---
title: "European Accessibility Act II: Websites, Apps and…"
description: "What the European Accessibility Act requires of webshops, banking apps, e-book sellers and other online services since 28 June 2025, how the Web Accessibility…"
url: https://pitch.law/academy/european-accessibility-act-websites-apps-e-commerce
---

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# European Accessibility Act II: Websites, Apps and E-commerce in Practice

What the European Accessibility Act requires of webshops, banking apps, e-book sellers and other online services since 28 June 2025, how the Web Accessibility Directive and EN 301 549 fit in, and what to put in your terms and supplier contracts.

- - By [Bart Lieben](https://pitch.law/team/bart-lieben), Attorney-at-Law
  - 13 November 2026

- Updated

  13-11-2026

## The legal framework

The European Accessibility Act is [Directive (EU) 2019/882](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019L0882) of 17 April 2019, published in the Official Journal L 151 of 7 June 2019. Member States had to adopt their national rules by 28 June 2022 and [apply them from 28 June 2025](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32019L0882#art_31) (Article 31). The rules that bind you are the national laws that transpose it, in Belgium several federal and regional laws and decrees. Scope and exemptions are covered in [European Accessibility Act I](https://pitch.law/academy/european-accessibility-act-scope-and-exemptions). This part is about websites, mobile apps and e-commerce.

### Which online services are covered

[Article 2(2)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32019L0882#art_2) lists the services provided to consumers after 28 June 2025. For most businesses with an online presence, three of them matter most:

- **E-commerce services.** [Article 3(30)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32019L0882#art_3) defines them as services provided at a distance, through websites and mobile device-based services, by electronic means and at the individual request of a consumer with a view to concluding a consumer contract. A webshop, a booking site or an app in which consumers order something falls within that definition.
- **Consumer banking services.** Article 3(28) covers credit agreements, certain investment services, payment services, services linked to a payment account and electronic money, when provided to consumers.
- **E-books and dedicated software.** Article 3(41) covers the digital files of a book and the software, including mobile apps, used to access, navigate, read and use them.

The list also covers electronic communications, access to audiovisual media services and parts of passenger transport.

[Article 2(4)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32019L0882#art_2) excludes some website and app content: pre-recorded time-based media and office file formats published before 28 June 2025, online maps if essential information for navigation is provided in an accessible digital way, third-party content that the operator neither funds, develops nor controls, and archives that are not updated or edited after 28 June 2025.

### The general requirements for every service (Annex I, Section III)

[Article 4(3)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32019L0882#art_4) requires covered services to meet Section III of Annex I (urban, suburban and regional transport excepted) and Section IV. Section III asks the provider to:

- make the products used to provide the service accessible (point (a));
- give information about how the service works via more than one sensory channel, in an understandable way, in adequate fonts with sufficient contrast, and with an alternative for non-text content (point (b));
- make websites, including the related online applications, and mobile device-based services, including mobile applications, accessible "in a consistent and adequate way by making them perceivable, operable, understandable and robust" (point (c));
- where support services exist (help desks, call centres, technical support), have them give information on accessibility and compatibility with assistive technologies, in accessible modes of communication (point (d)).

### The additional requirements per service (Annex I, Section IV)

Section IV adds specific rules:

- **E-commerce (point (g)).** Provide the information on the accessibility of the products and services sold, when the responsible economic operator gives that information. Make identification, security, electronic signature and payment functions perceivable, operable, understandable and robust.
- **Consumer banking (point (e)).** Identification methods, electronic signatures, security and payment services must be perceivable, operable, understandable and robust. Information must be understandable without exceeding level B2 (upper intermediate) of the Council of Europe's Common European Framework of Reference for Languages.
- **E-books (point (f)).** Synchronised text and audio where an e-book contains audio, files that do not prevent assistive technology from working, accessible navigation and layout, alternative renditions, metadata on accessibility features, and digital rights management that does not block accessibility features.

Where these sections do not address a function, the functional performance criteria of Section VII apply, such as at least one mode of operation that does not require vision.

### Information duty and the terms and conditions

[Article 13(2)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32019L0882#art_13) requires service providers to prepare information in accordance with Annex V and explain how the services meet the accessibility requirements. The information must be public, in written and oral format, and accessible to persons with disabilities. It must be kept for as long as the service is in operation.

Annex V says where: in the general terms and conditions, or an equivalent document. Next to the consumer information under [Directive 2011/83/EU](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32011L0083), it contains where applicable a general description of the service in accessible formats, explanations of how it operates, and how the Annex I requirements are met.

Article 13 also requires procedures to stay compliant when the service changes, corrective measures and immediate notice to the authorities in case of non-conformity, and cooperation on request.

### Disproportionate burden and microenterprises

[Article 14](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32019L0882#art_14) limits the requirements where compliance would fundamentally alter the basic nature of the service, or impose a disproportionate burden. The operator must assess this using the criteria in Annex VI, document it and keep the results for five years after the service was last provided. A service provider relying on disproportionate burden must renew the assessment when the service changes, when the authority asks, and in any event at least every five years (Article 14(5)), and must inform the authority (Article 14(8)). Funding received to improve accessibility rules out the argument (Article 14(6)).

[Article 4(5)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32019L0882#art_4) exempts microenterprises that provide services from the requirements. Article 3(23) defines a microenterprise as one with fewer than 10 persons and an annual turnover or balance sheet total of no more than EUR 2 million.

### Standards: EN 301 549

Under [Article 15](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32019L0882#art_15), services that meet harmonised standards whose references are published in the Official Journal are presumed to meet the accessibility requirements, as far as those standards cover them. The Commission had to request such standards. Check the Official Journal for whether a reference has been published under the Accessibility Act before you rely on a presumption.

For public sector websites and apps, a reference does exist. [Commission Implementing Decision (EU) 2021/1339](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32021D1339) of 11 August 2021 lists **EN 301 549 V3.2.1 (2021-03)**, "Accessibility requirements for ICT products and services", as the harmonised standard under the Web Accessibility Directive. It replaced V2.1.2 (2018-08) from 12 February 2022. The Accessibility Act itself names no version of the standard, so if you use EN 301 549 as the yardstick in a contract, name the version.

### The public sector: the Web Accessibility Directive

[Directive (EU) 2016/2102](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32016L2102) covers the websites and mobile apps of public sector bodies. [Article 4](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016L2102#art_4) requires them to be perceivable, operable, understandable and robust. [Article 7](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016L2102#art_7) requires a detailed accessibility statement, a feedback mechanism and a link to the enforcement procedure. It has applied to new websites from 23 September 2019, to all websites from 23 September 2020, and to mobile apps from 23 June 2021 ([Article 12(3)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016L2102#art_12)). If you build websites or apps for a public body, these duties come to you through the contract.

### Transition and enforcement

[Article 32(1)](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32019L0882#art_32) lets service providers keep using products they lawfully used before 28 June 2025 to provide similar services until 28 June 2030. Service contracts agreed before 28 June 2025 may continue unaltered until they expire, but no longer than five years from that date. This transition concerns products and existing contracts. It does not postpone the requirements for a website or app as such.

Consumers and organisations with a legitimate interest can act before the courts or competent administrative bodies ([Article 29](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32019L0882#art_29)). Penalties are national and take into account the seriousness and the number of persons affected ([Article 30](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32019L0882#art_30)). Authorities check services and follow up complaints ([Article 23](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32019L0882#art_23)).

## In practice

**A webshop.** A Belgian retailer with 40 employees sells furniture online. Its product pages, filters, basket, account creation and checkout must work with a keyboard and a screen reader, have sufficient contrast, and offer text alternatives for product images. Where the manufacturer provides accessibility information about a product, the shop must show it (Annex I, Section IV, point (g)(i)). The payment step is usually a third-party plugin, but it is part of the service, so the shop needs a payment provider whose flow is accessible. The general terms get an accessibility section along the lines of Annex V.

**A banking app.** A consumer credit provider updates its app. Login, strong authentication, electronic signing and payments must be perceivable, operable, understandable and robust. The credit information shown in the app must not exceed level B2 in complexity. Legal and product teams need to test their wording.

**An e-book seller.** A publisher sells e-books through its own platform and reading app. The files must not block screen readers, and the metadata must describe accessibility features. Its digital rights management must not switch off text-to-speech or other accessibility functions.

### Contracts with web agencies and SaaS suppliers

The duty rests on the service provider, even when others build or run the service. Pass it on in the contracts:

- **Requirements.** Name the standard as the acceptance criterion, for example EN 301 549 V3.2.1 (2021-03) for web and app content, and list the Annex I points that apply to your service.
- **Acceptance tests.** Include accessibility in acceptance, with manual tests using assistive technology, not only automated scans.
- **Change control.** Every release must keep the level reached. That mirrors Article 13(3).
- **Third-party components.** Payment, chat, cookie banners and video players are part of the service. Ask your [SaaS suppliers](https://pitch.law/academy/saas-agreements) for their own conformity information and a remedy if it turns out wrong.
- **Information and cooperation.** The supplier provides what you need for the Annex V information and for requests from authorities, within a set time.
- **Remedies.** Fix within agreed deadlines, at the supplier's cost where it delivered below the agreed standard, and an indemnity for national penalties caused by its failure.

### Steps

1. Map your consumer services against Article 2(2) and check the microenterprise test.
2. Audit website and apps against EN 301 549, including checkout, login and payment.
3. Add the Annex V information to your terms, in an accessible format.
4. If you rely on Article 14, document the Annex VI assessment and diarise the five-year review.
5. Use the new clauses in every new order and at each renewal.
6. Assign an owner for complaints and contact with the authorities.

## Frequently asked questions

### Our website is only informative. Is it covered?

The Accessibility Act covers specific services, such as e-commerce, banking and transport. Under Article 3(30), e-commerce means services provided at a distance at the request of a consumer with a view to concluding a consumer contract. A website that only informs and through which no contract can be concluded does not meet that definition. As soon as consumers can order or book through it, the ordering part does.

### Does an accessibility overlay or plugin make us compliant?

The Directive sets requirements for the result. No tool is presumed to achieve it. Test the actual site against the standard.

### Can we use the transition period until 2030 for our website?

Article 32(1) concerns products used to provide a service and contracts agreed before 28 June 2025. It is not a general delay for websites and apps.

## How this connects

Accessibility often surfaces in the same review as cookies and tracking, which we cover in [website technology audits and the GDPR](https://pitch.law/academy/website-technology-audits-and-gdpr). The scope of the Act, and its exemptions, are in [part I of this series](https://pitch.law/academy/european-accessibility-act-scope-and-exemptions). We draft and negotiate web agency, development and SaaS contracts with accessibility clauses as part of [commercial contracts and transactions](https://pitch.law/solutions/commercial-contracts-transactions). [Contract Review](https://pitch.law/technologies/clause-library-risk-review) checks existing supplier terms clause by clause, and [Document Studio](https://pitch.law/technologies/contract-studio), our proprietary document analysis and development system, prepares the updated terms and the Annex V text.

> **Cited provisions.** Directive (EU) 2019/882: Articles 2(2) and (4), 3(23), (28), (30) and (41), 4(3) and (5), 13, 14, 15, 23, 29, 30, 31 and 32, Annex I Sections III, IV and VII, Annexes V and VI. Directive (EU) 2016/2102: Articles 4, 7 and 12. Implementing Decision (EU) 2021/1339.
>
> **Key dates.** 23 September 2019, 23 September 2020 and 23 June 2021: public sector websites and apps. 12 February 2022: EN 301 549 V2.1.2 (2018-08) withdrawn in favour of V3.2.1 (2021-03). 28 June 2025: the Accessibility Act applies. 28 June 2030: end of the transition for products already in use and for older service contracts.
>
> **Further reading.** [European Accessibility Act I: scope and exemptions](https://pitch.law/academy/european-accessibility-act-scope-and-exemptions) · [Website technology audits and the GDPR](https://pitch.law/academy/website-technology-audits-and-gdpr) · [SaaS agreements](https://pitch.law/academy/saas-agreements)

## In short

- The Annex I requirements for websites and apps, point by point
- Extra rules for e-commerce, consumer banking and e-books
- The accessibility information you must publish (Annex V)
- Where EN 301 549 and the public-sector rules fit in
- Clauses for web agencies and SaaS suppliers

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