Sofia runs a mid-size fashion accessories store on PrestaShop, twelve employees, just over the microenterprise threshold. In June this year — a full year after the European Accessibility Act's compliance deadline — she got an email from a customer who uses a screen reader, explaining that the checkout's payment step couldn't be completed because a required field wasn't labelled for assistive technology. It wasn't a lawsuit. It wasn't even angry. But it was a reminder that "the deadline passed" and "we're compliant" aren't the same statement, and a year into enforcement, that gap is exactly what national authorities are starting to check.
The deadline already passed — here's what that actually means now
Directive (EU) 2019/882, the European Accessibility Act, has applied since 28 June 2025. That's not a future date to plan around — it's already in effect, and has been for over a year by the time you're reading this. What's changing now isn't the legal requirement itself; it's the intensity of enforcement. In the first months after a deadline like this, regulators typically focus on awareness and voluntary correction. A year in, spot checks, complaint investigations, and market surveillance activity tend to pick up, and that's the phase most EU member states are entering now.
Who's covered, and who's genuinely exempt
The Act applies to businesses providing certain products and services to consumers, including eCommerce. There's a real exemption, but it's narrower than many merchants assume: service microenterprises — fewer than 10 employees and annual turnover or balance sheet total of €2 million or less — are exempt from the service-provision obligations. Note the qualifier: this exemption is specifically for microenterprises providing services (which includes running an online store), not a general small-business carve-out. Cross a threshold — hire an eleventh person, or grow past €2M in turnover — and the exemption stops applying, without a grace period tied to when you crossed it.
| Business profile | Accessibility Act status |
|---|---|
| Under 10 staff AND ≤€2M turnover/balance sheet | Exempt (service microenterprise) |
| 10+ staff OR over €2M turnover | Must comply — no exemption |
| Marketplace sellers using someone else's checkout | Platform generally carries primary obligation, but check individual terms |
| B2B-only stores with no consumer sales | Scope is narrower — the Act targets consumer-facing services |
If you're near either threshold, plan as though you'll cross it — retrofitting accessibility after growth is far more expensive than building it in while you're already redesigning for growth anyway.
What "accessible" means in practice for a checkout flow
The Act aligns with EN 301 549, which in turn largely mirrors WCAG 2.1 AA for web content. For a PrestaShop store, that translates into concrete, testable things rather than a vague standard:
- Every form field (including payment fields) has a programmatic label a screen reader can announce
- Colour isn't the only way information is conveyed (error states, stock status, discount badges)
- The full purchase flow — cart, address, payment, confirmation — is completable via keyboard alone
- Text has sufficient contrast against its background at normal and enlarged sizes
- Images carry meaningful alt text, and decorative images are marked as such
- Time limits (session timeouts, flash-sale countdowns) can be extended or disabled
This is not a design-taste question — a store can look polished and still fail every one of these. It's also not usually a rebuild; it's a series of targeted fixes to templates, forms, and theme CSS.
How enforcement is starting to look, one year in
Enforcement mechanisms vary by member state, since the Directive was transposed into national law rather than applying uniformly and automatically. Broadly, expect a mix of: consumer complaint-driven investigations (the most common trigger in year one), market surveillance authority spot checks on prominent or complained-about sites, and — for the most serious or repeated non-compliance — fines set at national level. The practical pattern so far resembles other EU consumer-protection enforcement: authorities rarely lead with penalties, but they do escalate quickly when a business ignores an initial notice. A polite customer email, like the one Sofia received, is often the first and cheapest warning a merchant gets — treat it as one.
The parts of a PrestaShop store audits catch most often
In practice, the failures that come up repeatedly aren't exotic — they're the boring, easy-to-overlook basics:
- Checkout form fields without proper labels, especially payment gateway iframes from third-party providers that the merchant doesn't fully control
- Custom theme colour palettes that fail contrast ratios, often introduced during a rebrand without re-testing
- Product image galleries with missing or generic alt text ("image1.jpg")
- Countdown timers on flash sales with no way to pause or extend them
- Custom modules (reviews, upsells, live chat widgets) built without keyboard navigation support
Third-party payment and shipping modules deserve particular attention — you can fix your own templates, but a checkout that embeds an inaccessible third-party widget still fails as a whole. Ask module vendors directly whether their integrations meet EN 301 549; don't assume.
Accessibility audit checklist
- [ ] Full purchase flow tested with keyboard only, no mouse
- [ ] Screen reader pass (NVDA or VoiceOver) through product page and checkout
- [ ] Contrast ratio check on theme colours, including hover/error states
- [ ] All third-party checkout modules confirmed accessible by vendor documentation
- [ ] Countdown timers and session limits reviewed for pause/extend options
- [ ] Exemption status (staff count, turnover) reconfirmed against current figures
Building an ongoing process, not a one-time fix
The mistake most stores make is treating an accessibility audit as a project with an end date, then never revisiting it. Every theme update, new module, or redesigned checkout step can reintroduce issues that a one-off audit already fixed. Building a lightweight accessibility check into your release process — even just a keyboard-navigation pass before publishing a template change — costs far less than a full re-audit every year. For the deeper implementation walkthrough — specific PrestaShop theme fixes, module recommendations, and testing tools — see our European Accessibility Act PrestaShop implementation guide. It also pairs well with the broader EU compliance checklist if you're auditing multiple regulations at once.
If you've never done a formal check, start this week with the cheapest test available: unplug your mouse and try to complete a full purchase, from product page to order confirmation, using only Tab, Enter, and arrow keys. Wherever you get stuck is very likely where a real customer got stuck too.
Frequently asked questions
Is the European Accessibility Act still upcoming for PrestaShop stores?
No — it already applies, since 28 June 2025. Any "2026 deadline" framing is outdated; what's active now is enforcement, not the compliance date itself.
Which stores are exempt from the European Accessibility Act?
Only service microenterprises — fewer than 10 employees and annual turnover or balance sheet total of €2 million or less. Crossing either threshold ends the exemption immediately, with no grace period.
What accessibility standard does the Act actually require?
It aligns with EN 301 549, which largely mirrors WCAG 2.1 AA for web content — covering things like keyboard navigation, screen reader labels, sufficient colour contrast, and adjustable time limits.
What usually triggers an accessibility enforcement action?
In year one of enforcement, customer complaints are the most common trigger, followed by market surveillance spot checks on prominent or previously flagged sites. Fines are typically a later-stage escalation, not a first response.
Does a third-party payment module make my store non-compliant?
It can, if the module itself isn't accessible — the checkout fails as a whole even if your own templates are fine. Confirm accessibility directly with module and payment gateway vendors rather than assuming.
How often should a PrestaShop store re-check accessibility?
Ideally with every theme update, new module install, or checkout redesign — not just once. A quick keyboard-navigation and screen-reader pass before each release catches most regressions cheaply.
Related reading
- Complete EU Compliance Checklist for Online Stores
- Omnibus Directive Compliance Guide
- Product Safety Compliance Checklist
- Core Web Vitals for PrestaShop
- Understanding GPSR Requirements
