If your online store sells to consumers in the European Union and your business is not a microenterprise, it has had to meet accessibility requirements since 28 June 2025. The rules come from Directive (EU) 2019/882, the European Accessibility Act, which Portugal transposed through Decree-Law 82/2022 and every other member state through its own national law. In practice, a disabled customer must be able to find a product, choose it, pay for it and follow the order, on your website and in your app. Your store must also publish information about its accessibility. This article covers who is affected, what the requirements ask for and how to check where your store stands.
What the European Accessibility Act is
The directive sets common accessibility requirements for a range of products and services across the EU: computers, payment terminals, cash machines, consumer banking, e-books, transport services and e-commerce, among others. It has two aims. Blind, deaf and physically disabled people, and people with cognitive disabilities, should be able to use these products and services on their own. And businesses should face one set of rules in every country they sell to, instead of twenty-seven.
For e-commerce, the directive covers services provided at a distance, through websites and mobile apps, at a consumer's request and with a view to concluding a contract. That means the whole buying journey: catalogue, search, filters, basket, checkout, payment, customer account and order e-mails.
In Portugal, Decree-Law 82/2022 has been in force since December 2022 but applies to products placed on the market and services provided from 28 June 2025. It provides for inspections and fines for businesses that do not comply. If you sell into other EU countries, their national laws apply the same directive, so the requirements are broadly the same wherever your customers are.
Is your store covered?
Two questions settle most cases:
- Do you sell to consumers? The obligation applies to business-to-consumer sales. A store that sells only to other businesses, with no sales to the public, falls outside this part of the law. If you sell to both, you are covered.
- Are you a microenterprise? Microenterprises that provide services are exempt. The directive defines a microenterprise as one with fewer than ten staff and an annual turnover or balance sheet total below the limit set in Article 3 of the directive. Check your own figures with your accountant.
Being exempt is not a reason to ignore accessibility. Disabled customers, older customers and anyone shopping on a phone in poor light or with one hand free are the same people who abandon a difficult checkout. And a microenterprise that grows stops being exempt, often without noticing.
The law also lets a business claim that a specific requirement would impose a disproportionate burden. That assessment must be carried out and documented by the business itself, using the criteria in Article 14 and Annex VI of the directive. It is not a blanket exemption, and it rarely fits an online store.
What the requirements ask for
The law does not hand you a checklist. It describes the outcome: your store's information and interface must be perceivable, operable, understandable and robust.
- Perceivable: anything shown visually has an alternative for people who cannot see it. Product photos have text alternatives, videos have captions, text has enough contrast against its background, and nothing relies on colour alone. A sold-out size, for instance, is marked in text as well as greyed out.
- Operable: the store works with a keyboard alone and with screen readers. Menus, filters, size and colour pickers, carousels and dialogs can all be used without a mouse, with a visible focus indicator. No time limit throws the customer out without warning.
- Understandable: plain language, clearly labelled fields, error messages that say what went wrong and how to fix it, and a checkout that behaves predictably.
- Robust: the code follows web standards, so screen readers, magnifiers and other assistive technology can correctly interpret every button, field and state.
For e-commerce, Annex I of the directive adds two points. Your store must pass on the accessibility information for the products it sells, where the manufacturer provides it. And identification, security and payment functions must be accessible. A checkout with a visual CAPTCHA and no alternative, or a payment step that cannot be completed by keyboard, fails exactly here.
The technical benchmark: WCAG and EN 301 549
To show compliance, the usual reference is the European standard EN 301 549. For web content, it points to the W3C's Web Content Accessibility Guidelines (WCAG) at level AA.
We work to WCAG 2.2 AA, the latest version. It contains every success criterion from the earlier versions and adds a few that matter in a store: minimum touch-target sizes, focus that is not hidden behind sticky headers, and sign-in that does not rely on memory tests such as typing characters from a distorted image.
Publishing accessibility information
Making the store accessible is half of it. The law also asks for information. Under Annex V of the directive, as the service provider, you must explain in your terms and conditions, or an equivalent document, how the service meets the accessibility requirements, including a description of the service and how it works, in an accessible format. That information must stay available for as long as the store is running.
We recommend a dedicated accessibility statement page, linked from the footer on every page. It should state:
- the standard you follow and the level of conformance;
- anything not yet accessible, and when it will be fixed;
- how customers can ask for help or report a problem, by e-mail and by phone;
- the date of the latest assessment.
A statement that claims full conformance without any assessment behind it is worse than none. It sets an expectation the store cannot meet. An honest statement, listing what is missing and when it will be fixed, shows the work is under way.
How to audit your store
A proper audit has three layers.
- Automated tests. Tools such as axe or Lighthouse quickly find low contrast, images without text alternatives and unlabelled fields. They catch only part of the problems, but they show you where to start.
- Manual testing with a keyboard and screen reader. We walk through the whole buying journey with the keyboard alone, then with VoiceOver and NVDA: find a product, pick a variant, add it to the basket, apply a discount code, pay and view the order in the account. This is where the problems that stop a sale show up.
- Content review. Text alternatives that actually describe the product, headings in a logical order, link text that makes sense out of context, and PDFs such as size guides or spec sheets that are accessible too.
The result is a prioritised list of issues, each mapped to a WCAG criterion, with the proposed fix. Checkout and payment come first, because that is where a failure costs you the sale.
If your store runs on a platform such as Shopify or WooCommerce, the theme and the installed apps or plugins matter as much as any custom code. An accessible theme with an inaccessible filter plugin still fails. And accessibility is never done once: every new feature, campaign or plugin should go through the same tests before it goes live.
An example: the size picker
A common pattern on a product page: sizes appear as clickable squares, and sold-out sizes turn light grey. With a mouse, it works. With a keyboard, focus skips the squares entirely, because they are not buttons. With a screen reader, all you hear is "button", with no size, and nothing says that M is sold out.
The fix is small: native controls labelled with the size, the sold-out state given in text, and enough contrast in every state. The result works better for every customer, not only those using assistive technology.
Checklist
- Every product image has a text alternative that describes the product.
- The whole buying journey works by keyboard alone, with focus always visible.
- Screen readers announce filters, variants, basket and checkout correctly.
- Text, buttons and form fields meet AA contrast.
- Form errors say what went wrong and how to fix it.
- There is no CAPTCHA without an accessible alternative.
- The payment step works with a keyboard and a screen reader.
- The store publishes an accessibility statement with a contact for help.
- Every new feature is tested before it goes live.
Where to start
If your store is already live, start with an accessibility audit: knowing what fails, and what matters most, is the basis for every other decision. If you are planning a new online store, build accessibility in from the first design, which is far less work than fixing it later. And if the store needs a deeper overhaul, a redesign can tackle accessibility and speed together.
Accessibility is not the only legal requirement that shows on a store's pages. Businesses selling to consumers in Portugal also need a prominent link to the electronic complaints book.
If you would like help assessing and fixing your store, request a quote. Every project is quoted individually, based on what your store already has.
This article explains the law in practical terms and is not legal advice.
