The EAA deadline has passed and your checkout funnel is in scope
Since 28 June 2025, the European Accessibility Act is enforceable law across every EU member state. For Dutch and Belgian merchants who have been treating this as a future compliance task, that future has arrived. The regulation is not abstract: it reaches directly into the checkout flow, order forms, payment steps, and returns portals that shoppers use every day.
The EAA requires digital services to be perceivable, operable, understandable, and robust. In practice, this maps onto WCAG 2.1 and the harmonised standard EN 301 549. For a checkout journey, that means keyboard-navigable payment steps, adequate colour contrast on call-to-action buttons, descriptive error messages when a form field fails validation, and captions on any instructional video embedded in the purchase flow. No stage of the customer journey is exempt: the obligation runs from the homepage search bar through to the returns portal.
Merchants commonly limit their accessibility work to visible front-end adjustments: button sizes, alt text, contrast ratios. These fixes are necessary but incomplete. Page load performance is also a functional barrier. Screen readers, screen magnifiers, and voice control software impose higher processing demands, meaning a slow page hits assistive technology users hardest. The argument that slow delivery constitutes inaccessible delivery is gaining traction with regulators and in civil courts, and merchants should take it seriously.
The micro-enterprise exemption, covering businesses with fewer than ten employees and annual turnover below two million euros, gives the smallest operators some flexibility. Any merchant of meaningful scale has no equivalent cover. Enforcement approaches differ across member states, but the exposure to complaints, regulatory investigations, and civil claims from affected users is genuine and increasing.
The most productive reframe for merchants is to treat accessibility gaps as conversion problems rather than pure compliance burdens. Barriers that block or frustrate disabled shoppers, poorly labelled fields, unclear error states, non-keyboard-accessible modals, are almost always friction points that slow or deter all shoppers. An accessibility audit of the full purchase funnel, not just the homepage, is therefore both a legal obligation and a concrete opportunity to reduce drop-off.
Source: eur-lex.europa.eu
