European Accessibility Act (EAA): prepare your business for changes from June 28, 2025!

The Internet, which was supposed to be a space open to everyone, is still full of barriers for many users. Customers with disabilities or older people often face barriers that make it difficult or impossible to use many digital products and services, including online shopping. To change this, the European Union has introduced the European Accessibility Act (EAA), a directive aimed at ensuring better access to products and services for people with disabilities and those with special needs. In Poland, these provisions have been implemented by law and will come into full force from 28 June 2025.

For companies offering specific products and services, including the e-commerce sector, EAA is not only a new legal requirement, but also a real opportunity to grow and reach a wider group of customers. This article is a practical guide that will help you understand the key aspects of EAA and prepare your business, with a focus on e-commerce, for the upcoming changes.

WHAT IS THE EUROPEAN ACCESSIBILITY ACT (EAA)?

The European Accessibility Act, officially known as Directive (EU) 2019/882 of the European Parliament and of the Council of 17 April 2019 on accessibility requirements for products and services, is the first such comprehensive accessibility regulation in EU law to cover private sector entities. The main objective of the Directive is to eliminate obstacles limiting the independence and comfort of everyday life of people with motor, sensory or cognitive disabilities[cite: 5]. The aim of the Directive is to facilitate access to products and services for as many people as possible, regardless of their fitness or special needs, and to increase public awareness of accessibility. The EAA also aims to harmonise rules across all EU Member States.

In Poland, the EAA was implemented by the Act of 26 April 2024 on ensuring compliance with the requirements for the availability of certain products and services by business entities. This Act defines the requirements for the availability of products and services, the obligations of economic entities in terms of ensuring compliance with these requirements, and the system, principles and procedure for exercising market surveillance. Polish entrepreneurs have until 28 June 2025 to adapt their products and services to the new requirements.

WHO WILL BE AFFECTED BY THE NEW OBLIGATIONS?

Accessibility obligations apply to a wide range of business entities. These include:

• Manufacturers (a person or company that manufactures a product or has it manufactured and sells it under its own brand).
• Authorized representatives (a person or company authorized by the manufacturer to act on its behalf in the EU).
• Importers (an EU person or company that imports products from outside the European Union or EFTA into the EU market).
• Distributors (a person or company that sells a product on the market, but is not its manufacturer or importer).
• Service providers (a person or company that offers services to consumers in the EU).

Important! The provisions of the Act do not apply to services offered or provided by micro-entrepreneurs. According to the available data, micro-entrepreneurs are defined as companies employing fewer than 10 people and generating a turnover of less than EUR 2 million per year or simply employing less than 10 people. However, even these companies can benefit from the voluntary implementation of accessibility policies.

KEY REQUIREMENTS FOR PRODUCTS AND SERVICES, WITH A PARTICULAR FOCUS ON WEBSITES AND E-COMMERCE

For your business, including e-commerce platforms, to be EAA-compliant, it must be digitally accessible. This means designing technological solutions in such a way that they are accessible to all users.

General rules for the availability of information about products and services (in accordance with Articles 7 and 12 of the Act):

• Information should be provided through more than one sensory channel (e.g., information transmitted visually and audibly so that it can be perceived by the sense of sight, hearing, or touch).
• They must be presented in a way that ensures their comprehensibility (i.e. conveyed in a clear, logical way, enabling understanding of their content and purpose).
• Use text formats that allow them to be used in alternative and assistive communication (e.g., text formats that can be read by screen readers or converted to other forms of communication for those who need it).
• Use a font of the right size and typeface, with sufficient contrast and spacing between letters, lines and paragraphs.
• Non-text content must have an alternative presentation (e.g., alt text for images, transcriptions for audio content).
• Websites and mobile applications used to provide services should be perceivable, functional, understandable and compatible.

Specific requirements for e-commerce services (in accordance with Article 18 of the Act):

• Information on the fulfilment of accessibility requirements by products or services should be provided, if this information has been provided by the obliged economic operator.
• The perceptiveness, functionality, comprehensibility and compatibility of functions and methods for identifying the pages of the service, maintaining security and making payments, submitting electronic signatures and payment services that are part of the service must be ensured.

WCAG Standards as a Basis

The key tool for achieving digital accessibility is the WCAG (Web Content Accessibility Guidelines). It is often pointed out that compliance with at least WCAG level 2.1 AA is indicated. WCAG is based on four principles:

1. Perception: Information and interface components must be presented in a way that users can perceive (e.g., alt text for images, subtitles for videos, appropriate colors, contrast, or readability by screen readers).
2. Functionality: The interface must be operable in a variety of ways, including a keyboard or assistive technologies. Elements such as buttons, forms, and navigation must be accessible.
3. Clarity: Content and navigation must be clear, consistent, predictable, and easy to understand. This includes both language and logical structure.
4. Robust (Compatibility): Content must be compatible with a variety of software, including screen readers and assistive technologies. Pages should work properly on different devices and browsers.

Practical Steps for Your E-commerce (and Other Digital Platforms)

Adapting the digital platform to the requirements of the EAA is a process that should be divided into stages:

1. Analysis/Audit: Start with a thorough analysis (audit) of your platform for availability, preferably in accordance with WCAG 2.1 level AA. An audit allows you to detect barriers. It is worth using professional tools such as Axe, Lighthouse or WAVE.
2. Action Plan: Based on the audit, create a list of priority changes.
3. Implementation of Technical and Content Changes:
   • Add alt texts to graphics, photos, and icons (e.g., describing what the image represents).
   • Enable keyboard navigation.
   • Ensure that the text is contrasted in color to the background.
   • Ensure a logical and consistent structure for your headings and forms.
   • Create content in simple, understandable language. Use short sentences and left-align text.
   • Make sure that the links are descriptive (e.g. “see case study” instead of “click here”) and properly highlighted.
   • Buttons and links (CTAs) should be large enough to be easily clicked.
   • Use semantic HTML (<p>, <h2>, etc.) and the correct HTML structure.
   • Make your website mobile-responsive.
   • Order or registration forms must be easy to fill out, and errors must be clearly communicated. Each field should be properly described.
4. Team Training: Editors and site administrators should be trained in the principles of creating accessible content.
5. Testing with Users: Run tests with real users, including people with disabilities, to test practical functionality.
6. Continuous monitoring: Availability is an ongoing process – regular testing, updates and taking into account changes in accessibility standards are crucial.

BENEFITS OF IMPLEMENTING EAA – IT PAYS OFF!

Adapting to the EAA is not only an obligation, but above all an investment that brings measurable benefits:

• Avoidance of financial penalties: Violations of the regulations are punishable by up to 10% of the company’s annual turnover or up to ten times the average salary.
• Reach a wider group of customers: Accessibility opens up your business to millions of new customers, including people with disabilities, the elderly, and people with temporary limitations.
• Improved User Experience (UX): Changes made with accessibility in mind often improve the overall user experience for everyone. Simpler content and easier navigation increase comfort.
• Strengthening the brand image: Companies involved in creating inclusive solutions gain a reputation for being modern, socially responsible and caring for the customer.
• Increased sales: Better availability and a wider audience can translate into increased sales.
• SEO benefits: Many accessibility recommendations have a positive impact on the positioning of the website in search engines.
• Impetus for Innovation: The requirement to ensure accessibility can become a strong incentive for the development of innovative products and technologies.

CONSEQUENCES OF UNAVAILABILITY

Failure to comply with EAA regulations has serious consequences:

• Fines: As mentioned, they can be severe and amount to up to 10 times the average monthly salary or up to 10% of the company’s annual turnover from the previous year. The amount of penalties will be determined by PFRON or the competent market surveillance authority, taking into account, m.in, the scope of the infringement, its severity, the number of products or services that do not meet the accessibility requirements and the number of people adversely affected by it.
• Market Surveillance: The availability of products and services will be subject to control. The market surveillance authorities are, m.in, the President of the PFRON, the President of the Office of Electronic Communications, the minister responsible for computerization, the President of the Office of Rail Transport, voivodeship road transport inspectors, directors of maritime offices, the President of the Civil Aviation Authority, the Financial Ombudsman and customs authorities. These authorities may carry out inspections at entrepreneurs’ premises.
• Corrective actions: In the event of irregularities, the inspection body may call on the entrepreneur to take corrective action (e.g. within 120 days) or withdraw the product from the market/cease the provision of the service. It can also prohibit the provision of a product or service for a certain period of time (e.g. up to 180 days).
• Consumer complaints: Consumers will be able to file a complaint about the lack of availability directly with the entrepreneur or a notification to the President of PFRON. They can also use alternative dispute resolution methods or bring an action before a common court.

HOW CAN SEMIDEA HELP YOUR COMPANY?

We understand that adapting your business to the requirements of the European Accessibility Act can seem complicated and time-consuming. As a Semidea marketing agency specializing in supporting companies from various industries, including e-commerce, we are ready to help you at every stage of this process. We offer support in the field of:

• Audits of the accessibility of websites and e-commerce platforms.
• Design and implementation of available digital solutions.
• Adapting marketing content to plain language and WCAG standards.
• Training for your team on creating accessible messages.

Our goal is not only to help you meet legal requirements, but also to use the potential that accessibility brings to grow your business.

Don’t wait until the last minute! Contact Semidea today to find out how we can support your business in preparing for EAA.

SUMMARY

The European Accessibility Act is a significant step towards a more inclusive market. For entrepreneurs, especially in the e-commerce sector, this is both a challenge and a huge opportunity. Remember that the deadline for implementing the regulations is June 28, 2025.

By acting proactively, you will not only avoid potential penalties, but above all, you will open your business to new customers, build a stronger brand, and contribute to creating a more accessible world.