Insights
E-shop accessibility under the EAA: a practical guide
An e-shop must be accessible under Act No. 424/2023 Coll. since 28 June 2025, unless it is run by a micro-enterprise. Accessible means that a person who uses a screen reader, navigates only by keyboard or needs enlarged text can still complete a purchase. In practice, the benchmark is the EN 301 549 standard, which incorporates WCAG 2.1 at level AA. Besides adjusting the website, you must publish accessibility information and expect supervision by the Czech Trade Inspection Authority.
Verified as of 30 October 2026: the facts in this article are based on the text of the act and on official sources from the European Commission and W3C.
What is the EAA and how is it reflected in Czech law?
The European Accessibility Act (EAA) is Directive (EU) 2019/882. In Czechia it is implemented by Act No. 424/2023 Coll., on accessibility requirements for certain products and services. The act has been valid since 29 December 2023 and in effect since 28 June 2025.
| Date | What happened or will happen |
|---|---|
| 29 December 2023 | Act No. 424/2023 Coll. becomes valid |
| 28 June 2025 | Act takes effect – requirements apply to new services and contracts |
| 28 June 2030 | End of the transitional period for services under older contracts and for products already in use |
Does the act apply to your e-shop?
The act covers selected consumer services. These include:
- e-commerce services,
- financial and banking services,
- electronic communications services,
- access to audiovisual media services,
- e-books and the software used to read them,
- selected services in air, bus, rail and water transport – websites, mobile apps, electronic tickets, information and terminals,
- self-service terminals in urban and regional transport.
If you sell to consumers online, you fall into the e-commerce category.
The micro-enterprise exemption
The act does not apply to services provided by a micro-enterprise. Under the EU definition, a micro-enterprise is a company with fewer than 10 employees and an annual turnover or balance sheet total of no more than EUR 2 million. If you exceed either threshold, the exemption does not apply to you. Check the exact conditions, such as how linked companies are counted, in Commission Regulation (EU) No 651/2014, which the act refers to.
Even if you are exempt, accessibility pays off. An accessible website works better on mobile, for older customers and for search engines.
Our EAA accessibility self-check gives you a quick first orientation.
Which standard must an e-shop meet?
The act describes the requirements in general terms, and Section 16 sets a presumption of conformity: if you meet a harmonised standard, you are presumed to meet the act as well. The act does not explicitly name a specific standard or WCAG.
For web and mobile services, the harmonised standard in practice is EN 301 549. Its version 3.2.1 incorporates WCAG 2.1 at level AA. WCAG (Web Content Accessibility Guidelines) is an international set of rules for accessible web content published by the W3C consortium. Level AA is the middle of three levels and is generally treated as the target standard.
What does an accessible e-shop mean in practice?
WCAG has dozens of success criteria. In e-shops, problems most often appear in these areas:
Keyboard navigation
The whole purchase must be possible without a mouse: menu, filters, choosing a variant, cart, shipping, payment. The element the user is currently on must be visible. Typical problems are drop-down menus, modal windows and custom select controls that cannot be operated by keyboard or cannot be left.
Images and text
Product photos need a text alternative that describes what matters in the image. Icons without text, such as a magnifying glass or a cart, need an accessible name. Text colour must have sufficient contrast against the background. The website must be zoomable without losing content.
Forms and checkout
Every field needs a label, not just grey placeholder text inside the field. An error message must say what is wrong and how to fix it, and a screen reader must announce it. Time limits, such as holding goods in the cart, must be extendable. CAPTCHA must have an accessible alternative.
Page structure
Headings follow a logical hierarchy, the page has a main area and navigation, and links have meaningful text. A screen reader uses all of this to guide the user through the page.
Third-party elements
The cookie banner, chat window, payment gateway or review widget are part of your service. If the cookie banner blocks the page and cannot be closed by keyboard, the purchase stops right at the start. Check accessibility with your suppliers too, and put it in the contract.
A hypothetical example: a furniture e-shop has a colour filter made of coloured squares without text. A screen reader user hears only “button, button, button”. The fix is simple: give each square an accessible colour name and a “selected” state.
What is an accessibility statement?
Section 14 of the act requires the service provider to publish information on how the service meets accessibility requirements. It is published in the general terms and conditions or a similar document. On a website it must be in an accessible format, and on request you must also provide it in audio form.
In practice, it is worth having a separate page linked from your terms and conditions and from the footer. Describe the level of accessibility the service meets, its known limitations and how customers can contact you if they run into a problem.
Are there any transitional periods?
Yes, Section 28 of the act sets several transitional rules:
- Services provided under contracts concluded before 28 June 2025 can continue unchanged until the contract ends, but no later than 28 June 2030.
- Products used to provide services before the act took effect can be used until 28 June 2030.
- Self-service terminals can be used for no more than 20 years from when they were put into operation.
- Older website content that is not updated after the act took effect, as well as older media and office files, are also exempt.
For a typical e-shop that changes all the time, the transitional periods usually do not help much. New orders are new contracts, and the website is updated constantly.
Who checks accessibility and what are the fines?
Supervision of e-commerce and financial services lies with the Czech Trade Inspection Authority (ČOI), the Czech consumer protection authority. Electronic communications are supervised by the Czech Telecommunication Office, audiovisual services by the Council for Radio and Television Broadcasting, and transport by the relevant transport authorities. The Ministry of Industry and Trade is responsible for the act, but it is not a supervisory authority.
The act sets fines for offences of up to CZK 10,000,000. Depending on the type of offence, the upper limit is CZK 10, 5, 2 or 1 million.
How can you quickly test accessibility yourself?
Before you order an audit, spend an afternoon on your own test. It will reveal the most serious problems and show you how big the task ahead is.
- Keyboard test. Put the mouse aside and go through a purchase using Tab, Enter, the space bar and arrow keys. Watch whether you can always see where you are and whether you get stuck anywhere.
- Zoom test. Zoom the page in your browser to 200%. Text must not overlap or disappear, and content should be readable without horizontal scrolling.
- Automated check. Tools built into the browser, such as Lighthouse, or accessibility testing extensions will show missing labels, low contrast and structural errors.
- Screen reader. Turn on VoiceOver on macOS or the free NVDA screen reader on Windows and try to find a product and add it to the cart.
Keep in mind that automated tools find only some of the errors. A score of “100” does not mean the e-shop is accessible.
How to proceed step by step
- Audit. An automated test reveals only some problems, such as missing labels or low contrast. The rest is found by manual testing with a keyboard and a screen reader on key journeys: product search, cart, checkout, registration.
- Prioritisation. Fix what stops a purchase first. Cosmetic issues can wait.
- Fixes. Changes to the template, components and content. On off-the-shelf platforms, find out what the vendor will fix and what you have to change yourself.
- Statement. Publish your accessibility information and link to it from your terms and conditions.
- Monitoring. Every new banner, product or plugin can break accessibility. Check it regularly.
We describe the audit, fixes, statement and monthly monitoring on the Web accessibility under the EAA page.
What to do now
- Check whether you are a micro-enterprise and document the result.
- Go through the whole purchase using only the keyboard, without a mouse.
- Check form labels, error messages and text contrast.
- Review the cookie banner, chat, payment gateway and other third-party elements.
- Have an audit done against WCAG 2.1 AA, both automated and manual.
- Publish your accessibility information and link to it from your terms and conditions.
- Set up a regular check after every major change to the website.
Start with the accessibility self-check, download the checklist in Downloads, or write to us via the contact form and arrange a no-obligation consultation.
Frequently asked questions
Since when must e-shops be accessible?
Act No. 424/2023 Coll. has been in effect since 28 June 2025. From that date, accessibility requirements apply to e-commerce services for consumers.
Does the obligation apply to a small e-shop?
It does not apply to micro-enterprises that provide services. A micro-enterprise has fewer than 10 employees and an annual turnover or balance sheet total of no more than EUR 2 million; once you exceed either threshold, the obligation applies to you.
Which standard must an e-shop meet?
The act does not name a specific standard and refers to harmonised standards instead. In practice, EN 301 549 is used, and its version 3.2.1 incorporates WCAG 2.1 at level AA.
Who checks e-shop accessibility?
Supervision of e-commerce and most other services lies with the Czech Trade Inspection Authority (ČOI). The Ministry of Industry and Trade is responsible for the act but is not a supervisory authority.
What fine can an inaccessible e-shop face?
The act sets fines of up to CZK 10,000,000. Depending on the type of offence, the upper limit is CZK 10, 5, 2 or 1 million.
Do I have to publish an accessibility statement?
Yes, the service provider must publish information on how the service meets accessibility requirements in its general terms and conditions or a similar document. On a website, this information must be in an accessible format.