A customer messages a shop saying they can't complete an order because their screen reader won't let them navigate the form properly. They ask to have the barrier removed.
From 28 June 2025, such a message can constitute an official accessibility complaint. If you fall under the scope of the Act, you have 30 days to review it and respond.
Crucially, missing this deadline carries direct consequences. If a properly submitted complaint isn't handled in time, the law stipulates that it is deemed resolved in favour of the customer's request.
That is why online shop accessibility is no longer just about good practice, UX, or an optional feature for a subset of users.
Who do the new accessibility requirements apply to?
The regulations take effect on 28 June 2025 and stem from the implementation of the European Accessibility Act.
The Act covers specific products and services offered to consumers. These services include, among others, e-commerce, retail banking, telecommunications, e-books, and certain passenger transport services.
For many companies, the most significant of these categories is the first one: e-commerce.
If you run an online shop and sell products or services to consumers, you should check whether your business falls within the scope of the Act.
Does the Act apply to every website?
No.
Simply having a website does not automatically mean a business is subject to e-commerce accessibility requirements.
Among other factors, what matters is whether the website is used to offer a distance service to consumers to conclude a contract.
That means a standard corporate website showcasing an offer may be in a different position than an online shop, a platform selling services, or a website enabling consumers to enter into contracts online.
The type of business activity also matters. A bank, a telecom provider, or a company offering specific transport services may fall under the Act regardless of whether their website resembles a traditional online shop.
What about micro-enterprises?
The Act provides an exemption for micro-enterprises regarding the provision of services.
However, this does not mean every small business is automatically exempt. You must verify whether your company truly meets the statutory criteria of a micro-enterprise.
In practice, before embarking on a major remediation project, you should first establish whether your company falls within the scope of the regulations, and in what capacity.
This avoids both ignoring legal obligations and undertaking costly work purely based on the general assumption that "every website must comply with WCAG now."
An online shop is one of the key cases
In e-commerce, accessibility is directly linked to the ability to complete a purchase.
Users need to be able to find a product, navigate the basket, enter their details, understand form validation messages, select delivery and payment methods, and complete the order.
If any of these stages cannot be operated via a keyboard, or if a screen reader fails to convey the required information, some customers will simply be unable to buy.
That's why, when assessing an online shop's accessibility, the entire checkout journey is far more important than the visual layout of the homepage.
30 days to answer a complaint
A consumer may submit an accessibility complaint to an enterprise regarding a failure to provide accessibility.
As a rule, the business has 30 days from receipt to investigate the matter and respond.
In particularly complex cases, this deadline can be extended. However, you cannot simply reply later. Before the initial 30 days elapse, you must inform the consumer of the reasons for the delay and specify a new deadline.
This extended timeframe cannot exceed 60 days from the original receipt of the complaint.
What happens if you don't reply?
This is one of the most critical provisions of the Act from a business perspective.
If the deadline is missed, the complaint is deemed accepted in accordance with the request of the person who submitted it.
So failing to reply does not just leave an overdue ticket sitting in customer support.
Because of this, any company covered by the rules should establish a clear procedure for handling such inquiries: who receives them, who determines whether they constitute an accessibility complaint, who drafts the response, and who monitors the deadline.
This is a relatively small operational tweak that can be just as crucial as technical fixes on the website.
Not every message automatically qualifies as a valid complaint
The Act also specifies the details a complaint must contain.
Among other things, the customer should specify which accessibility requirement they believe the product or service fails to meet, and state their demand.
Consequently, a vague message like "Your site isn't accessible" doesn't automatically trigger all the statutory consequences of a properly lodged complaint.
Even so, ignoring such feedback is rarely wise. It can highlight a real barrier that stops customers from using your store and hurts sales, regardless of legal implications.
What exactly needs to be accessible in a shop?
The regulations go far beyond adding a button that enlarges text or toggles contrast.
For e-commerce, features related to user identification, security, payments, and contract conclusion carry special weight.
In practice, this means paying close attention to registration, login, search, product pages, the basket, checkout, forms, delivery selection, payments, and error handling.
A customer relying purely on a keyboard must be able to complete the entire journey. Screen readers must correctly announce form fields, buttons, headings, and error notifications.
If clicking "Place order and pay" triggers a visual error message that assistive technologies cannot perceive, the mere presence of the error on screen does not solve the accessibility issue.
You should never treat a widget as a substitute for an accessible website.
Such tools can offer useful user preferences, such as adjusting contrast, text size, or layout presentation.
However, they cannot automatically repair broken form structures, missing labels, incorrect focus order, an inaccessible navigation menu, or a checkout flow that cannot be operated without a mouse.
A similar limitation applies to automated scanners.
They are invaluable for spotting widespread code issues quickly and for ongoing monitoring, but they cannot answer the fundamental question: can someone using assistive technology actually buy a product from start to finish?
Why manual testing is essential
An automated accessibility audit is a solid starting point because it quickly reveals recurring issues across multiple templates.
Following that, however, you must test key processes manually.
In an online shop, the first manual test should be completing an entire order without touching a mouse. The next is going through that exact same journey with a screen reader.
Manual testing frequently uncovers barriers that automated tools miss completely.
You might find that a form contains all required fields technically, but a user has no way of knowing which one failed validation. Or that a delivery method modal can be opened with the keyboard, but cannot be closed.
Don't forget the service accessibility statement
A business's obligations don't end with clean code.
Service providers must also provide information explaining the service and how it meets accessibility standards.
This information can be included in terms and conditions or an equivalent document, and must itself be fully accessible.
Remediating an online shop should therefore be seen as a mix of technical work, testing, and documentation upkeep, rather than merely a punch list of developer tasks.
What if making the shop accessible is disproportionately costly?
The Act allows businesses to claim a disproportionate burden in specific circumstances.
However, this is not as simple as asserting that a rebuild is too expensive.
You must conduct a documented assessment based on statutory criteria. This takes into account accessibility remediation costs, overall operating costs, net turnover, and the estimated benefits for people with disabilities.
Records of this assessment must be retained, and relying on this exception may also trigger an obligation to notify the relevant supervisory authority.
A disproportionate burden defence must be handled as a formal, documented exception, not a shortcut to skip accessibility altogether.
Where should you begin?
First, verify whether your company and its services fall within the scope of the Act.
If they do, designate someone responsible for accessibility inquiries and ensure a valid complaint can never go unanswered for 30 days.
Next, audit the core commercial funnel on your site.
In an online shop, that generally means the path from product page to basket, customer details, payment, and order confirmation.
Only then should you move on to secondary pages and lower-priority features.
This prioritisation eliminates the barriers that create immediate legal liability and directly prevent customers from buying.
Address accessibility before rebuilding your shop
If you are planning a new shop or a major redesign of an existing site, build accessibility requirements into the project from day one.
Structuring forms, UI components, and the purchase flow correctly while designing and building is far easier than tearing down an already launched checkout later.
The same applies to ongoing maintenance. Theme updates, new plugins, or a revised checkout flow can easily reintroduce barriers that were previously resolved.
Accessibility is not a one-off project that ends with an audit.
Want to check your shop's accessibility?
At DOCK, we handle digital accessibility for websites and online shops. We look for issues that automated scans can catch, as well as critical flows that demand hands-on manual testing.
For e-commerce, we focus first on the user journeys that matter most to shoppers and revenue: product pages, basket, checkout forms, delivery, and payments.
We can also help you fix the discovered barriers directly in your existing WordPress, WooCommerce, or custom platform setup.
If you want to know where your online shop stands, get in touch with us. We'll start by checking the touchpoints that could genuinely prevent customers from checking out.
