Since 28 June 2025, the Polish act implementing the European Accessibility Act (EAA) has been in force. If you run an online store or provide online services to consumers, you have specific obligations: adapt your website, app and purchasing process to accessibility standards. Failure to implement them carries a risk of a fine of up to 10% of annual turnover. Below, you will find who the rules cover, what you need to do and in what order.
Note: The obligations also cover importers, manufacturers, distributors and suppliers. This article, however, concerns only businesses providing online services.
What is the EAA Directive and how was it implemented in Poland?
Directive (EU) 2019/882 of the European Parliament and of the Council (the EAA, or European Accessibility Act) establishes minimum accessibility requirements for certain products and services for people with disabilities. In Poland, it was implemented by the Act of 26 April 2024 on ensuring that certain products and services meet accessibility requirements by economic operators.
The rules have applied since 28 June 2025. Their scope includes, among other things, e-commerce services.
Who is covered by the new obligations?
Businesses offering online services must adapt their websites, mobile apps and purchasing processes to accessibility requirements. This applies to:
- businesses operating in the European Union,
- businesses outside the EU that direct their services to users in the EU.
Who is exempt?
Microenterprises are exempt if they meet both of these conditions:
- they employ fewer than 10 people,
- their annual turnover does not exceed EUR 2 million.
Exception: the exemption does not cover microenterprises acting as a manufacturer or importer.
In practice, this means that most medium-sized and large e-commerce businesses providing services to consumers must fully adapt to the requirements of the Act.
What obligations does the Act impose on e-commerce businesses?
Below are seven requirements you need to meet.
1. Assess compliance with accessibility requirements
Carry out an internal accessibility assessment of your digital services. This includes reviewing websites, mobile apps and purchasing processes for accessibility for people with visual, hearing, mobility and cognitive limitations.
To check compliance, use tools such as WAVE (Web Accessibility Evaluation Tool) or Lighthouse (Google).
2. Implement WCAG 2.1 AA standards
Adapt your digital services, website and mobile app to the WCAG 2.1 Level AA guidelines. This is the minimum accessibility standard required in both the public and commercial sectors.
WCAG (Web Content Accessibility Guidelines) is a set of international guidelines developed by the W3C (World Wide Web Consortium). They specify how to make web content accessible to people with different types of disabilities.
Implementation covers four areas:
- Perceivable: content must be available to users with different disabilities. Use alternative text (alt text) for images, provide sufficient colour contrast and allow text to be enlarged.
- Operable: every website function must work without a mouse. Provide full keyboard operation with a visible focus indicator.
- Understandable: content and the interface must be clear and predictable, with unambiguous labels and a logical heading structure.
- Robust: the website must work correctly with different devices and assistive technologies, such as screen readers.
3. Adapt forms and purchasing processes
Registration, login, order and payment forms must meet accessibility standards:
- unambiguous field labels,
- keyboard navigation,
- error messages that every user can understand.
4. Security, payments and identification
User identification systems, electronic signatures and online payment systems must be accessible:
- technically, including compatibility with screen readers,
- functionally, for example by providing a longer session for people with manual difficulties.
5. Multimedia content
Videos, advertisements and other multimedia materials must include:
- captions,
- transcripts,
- audio description, where needed.
6. Provide information about accessibility
Publish information about meeting accessibility requirements in your terms and conditions and documents provided to consumers. Identify the specific features that provide accessibility, such as keyboard operation or text enlargement.
7. Publish an accessibility statement
Publish an accessibility statement on your company website containing:
- a declaration that accessibility requirements are met,
- contact details for reporting accessibility problems,
- the date of the latest update and a remediation plan, if limitations exist.
How to implement EAA requirements in practice
Implementing the EAA is a multi-stage project. It requires the involvement of IT, UX/UI, legal and marketing teams. The following is the order of work:
- Audit the current state: assess your website and mobile app for compliance with WCAG 2.1.
- Map gaps and plan implementation: identify gaps in code, design and content. Set priorities.
- Technical implementation: make changes to the frontend and backend.
- Prepare documentation: develop an accessibility policy and statement.
- Train the team: train employees so that compliance can be maintained in the future.
- Monitor and test periodically: carry out regular audits and adapt the website to new requirements.
Penalties for failing to adapt
A breach of accessibility obligations may result in:
- a financial penalty of up to 10% of the company’s annual turnover or up to 10 times the average remuneration,
- a ban on providing services or making products available,
- an obligation to withdraw inaccessible services from the market.
In the case of e-commerce, supervision is exercised, among others, by the minister responsible for digitalization and the President of the State Fund for Rehabilitation of Disabled People (PFRON).
What do you gain by implementing accessibility?
Digital accessibility is an investment in a better customer experience. Adapting your website to the needs of all users can lead to:
- better usability: a clearer website works better for everyone, not only people with disabilities,
- wider reach: more people can use your services without barriers,
- brand credibility: you show that your business acts responsibly,
- lower legal risk: you avoid penalties and supervisory proceedings,
- better visibility in search engines: accessible websites are indexed more effectively.
Summary
Digital accessibility rules have applied since 28 June 2025 and impose specific requirements on e-commerce businesses. Check whether your business is covered by the new obligations. If it is, carry out an audit, plan implementation and prepare the documentation. Act now, before an inspection takes place.
If this article has not answered all your questions or you need support implementing accessibility requirements, get in touch with us. We can help adapt your business to the applicable rules quickly and without downtime.
Frequently asked questions
Does my online store have to meet digital accessibility requirements from 28 June 2025?
Yes, if your business is not a microenterprise, meaning it employs 10 or more people or has annual turnover above EUR 2 million. Microenterprises that meet both conditions (fewer than 10 employees and turnover up to EUR 2 million) are exempt, unless they act as a manufacturer or importer. The rules cover businesses operating in the EU and businesses outside the EU that direct their services to users in the Union.
What exactly needs to be adapted in e-commerce to meet the EAA requirements?
You need to adapt seven areas: assess the accessibility of digital services; implement WCAG 2.1 AA on the website and in the mobile app; adapt forms and purchasing processes (field labels, keyboard navigation and error messages); ensure payment and user-identification systems are accessible; add captions and transcripts to multimedia content; include accessibility information in your terms and conditions; and publish an accessibility statement with contact details and the date of the latest update.
How do you implement EAA requirements in an online store step by step?
Implementation has six stages: audit the current website and app against WCAG 2.1; map gaps in code, design and content and set priorities; implement technical changes in the frontend and backend; prepare documentation (an accessibility policy and statement); train the team to maintain compliance; and monitor and test periodically. The project requires IT, UX/UI, legal and marketing teams. Plan it before an inspection takes place.
What penalties apply for a lack of digital accessibility in e-commerce?
You may face a financial penalty of up to 10% of the company’s annual turnover or up to 10 times the average remuneration, a ban on providing services or making products available, and an obligation to withdraw inaccessible services from the market. Supervision of e-commerce is exercised, among others, by the minister responsible for digitalization and the President of PFRON.
Is WCAG 2.1 AA a mandatory standard for online stores after the EAA was implemented?
Yes. WCAG 2.1 Level AA is the minimum accessibility standard required in both the public and commercial sectors. It covers four areas: perceivability of content, operability (full keyboard access), understandability of the interface and compatibility with assistive technologies such as screen readers. It gives your IT, UX and product teams a concrete reference point when planning an audit and implementation.
