Can Foreign Laws Be Applicable to UK Retailers?
In cross-border e-commerce, which laws need to be followed: the country in which the retailer resides or where the product is sold?
Imagine a person with a visual impairment visiting your online shop. If navigation is difficult due to a lack of screen reader support, a challenging checkout process with poor colour contrast and hard-to-recognize buttons, and poorly formatted or unlabeled content, they may leave your site despite the appeal of your products. People with visual, hearing, or mobility impairments often face such barriers in e-commerce.
The European Accessibility Act (EAA) (Directive 2019/882) aims to remove these barriers, ensuring equal access for all users. By 28 June 2025, EU member states must implement these requirements, meaning online shops must soon comply with new accessibility rules.
Increasing accessibility is not just a legal requirement—it also offers a competitive advantage, helping you reach a wider customer base. But what does this mean in practice? This article outlines practical steps to meet the accessibility requirements.
Table of contents:
Why are online shops affected?
The EAA extends accessibility requirements to the private sector, covering both products and services, including those offered to consumers in e-commerce related to contract conclusion. This means the directive applies to any online sale of products or services to consumers. Websites or apps where sales offers, bookings, or payments are made must comply with these accessibility rules. B2B stores are not affected by the directive.
What does "accessible" mean?
According to the EAA, products must be designed and produced to maximize their usability for persons with disabilities. They should also include accessible information about their functions and accessibility features, either directly on the product or through other means.
For digital services, accessibility means ensuring that information is available through multiple sensory channels, is clearly structured and perceivable, and that user interfaces are navigable and operable for different abilities. This includes requirements such as sufficient colour contrast, scalable text, compatibility with assistive technologies, and alternatives to visual or auditory content.
These principles aim to ensure that online shops and digital services across the EU become more accessible to all users.
How to proceed in practice?
The topic of accessibility may initially seem complex and requires a layered approach. However, we want to assure you that, with a well-structured roadmap, the transition to a higher level of accessibility is both realistic and achievable.
Recommended reading:
Make Your Website Accessible for the Blind and Visually Impaired
Does a legal exception apply?
Before taking action, it’s important to determine whether your online store is legally obligated to ensure accessibility. While most online shops are covered by the EAA, certain exceptions may apply:
- Microenterprises: Stores with fewer than 10 employees and annual revenue or balance sheet totaling under 2 million euros are exempt but may choose to voluntarily improve accessibility.
- Disproportionate costs: If the costs of implementing accessibility (e.g., for specialized personnel, training, or process adjustments) are disproportionately high, an exception may apply.
- Fundamental service change: If meeting accessibility requirements requires significant changes (e.g. new technologies) that disrupt the core functionality of the store, this exception can apply but must be carefully evaluated.
Technical implementation
Once you've confirmed that your online shop must comply with the accessibility requirements, the next step is implementation. Your shop must be designed to be perceivable, operable, understandable, and robust for all users.
Certain e-commerce functions—such as identification, authentication, security, and payments—must also be accessible. A key standard for web accessibility is the EN 301 549, which refers to the Web Content Accessibility Guidelines (WCAG). The WCAG are divided into conformance levels:
- Level A (30 success criteria) – mandatory
- Level AA (20 success criteria) – mandatory
- Level AAA (28 success criteria) – voluntary
While Levels A and AA are mandatory, Level AAA provides extended but non-obligatory measures that significantly improve accessibility. For detailed criteria, refer directly to the WCAG.
Recommended reading:
E-commerce Age Verification Laws: Requirements for the UK & Europe
Examples of measures to enhance accessibility
To meet accessibility standards, your website may need several technical adjustments, such as:
- Contrast: Ensure high contrast between text and background for visibility.
- Text-based information: Provide essential info as text (not only images or graphics).
- Clear headings/labels: Make headings and labels easy to understand.
- Adjustable text: Allow users to change text size and line spacing.
- Alternative text: Add descriptive alt-text for all images.
- Multimedia: Include subtitles for videos and allow pausing or stopping.
- Keyboard navigation: Enable keyboard navigation for all interactive elements.
- Form tips: Provide clear error messages and label the required fields.
Focus areas for implementation
Shutterstock/SinFilm
The following areas are essential for usability and accessibility in e-commerce:
- Product pages: Clear details on price, availability, and descriptions.
- Search & filter functions: Accessible and assistive technology-friendly.
- Order overview/input fields: Well-structured cart with clear price info and marked fields.
- Payment & shipping: Accessible selection options.
- Checkout process: Simple, intuitive navigation through to order completion.
- Customer support: Accessible contact options.
- Pop-up/modal windows: Easy to navigate and clearly structured.
By focusing on these areas, you’ll ensure that your online shop is accessible and user-friendly for everyone.
Accessibility statement
An online shop must provide an accessibility statement including the following key elements:
- General description of the service: Provide a clear description of the service that is easily understood by all users, including those with disabilities.
- Explanation of service delivery: Detail how the service is delivered and how users can access it in an accessible manner.
- Compliance statement: Outline the extent to which the shop meets the required accessibility standards.
In addition to these elements, the accessibility statement must meet the basic consumer information requirements. This includes providing the company's identity and contact details (address and phone number), which can either be included directly or referenced from the imprint. The statement must be made available within the general terms and conditions (GTC) or displayed prominently on the website.
With Trusted Shops' Legal Text Generator, you can create a tailored accessibility statement for your online shop (Note: legal texts can be created in many languages).
Recommended reading:
The Digital Markets Act: Shaping Fair Competition in the Digital Age
Accessibility framework in the UK
Following Brexit, the EAA was not implemented in the UK. Instead, the Equality Act 2010 remains the primary piece of legislation in the UK regarding accessibility, including for digital products and e-commerce services. This Act requires that websites and online platforms be accessible to prevent discrimination against individuals with disabilities.
As with the EU, UK businesses generally align with European and international standards, especially the Web Content Accessibility Guidelines (WCAG), to ensure their online offerings are accessible to all users.
Unlike in the EU however, there is no legal obligation in the UK for private companies to provide an accessibility statement. However, voluntarily publishing one can demonstrate a commitment to inclusive design and international accessibility standards. It also helps create uniformity across cross-border online presences and can enhance customer trust.
In the UK, enforcement of accessibility standards falls under the Equality and Human Rights Commission (EHRC), which can investigate complaints and issue recommendations. Non-compliance with accessibility standards could lead to legal challenges and claims of discrimination.
Key advice
Current market studies show that few online shops are actively addressing accessibility requirements, leaving most unprepared for upcoming legal obligations. Taking proactive steps now can reduce legal risks and provide a competitive edge. Early implementation of accessibility measures positions your shop as inclusive, attracting a wider audience in an increasingly competitive market.
Additionally, demonstrating proactive efforts in accessibility may be viewed positively by market surveillance authorities, helping to mitigate the risk of fines.
Check now whether your shop is subject to legal requirements and begin implementing necessary measures. If technical implementation support is needed, consult with accessibility and web development experts to ensure compliance.
For further guidance, whitepapers, and advice on accessibility regulations, you can explore the Trusted Shops Legal Products (in German). With a membership, you can stay up-to-date with the latest developments and navigate all relevant legal requirements in e-commerce effectively. For tailored legal advice, we recommend reaching out to our partner law firm FÖHLISCH Rechtsanwälte, who can assist you with specific legal matters related to your online shop’s accessibility.
Want to know what Trusted Shops does to comply with the European Accessibility Act? Check out our Help Centre article.
