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.
E-commerce is the most actively enforced sector under the European Accessibility Act and its national implementations. If your organisation sells products or services to consumers in the EU via a website or app, you are in scope. This is not a future obligation: enforcement has started.
Why e-commerce is the primary enforcement target
Several factors make online retail the sector most likely to receive enforcement attention first. 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.
Research data from the Barómetro de Accesibilidad Web 2025, covering 204 private-sector websites across seven sectors, found that the majority of e-commerce sites failed to meet core accessibility requirements. The blocking rate for disabled users attempting to complete purchases is significant: tasks that sighted users complete in seconds are simply not available to many assistive technology users.
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 Bundesnetzagentur can additionally impose fines up to €100,000 for serious violations.
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 (approximately €900,000). Sweden operates two fine types: a Sanktionsavgift for non-cooperation with PTS, and a Vite for accessibility issues not remediated within a grace period. Penalty decisions are expected throughout 2026.
Netherlands
The ACM (Authority for Consumers and Markets) is conducting active audits. The fine ceiling is €900,000 or 10% of annual turnover. There is also a mandatory reporting requirement most organisations have missed: businesses must proactively report their accessibility compliance status to the ACM, with documentation and a compliance declaration ready on request. Failure to report puts an organisation at the front of the audit queue.
Ireland
ComReg is the enforcement authority for digital services. Ireland's implementation is notable for criminal sanctions: directors, managers and other officers can be held personally liable for serious or persistent non-compliance. The penalty on conviction in the higher courts is a fine up to €60,000 and/or imprisonment up to 18 months.
What EAA compliance requires for e-commerce
EAA compliance is not a single audit. For an e-commerce organisation, it requires four things:
- 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 on your site, setting out your current compliance position, what is not yet accessible, and your remediation plan. This is the first document enforcement bodies request.
- 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, it is required as part of BFSG compliance. In Ireland, it is the first document ComReg requests in any complaint investigation. In the Netherlands, it forms part of the mandatory reporting declaration. 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.
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 EAA requirements you have addressed, and what a proportionate next step looks like.
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