What is the European Accessibility Act (EAA)?
The European Accessibility Act is a directive adopted back in 2019. It places a range of obligations on businesses with the aim of harmonising accessibility standards for products and services across the board.
The Polish Accessibility Act
In Poland, the EAA came into force on 28 June 2025 as part of the Act on Ensuring that Certain Products and Services Meet Accessibility Requirements – referred to here as the Polish Accessibility Act (PAA).
In practice, the PAA is simply the EAA transposed into Polish law.
The goals of the EAA
The European Accessibility Act’s primary goal is to remove the barriers that make everyday life harder for people with disabilities. The EU intends to achieve this by defining and standardising accessibility requirements for products and services across the entire internal market.
The EAA sits within the broader framework of Corporate Social Responsibility (CSR), which holds that businesses should factor in social impact, environmental protection, and stakeholder relationships when shaping their strategies.
The Act should not, however, be seen as an unproductive burden on businesses. One of the practical outcomes of compliance is that companies open themselves up to a wider customer base – making services accessible to people with disabilities means catering to a hard-to-ignore group of nearly 90 million EU citizens.
WCAG – what are the accessibility guidelines?
WCAG, or Web Content Accessibility Guidelines, is a technical standard providing guidance for website and app developers to ensure their products are accessible to all users.
At the heart of WCAG is the POUR framework, which states that content on a website or app should be:
- Perceivable – achieved through adequate contrast, captions for video content, and alternative text describing images.
- Operable – a fully operable site can be navigated entirely by keyboard or screen reader, without needing a mouse. It includes properly labelled text links, titles, and headings.
- Understandable – content uses plain language and a logical structure (such as clear headings), and the site behaves predictably, making navigation easier for all users.
- Robust – content includes metadata such as author information and page titles, helping assistive devices quickly confirm whether the right page is being read and supporting search engine indexing. Robust content should also be regularly tested for accessibility – both through automated tools and real user testing.
EAA vs WCAG – what’s the difference?
- The EAA is a specific directive that places obligations on businesses.
- WCAG is a set of concrete guidelines describing exactly what needs to be done to make websites compliant with the EAA.
Important!
The current applicable standard is WCAG 2.2, which has been in force and required since 28 June 2025. It builds on the previous WCAG 2.1 standard, introducing new accessibility criteria while dropping criterion 4.1.1 (Parsing).
Who does the European Accessibility Act apply to?
The EAA applies to five categories of businesses:
- manufacturers,
- authorised representatives,
- importers,
- distributors,
- service providers
offering products and/or services covered by the Act.
Important!
Importers of products manufactured outside the European Union that fall within the scope of the EAA are also required to comply with the new rules.
Online stores are, of course, among the businesses subject to EAA obligations – and by extension, WCAG compliance – with the exception of those run by microenterprises.
Products and services covered by the Accessibility Act
Article 3 of the Polish Accessibility Act contains a list of the products and services to which the Act applies.
Products covered by the Polish Accessibility Act
- consumer general-purpose computer hardware systems and their operating systems,
- payment and self-service terminals, including:
- ATMs,
- cash deposit machines,
- ticketing machines,
- check-in kiosks,
- interactive information terminals that are not integral parts of cars, aircraft, watercraft, or rolling stock,
- consumer terminal equipment used to access or provide telecommunications services and audiovisual media services,
- e-book readers.
Services covered by the Polish Accessibility Act
- telecommunications services, with the exception of machine-to-machine transmission services,
- services accompanying passenger transport by bus, coach, water, air, and rail, covering:
- websites,
- services offered or provided via mobile devices and applications,
- electronic tickets,
- electronic ticketing systems,
- provision of information related to the above services,
- provision of information via interactive self-service terminals located within the EU,
- retail banking services,
- e-book distribution services,
- e-commerce services.
Who is exempt from the EAA?
The European Accessibility Act does not apply in a number of specific cases.
Micro-entrepreneurs do not have to comply with the EAA
If your company is a microenterprise, meaning:
- it employs fewer than 10 people and its annual turnover does not exceed €2 million,
- the provisions of the Accessibility Act do not apply to it. Therefore, you do not have to maintain accessibility documentation or comply with the EAA requirements.
This doesn’t mean, however, that it’s not worth considering. Meeting even some of the accessibility requirements can bring several specific benefits to your company:
- in the event that it loses its microenterprise status, the company will be ready to adopt the EAA and will not have to rush to implement the guidelines;
- your business will open up to a new group of customers, making shopping easier for them;
- you will strengthen the image of a socially responsible, inclusive company that cares for all customers;
- you will streamline your company’s website and make it easier for customers to navigate it.
Other exceptions
Article 21(1) of the PAD states that accessibility requirements apply only to the extent that ensuring compliance with them:
- does not require the business to make fundamental changes to the product or service,
- does not impose a disproportionate burden on the business.
However, applying these exemptions can be complex and difficult to achieve. The remainder of Article 21 states that the business must make its own assessment, thereby answering the question of whether ensuring compliance with accessibility requirements requires changes to the product or service and does not impose a disproportionate burden.
Assessment of the proportionality of the burden
To make this assessment, the following criteria should be applied:
- the ratio of net costs associated with meeting a specific accessibility requirement to the company’s overall operating and capital costs,
- the estimated costs and benefits for the entity,
- and the ratio of net costs associated with meeting accessibility requirements to the company’s net revenues from selling a product, offering, or providing a service.
Although the rules contained in Article 21 of the PAD are extensive and appear detailed, in reality, these provisions are imprecise and may raise legitimate interpretation questions. If the exemptions in question need to be applied, it may be necessary to obtain an individual interpretation for a specific case – the Act does not specify in which situations this exemption can be used.
EEA in e-commerce – what requirements must be met?
If you run an online store, your company must meet a number of conditions, which we have divided into 6 aspects.
Before You Begin: Accessibility Assessment
To accurately determine which areas of your online store require work to adapt it to EAA requirements, you should conduct an internal accessibility assessment.
To do this, you can use tools such as:
- Google Lighthouse,
- WAVE (Web Accessibility Evaluation Tools),
- Accessibility Checker,
- WCAG Audits – a paid solution
Implementation of WCAG standards
This section should implement the guidelines gathered in the Web Content Accessibility Guidelines. The current standard is WCAG 2.2.
Important!
Online stores should implement all guidelines marked with level AA. Implementing level AAA guidelines is not yet required, although it will certainly positively impact the site’s accessibility for users.
Easier navigation on the website
Your online store should be fully operable using only a keyboard – without the need for a mouse or other pointing device.
Responsive Web Design (RWD) is also worth considering. This is the design of websites so that they are equally accessible on computers, mobile devices, and screen readers.
Compatibility with assistive technologies and devices
An accessible online store is one that allows the use of technologies such as:
- screen readers,
- devices and applications for issuing voice commands (voice commands, voice commerce),
- eye-tracking devices.
Content customization
Visitors to your online store should have easy access to your content. Adapting content to screen readers, as discussed in the previous section, partially meets this requirement, but it’s also necessary to:
- ensure adequate contrast (e.g., by implementing high contrast mode),
- ensure the ability to enlarge the displayed text,
- implement a specific heading structure.
Adaptation of purchasing processes
When designing a purchasing process that adheres to accessibility guidelines, it’s important to ensure:
- Easy customer service – including simple, clear forms, the ability to use text-based communication (chat, contact form) for people with hearing impairments, and communication methods adapted for people with visual impairments.
- Providing documents, user manuals, and product descriptions adapted for readers and other assistive devices.
- Regular accessibility verification – conducting audits and monitoring, the primary goal of which is to identify errors and barriers to accessibility – for example, on newly created subpages.
Important!
The guidelines “How to ensure accessibility of products and services” developed by the State Fund for the Rehabilitation of Disabled Persons may be helpful in meeting the requirements.
What penalties do online store owners face for lack of availability?
Failure to adapt an online store to the EAA requirements carries a significant risk of severe penalties. In Poland, online store owners who fail to comply with WCAG requirements may be fined.
Article 73.1 of the Act on the EAA provides that the fine may amount to a maximum of 10 times the average monthly salary in the national economy for the preceding year, but cannot exceed 10% of the turnover achieved in the financial year preceding the year in which the penalty is imposed.
Important!
Information online often claims that the maximum fine is PLN 10,000. However, this statement is only true in the context of public entities. This is based on the provisions of the Act on Digital Accessibility of Public Entity Websites and Mobile Applications.
Summary
The European Accessibility Act (EAA) regulations may prove to be a significant burden for online store owners, but they also represent a significant opportunity for both customers and stores. Complying with all WCAG guidelines allows companies to reach new customers—people who would otherwise abandon a website because it is too inaccessible.
Addressing the needs of people with disabilities can also prove to be a significant competitive advantage, especially since many companies have yet to implement the solutions required by the EAA.
Frequently asked questions
What is the difference between EAA, PAD and WCAG?
EAA – European Accessibility Act – an EU act defining the requirements that businesses must meet regarding the accessibility of products and services.
PAD – Polish Accessibility Act – is actually the Act of April 26, 2024, on ensuring that businesses meet the accessibility requirements for certain products and services. This act transposes the provisions of the EAA into Polish law.
WCAG – Web Content Accessibility Guidelines – a set of specific solutions that businesses should implement to meet the requirements set by the EAA.
Who does not fall under the EAA requirements?
- Micro-entrepreneurs.
- Companies that demonstrate that implementing EAA solutions would constitute an excessive burden.
- Companies that demonstrate that implementing EAA solutions would require fundamental changes to the products and/or services offered by the company.
What EAA requirements for e-commerce must be met?
- Conducting an accessibility assessment.
- Implementing WCAG standards.
- Easier website navigation.
- Compatibility with assistive technologies and devices.
- Adapting content on websites and applications.
- Adapting purchasing processes to the needs of people with disabilities.
What are the penalties for failing to meet accessibility requirements for online stores?
- A fine of no more than 10 times the average monthly salary in the preceding year, and no more than 10 times the company’s annual turnover.
- An order to adjust or withdraw from the market the product or service affected by the non-compliance.
- A ban or restriction on the right to provide services.
