Accessibility law for small online shops (EAA)

What changed on 28 June 2025

The European Accessibility Act (Directive (EU) 2019/882) sets accessibility requirements for certain products and services. Each member state had to turn it into national law. Germany did this with the Barrierefreiheitsstärkungsgesetz (BFSG). Poland did it with the act of 26 April 2024 on ensuring that economic operators meet accessibility requirements for certain products and services. The main rules of both laws apply from 28 June 2025.

E-commerce is one of the covered services. The laws describe it as a service that is offered through websites or mobile apps, at the individual request of a consumer, in order to conclude a consumer contract (§ 2 BFSG; art. 5 point 32 of the Polish act). A shop that sells to consumers will usually fit this description.

Who is covered and who is not

• Consumers: the rules apply to services for consumers, that is, private individuals who buy for purposes outside their trade or profession. If you sell only to businesses, check carefully whether the rules reach you at all.
• Micro-enterprises: services of micro-enterprises are exempt (Art. 4(5) of the directive). Both conditions must be met: fewer than 10 employees and an annual turnover or an annual balance sheet total of at most EUR 2 million (Art. 3 point 23 of the directive). Germany uses the same thresholds (§ 2 and § 3 para. 3 BFSG). The Polish act also excludes services of micro-enterprises (art. 4 point 1) and refers to the Entrepreneurs' Law: on average fewer than 10 employees and a net annual turnover or balance sheet total of at most EUR 2 million (in złoty) in at least one of the last two financial years (art. 7 para. 1 point 1 Prawo przedsiębiorców). Employees are counted as annual work units, so part-time staff count proportionally. Products are not covered by this exemption. Check the definition in the law that applies to you.
• Products: the exemption names services. If you also make or import products that fall under the laws, such as e-book readers, other rules apply to them.
• Old contracts: service contracts concluded before 28 June 2025 may continue unchanged, at most until June 2030 (§ 38 BFSG; art. 85 of the Polish act). This covers contracts concluded before that date, not new ones.

Whether you count as a micro-enterprise depends on figures you know better than any checklist: employees, turnover and balance sheet total. Write down how you reached your conclusion and when. This text cannot decide it for you.

What the rules ask of a web shop

The German regulation to the BFSG (BFSGV) asks that websites and apps are perceivable, operable, understandable and robust (§ 12). For e-commerce there are additions (§ 19 BFSGV; art. 18 of the Polish act): sign-in, identification, security and payment functions must meet the same four principles, and you must pass on accessibility information about the products you sell if the responsible operator provides it. In Germany, service providers also have to prepare the information required by Annex 3 of the BFSG and make it available to the public in an accessible form (§ 14 BFSG).

A checklist to start with

• Images have a text alternative that does the same job as the image. Purely decorative images have an empty alt attribute (WCAG 1.1.1).
• Everything can be used with the keyboard alone: menu, search, product options, cart and checkout (WCAG 2.1.1).
• Text has enough contrast with its background: at least 4.5 to 1 for normal text (WCAG 1.4.3).
• Every form field has a visible label, also in login and checkout (WCAG 3.3.2).
• Error messages say which field is wrong and what is wrong with it (WCAG 3.3.1).
• Sign-in, identification and payment steps work with a keyboard and a screen reader. Test them yourself or ask someone who uses assistive technology.

What a check can and cannot do

Automated tools find a part of the problems: missing alt texts, missing labels, weak contrast. They cannot judge whether an alt text is meaningful, whether your checkout is easy to understand, or whether your shop meets the law. Treat a score as a hint, not as proof.

A sensible order: run the website check for an overview, then the accessibility check on the pages that matter most (home page, product page, cart, checkout), fix what is clear, and try the checkout with the keyboard. The tools of Do4U give hints and explanations. They are not a legal assessment and not a certificate.