Accessibility guide

E-commerce Accessibility: Why Online Shops Are in Scope

E-commerce is one of the services explicitly listed in the European Accessibility Act, and online shops are also the single most common target of US web-accessibility lawsuits. Beyond the legal exposure, accessibility barriers in a checkout flow directly cost sales. This guide explains why online shops are in scope and the failures that come up most often.

Reviewed by the EAA Navigator team

TL;DR

  • E-commerce is named as a service in scope under the EAA, so online shops selling to EU consumers generally must meet the accessibility requirements.
  • Online retail is also the most frequent target of US ADA web-accessibility lawsuits, which run into the thousands each year.
  • The most common failures are low-contrast text, missing alt text, unlabelled form fields, keyboard traps and missing focus indicators.
  • Accessibility barriers in product pages and checkout cost conversions as well as creating legal risk.
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In this guide

What this covers

  • Why e-commerce is squarely in EAA scope and a frequent ADA litigation target.
  • The accessibility failures that show up most often on online shops.
  • Where in the buying journey those failures cause the most harm — product pages, forms and checkout.
  • How to test and prioritise fixes without relying on automated scans alone.

What matters

Common failures

  • Low-contrast text: the single most common WCAG failure on the web — found on 79.1% of home pages in the WebAIM Million 2025 — and it makes prices, labels and calls-to-action hard to read.
  • Missing alt text: 55.5% of home pages had missing alternative text in 2025, so screen-reader users cannot tell what a product image shows.
  • Unlabelled form fields: inputs without proper labels make search, login and checkout forms unusable with assistive technology.
  • Keyboard traps and broken focus order: users who navigate by keyboard can get stuck in a menu or modal, or lose track of where they are without a visible focus indicator.
  • Empty links and buttons: "add to cart" controls with no accessible name leave assistive-technology users unable to act.

Across web accessibility, Level AA of WCAG 2.2 is the working target, and for the EU it is incorporated into the harmonised standard EN 301 549.

What to do

What to do next

  1. Treat your shop as an in-scope EAA service and set WCAG 2.1 AA (or 2.2 AA) as the target.
  2. Run a keyboard-only pass through search, product page, cart and checkout — if you cannot complete a purchase without a mouse, neither can many users.
  3. Fix the high-frequency basics first: text contrast, image alt text, form labels and visible focus indicators.
  4. Test the checkout with a screen reader, since that is where barriers most directly cost sales and attract complaints.
  5. Publish an accessibility statement with a feedback route, and commission a manual audit to catch what automated tools miss.

For the standard itself, see the WCAG explainer; to put it into practice, work through the WCAG 2.2 AA checklist.

FAQ

Common questions

Is my online shop covered by the EAA?
Most likely, yes. E-commerce is explicitly listed as a service in scope under the EAA, so an online shop selling to EU consumers generally needs to meet the accessibility requirements unless a specific exemption applies, such as the micro-enterprise services exemption.
Why are e-commerce sites sued so often in the US?
Online retail is the most common target of US web-accessibility lawsuits, which run into the thousands a year. Shops are public-facing, transactional and easy to test, so barriers in product pages and checkout are quickly identified.
What are the most common accessibility problems on online shops?
Low-contrast text, missing image alt text, unlabelled form fields, keyboard traps and missing focus indicators. The WebAIM Million 2025 found low-contrast text on 79.1% of home pages and missing alt text on 55.5%.
Does accessibility affect conversions?
Yes. A checkout that cannot be completed with a keyboard or screen reader loses those customers outright, and barriers such as poor contrast and confusing forms add friction for everyone. Fixing them tends to help conversion as well as compliance.

Make your site accessible

Start with the WCAG 2.2 AA checklist, then work through the guides to fix what you find.

Get the WCAG ChecklistTry the contrast checker

This is guidance, not legal advice

This guide is here to help you understand web accessibility and how WCAG, the EAA and the ADA apply in practice. It is not legal advice. For decisions specific to your business, confirm with the official sources we link or a qualified adviser.

Sources

  1. [1]Web Content Accessibility Guidelines (WCAG) 2.2 (W3C Recommendation)retrieved 9 Jun 2026
  2. [2]WCAG overview (W3C Web Accessibility Initiative)retrieved 9 Jun 2026
  3. [3]Directive (EU) 2019/882 — European Accessibility Act (EUR-Lex)retrieved 9 Jun 2026
  4. [4]EN 301 549 v3.2.1 — harmonised ICT accessibility standard (ETSI)retrieved 9 Jun 2026
  5. [5]US DOJ ADA Title II web accessibility rule fact sheetretrieved 9 Jun 2026
  6. [6]WebAIM Million 2025 — accessibility of the top 1,000,000 home pagesretrieved 9 Jun 2026
  7. [7]Overlay Fact Sheet — why overlays do not deliver complianceretrieved 9 Jun 2026

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E-commerce Accessibility: EAA Scope & Common Failures | EAA Navigator · EAA Navigator