Selling to Europe? The European Accessibility Act applies to US stores too
The European Accessibility Act has applied since June 28, 2025 and covers e-commerce services offered to consumers in the EU, regardless of where the seller is based. A US store that actively sells to EU customers is in scope unless it qualifies as a microenterprise (fewer than 10 employees and no more than €2 million in turnover or balance sheet). The technical benchmark is EN 301 549, which incorporates WCAG 2.1 Level AA, and enforcement and penalties are set by each member state.
This is not legal advice. It is a builder’s summary of what the Act asks for and where we see US stores caught off guard.
What it is
The European Accessibility Act, Directive (EU) 2019/882, became applicable across the EU on June 28, 2025. It sets accessibility requirements for a list of products and services, and e-commerce is one of them. In practice that means the full path a consumer takes on your site: finding a product, reading about it, adding it to a cart, paying, and getting support afterwards.
Each member state transposed the directive into its own law, so enforcement bodies and penalties differ by country.
Does it apply to a US company
Location does not exempt you. The Act applies to services offered to consumers in the EU. If your store actively sells to EU consumers, it is in scope even if the company, servers and staff are all in the United States.
The signals that you are actively targeting the EU are the ones you would expect: shipping to EU addresses, prices in euros, EU payment methods, local-language versions, marketing aimed at EU countries.
Who is exempt
Microenterprises providing services are exempt: fewer than 10 employees and either annual turnover or balance sheet total of no more than €2 million. Note that the exemption for products is narrower than for services.
B2B-only sellers are generally outside scope if the business-only nature is clear and no consumer contracts are concluded.
If you are a ten-person store doing well, check the thresholds carefully. Many growing DTC brands cross them without noticing.
What the standard asks for
The harmonized standard is EN 301 549, and for web content it incorporates WCAG 2.1 Level AA. If you have done serious ADA work on your store, most of the website side will look familiar:
- Text alternatives for images, including product images.
- Sufficient color contrast.
- Everything operable by keyboard, including filters, carousels and the cart drawer.
- Labeled form fields and clear error messages at checkout.
- Captions for video.
- Content that works when text is enlarged and on narrow screens.
The Act also expects you to provide information about how your service meets the requirements, typically in your terms or an accessibility statement.
Where stores usually fail
Product filters. Custom filter components are often unreachable by keyboard and silent to screen readers.
Checkout. Third-party payment widgets, address autocomplete and error messages that only appear as red outlines.
Apps and plugins. A store theme can be accessible and still fail because of a reviews widget, a pop-up or a chat bubble installed later.
Overlays. Several vendors sell an accessibility toolbar as EAA compliance. An overlay does not change the underlying markup, and the standard is about the markup.
What we would do
- Decide whether you are in scope, with counsel, based on how you actually sell to the EU.
- Audit the templates that make up the purchase path: category, product, cart, checkout, account.
- Fix the theme first, then audit every installed app against the same standard.
- Publish accessibility information and a contact for barriers.
- Re-test after every theme update or new app.
The US side of the same question is covered in ADA website lawsuits in 2026. We are based in Europe and build stores for customers on both sides of the Atlantic; accessibility is cheapest when it starts with the first template. See ecommerce development.
Common questions
How does the EU decide if my store targets EU consumers?
Guidance and commentary point to signals such as shipping to EU addresses, pricing in euros or other EU currencies, EU-specific payment methods, local-language versions and marketing aimed at EU countries. Occasional orders from Europe on a US-only store are a different situation from an active EU storefront. Confirm your position with counsel.
Is a B2B store covered?
The Act covers services to consumers. A store that clearly sells only to businesses and does not conclude consumer contracts is generally outside its scope. A store that sells to both is in scope for the consumer side.
If I fix my site for the ADA, am I covered for the EAA?
Mostly, on the website itself, since both point to WCAG 2.1 AA in practice. The EAA adds obligations of its own, including information about accessibility in your service terms. Treat ADA work as the foundation and check the EAA additions separately.
