E-commerce

What the EAA covers here

E-commerce is one of the service categories Annex I of the EAA names directly: a consumer-facing website or app that lets someone conclude a purchase contract. That reaches the whole buying journey a customer actually walks through — not just the homepage, and not just the payment step in isolation. A catalogue that’s easy to browse but a checkout that can’t be completed without a mouse still falls short of what the Act is aimed at.

The obligation attaches to the economic operator offering the service to consumers in the EU, regardless of where the operator itself is established. A retailer based outside the EU selling into it is in the same position as one headquartered in a member state.

The buying journey end to end

A useful way to think about scope here is as a sequence, because each step tends to introduce its own failure mode: product discovery and search, product detail pages, cart, checkout — including payment method selection, address and card forms, and error recovery — account creation and login, order confirmation, and the post-purchase surfaces customers come back to: order history, returns, and support.

Third-party components sit inside that sequence too. Payment iframes, address-lookup widgets, and consent banners are frequently supplied by a vendor rather than built in-house, but they still sit inside the checkout flow a customer has to get through, so they’re part of what a review of that flow has to look at.

Where the obligation actually bites

The EAA has applied since 28 June 2025. Microenterprises — fewer than 10 people and either annual turnover or balance-sheet total no more than €2 million — providing services are exempt from the accessibility requirements, though that’s a narrow carve-out and doesn’t extend to every small online shop. Whether a particular storefront falls inside this area, and whether an exemption applies to it, is a determination for the operator running it, not something a page like this one can settle in the abstract.

What auditors look at first

In practice, a first pass tends to concentrate on the parts of the journey where a purchase can actually be lost: whether checkout form fields keep a visible, programmatic label through every state; whether an error is announced and tied to the field it belongs to; whether cart and price changes are exposed to assistive technology as they happen, not just visually; and whether every control in the flow — search, filters, quantity steppers, payment selection — can be reached and operated from a keyboard alone, with a focus indicator that’s actually visible at each step.