also a duty to report. The ACM says that if your service is not accessible and you can’t fix it straight away, you must report it: within a week for critical or serious problems, within a month for moderate or minor ones.
Ireland
The CCPC is the enforcement authority for e-commerce and digital services. Ireland's implementation is notable for criminal sanctions: a director, manager, secretary or other officer also commits an offence if it was committed with their consent, connivance or approval, or is attributable to their wilful neglect (Regulation 33). The penalty on conviction in the higher courts is a fine up to €60,000 and/or imprisonment up to 18 months.
France
Civil society organisations filed proceedings against four retailers: Carrefour, Auchan, E.Leclerc, and Picard Surgelés. The Tribunal judiciaire de Caen ordered Carrefour France to make its online commerce services fully accessible within six months. French press reporting puts the penalty for delay at €500 per day; the figure does not appear in the associations’ own communiqués. The court rejected Carrefour's argument that 71% conformance was sufficient, stating that accessibility is an obligation of result: a site cannot be only a little accessible, it must be totally accessible.
What EAA compliance requires for e-commerce
EAA compliance is not a single audit. For an e-commerce organisation, it comes down to four areas of work:
- Technical conformance against EN 301 549 (WCAG 2.1 Level AA in practice) across your website, app, and any customer-facing digital service.
- A published accessibility statement explaining how your service meets the accessibility requirements, in your terms and conditions or an equivalent document. Saying what is not yet accessible, and your plan, is good practice.
- Active governance: a named owner for accessibility, a regular testing rhythm, and a process that survives team changes and new product releases.
- Documentary evidence of ongoing management: assessments, remediation records, and a compliance trail that demonstrates active engagement rather than passive non-compliance.
The accessibility statement is critical. In Germany, the BFSG requires the information in your general terms and conditions or in another clearly perceptible way. An organisation without one starts any enforcement interaction at a disadvantage.
The commercial case
Beyond enforcement, inaccessible e-commerce has a direct commercial cost. Disabled consumers represent a significant share of purchasing power. When a checkout process, product filter, or account management flow is inaccessible, those customers go elsewhere. The revenue lost does not appear in any analytics report because those users never made it to the point of attempting a transaction.
It is also an opportunity. Every checkout barrier removed is a customer who can now buy. This is not a compliance line item. It is a segment that converts the moment the journey actually works.
Organisations that have addressed accessibility consistently report reduced customer service costs, higher conversion rates among assistive technology users, and improved SEO performance as a secondary benefit of the structural improvements required for accessibility.
Find out where your organisation stands
Our free initial assessment covers your sector-specific exposure, which of the four areas of EAA compliance work you have covered, and what a proportionate next step looks like.
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