European Accessibility Act (EAA) in Poland: A Comprehensive Guide for E-commerce

The 28th of June 2025 is approaching — a date that for many online entrepreneurs in Poland, especially online store owners and website creators, means having to comply with new EU requirements. We are talking about the European Accessibility Act (EAA), which aims to harmonise accessibility standards for products and services across the European Union. While this may sound like yet another bureaucratic challenge, in reality the EAA opens the door to a wider customer base and builds a more inclusive market. In this article, we will look at what the EAA means in practice for Polish e-commerce, with a particular focus on WordPress and WooCommerce platforms, based on the current legal status.

What Is the European Accessibility Act (EAA)?

The European Accessibility Act (EAA), formally known as Directive of the European Parliament and of the Council (EU) 2019/882, is a legislative initiative of the European Union. Its main objective is to improve the functioning of the internal market by removing barriers to access to key products and services for people with disabilities and older people. The EAA seeks to harmonise accessibility rules across member states, making it easier for companies to offer accessible products and services throughout the EU and for consumers to use them without obstacles.

The EU background of the EAA stems from the EU’s commitments under the UN Convention on the Rights of Persons with Disabilities. The Act does not impose specific technical solutions, but defines functional requirements that products and services must meet in order to be considered accessible.

Implementation of the EAA in Poland – Legal Basis and Key Dates

In Poland, the European Accessibility Act was implemented through the Act of 26 April 2024 on ensuring that certain products and services meet accessibility requirements by economic operators. This Act sets out the rules and procedures for ensuring accessibility and the supervision of compliance.

The key date from which businesses must apply the new provisions on the accessibility of products and services covered by the EAA is 28 June 2025. Businesses therefore have until this deadline to adapt their products and services — from that date the new provisions will be fully binding.

• Date the EAA provisions enter into force in Poland: 28 June 2025.
• Legal basis: Act of 26 April 2024 on ensuring that certain products and services meet accessibility requirements by economic operators (implementing EU Directive 2019/882).
• Who it applies to: Economic operators placing products on the market or providing services covered by the scope of the Act.

It is advisable to start preparations as early as possible to avoid a last-minute rush and potential problems just before the final deadline.

Who Does the EAA Apply to in Practice? Explaining Exemptions for Micro-enterprises

The European Accessibility Act covers a wide range of economic operators. In the context of e-commerce, every online store selling products or offering services covered by the EAA is required to ensure the accessibility of its sales platform and processes.

However, the Act provides for certain exemptions for micro-enterprises:

• Micro-enterprises (i.e. entities employing fewer than 10 employees and whose annual turnover or annual balance sheet total does not exceed EUR 2 million) that provide services covered by the Act (including e-commerce services, such as running an online store) are exempt from the obligation to apply the provisions of this Act.
• IMPORTANT NOTE: If the same micro-enterprise places on the market (e.g. imports, manufactures or distributes) products covered by the EAA (such as computers, operating systems, payment terminals, e-readers), then with regard to those products it will be subject to the obligations arising from the Act.

Even if a micro-enterprise providing only e-commerce services may formally be exempt, we strongly recommend striving for the greatest possible accessibility. This is not only good business practice, but also a way to reach a wider customer base and build a positive brand image.

What Exactly Must Be Accessible? A Checklist of Obligations for Store Owners

The EAA, and consequently the Polish Act, imposes an obligation to ensure accessibility for a range of elements that are key to the operation of an online store. The standard most often referenced is WCAG (Web Content Accessibility Guidelines), most commonly at level AA (WCAG 2.1 or the newer WCAG 2.2).

Here is what specifically must be accessible in your store:

1. The store’s website (user interface):
   • Navigation: Must be logical, consistent and operable by keyboard. Links should be meaningful and understandable.
   • Content: Appropriate heading structure (H1, H2, H3 etc.), readable fonts, adequate text-to-background contrast.
   • Graphics and multimedia: Images must have alternative texts (alt attribute), and video content must include subtitles for the deaf and/or audio description.
   • Forms: All form fields (contact, registration, login, newsletter sign-up) must be correctly labelled (label elements), and error messages must be clear and accessible.
2. The purchasing process:
   • Product pages: Clear descriptions, accessible images (with alt texts), clear information on price and availability.
   • Shopping cart: Ability to easily add, remove and modify products; keyboard-operable.
   • Order placement process (checkout): Each step must be intuitive, with clear instructions and accessible form fields.
   • Payment process: Integration with payment gateways must ensure accessibility. The choice of payment method must be possible for every user.
3. Store mobile apps: If you have a mobile app, it must also meet accessibility requirements.
4. Downloadable documents: All documents made available to customers (e.g. terms and conditions, privacy policies, PDF instructions) should be accessible (e.g. tagged PDFs).
5. Customer service systems: If you use chats or ticketing systems, they should also be accessible.
6. Payment and self-service terminals (where applicable): If as part of your business you place on the market or use payment terminals, ticket machines, ATMs or other self-service terminals, they must meet accessibility requirements.

In general, the aim is to ensure that a person with a disability (e.g. visual, hearing, motor, or cognitive) can independently and without barriers make purchases in your store.

What Are the Consequences of Non-compliance? Financial Penalties and Reputational Risk

Failure to comply with the requirements of the European Accessibility Act after 28 June 2025 will have consequences. The supervisory authorities in Poland will include, among others, the President of the Office of Electronic Communications (UKE) and the Trade Inspection, depending on the type of product or service.

Potential sanctions:

• Financial penalties: The Act provides for the possibility of imposing financial fines. Their severity can be significant and depends on many factors, such as the type and scale of the infringement, the duration of the irregularity, the degree of the operator’s fault and their previous conduct.
  • A fine may amount to up to 10% of the operator’s annual turnover achieved in the previous calendar year.
  • In cases where turnover cannot be established or does not exceed a specified amount, the fine may amount to up to 10 times the average monthly salary in the national economy for the previous year, as announced by the President of the Central Statistical Office (GUS).
• Compliance order: The supervisory authority may order the removal of accessibility barriers within a specified deadline.
• Withdrawal of the product/service from the market or restriction of its availability: In extreme cases, if the product or service still fails to meet the requirements.
• Reputational risk: A lack of attention to accessibility can negatively affect brand image. Customers are increasingly aware, and news about an inaccessible store can spread quickly, deterring not only people with disabilities, but also their families, friends and those who value inclusivity.
• Loss of customers: An inaccessible store simply represents lost sales potential. It is estimated that as many as 15–20% of the population may experience some form of disability, and when older people are also included, this group becomes a significant market segment.

How to Prepare for the EAA? Audit, Implementation, Documentation

Preparing an online store for the EAA requirements is a process best divided into stages:

1. Education and awareness: Familiarise yourself thoroughly with the EAA requirements, the Polish Act and WCAG standards. Understand what digital accessibility entails.
2. Accessibility Audit:
   • This is the first and most critical step. The audit should assess the current accessibility status of your website and mobile app (if you have one) against WCAG 2.1 or WCAG 2.2 at level AA (recommended).
   • The audit can be carried out by a specialist company or an experienced accessibility expert. You can also start with automated tools (see the tools section), but a full audit also requires manual testing, including with assistive technologies.
3. Implementation plan: Based on the audit results, create a task list and set priorities.
4. Implementation of technical and content changes:
   • Technical: Modifications to HTML, CSS and JavaScript code. Improving keyboard navigation, adapting forms, implementing ARIA.
   • Content: Adding alternative texts, transcripts, subtitles, ensuring readability and text structure, accessible PDFs.
   • Design: Checking contrast, typography, responsiveness.
5. Testing: After implementing changes, conduct re-testing.
6. Documentation and Accessibility Statement:
   • Prepare an Accessibility Statement. This is a public document in which you inform visitors about the level of accessibility of your site/app, indicate any areas that are not yet fully accessible (along with a plan to address them) and provide contact details for the person responsible for accessibility matters. The Polish Act specifies in detail the elements that such a statement must contain for services.
7. Team training: Ensure that your team understands the principles of accessibility.
8. Continuous monitoring and improvement: Accessibility is not a one-off project, but an ongoing process.

Example: What Does the EAA Mean for a Typical WooCommerce Store?

Suppose you run a clothing store on WordPress with WooCommerce. Here is what you need to pay particular attention to in the context of the EAA:

1. Theme: Choose a WordPress theme that is labelled “accessibility-ready” or is well-coded. Check keyboard navigation and focus visibility.
2. Homepage and categories: Sliders/carousels must be pausable and navigable by keyboard, with alt texts. Products with alt texts, readable names and prices. Filtering and sorting accessible by keyboard.
3. Product page: Image gallery with alt texts and keyboard navigation. Product description with heading structure, no justification, good contrast. Variant selection accessible by keyboard and for screen readers. “Add to cart” button clearly labelled and accessible.
4. Cart and checkout process: Form fields with labels (<label>). Error messages clear and accessible (e.g. ARIA). Choice of payment method and transition to it fully accessible.
5. User account: Login, order history, data editing — all accessible.
6. Plugins: Choose plugins carefully. Some may generate inaccessible code.

Remember that even “ready-made” solutions like WooCommerce may require additional adjustments.

What Tools and Plugins Will Help Meet the Requirements?

• Automated accessibility testers (as a first step): WAVE, Axe DevTools, Lighthouse. Note: These will only detect some of the issues.
• Manual testing tools: Keyboard, screen readers (NVDA, VoiceOver, TalkBack), browser developer tools.
• WordPress and WooCommerce:
  • Accessibility-ready themes.
  • Elementor (with verification).
  • Accessibility plugins (WP Accessibility, One Click Accessibility, Accessibility Checker by Equalize Digital). Note: No plugin will provide 100% compliance automatically.
• Code validators: W3C Markup Validation Service, W3C CSS Validation Service.

Summary and CTA: Why You Should Adapt Now

The European Accessibility Act is an inevitable change that came into force on 28 June 2025. Ignoring it means risking financial penalties, reputational damage and, most importantly, excluding a significant group of potential customers.

Adapting your online store to EAA requirements is an investment that brings measurable benefits:

• Legal compliance: Avoiding sanctions.
• Expanding the market: Access to customers with disabilities, older people and their families (up to 20–25% of the population!).
• Better SEO: Many accessibility practices (e.g. semantic HTML, alternative texts) have a positive effect on search rankings.
• Improved UX for everyone: An accessible website is generally more intuitive and easier to use for all visitors.
• Higher conversion rates: Fewer barriers mean a smoother purchase journey.
• Positive brand image: You show that your company is socially responsible.

Don’t wait until the last moment! Start the preparation process today. Carry out an accessibility audit, plan your implementations and make use of available tools. Investing in accessibility is investing in the future of your e-commerce business.

Have questions about the EAA and adapting your WordPress/WooCommerce store? Contact us — we will help you through the process!

Update: Legal Status as of 2025

The European Accessibility Act (EAA) is implemented in Poland through the Act of 26 April 2024 on ensuring that certain products and services meet accessibility requirements by economic operators. Key facts that businesses — especially in the e-commerce sector — must bear in mind:

1. Obligation to apply provisions: Commences 28 June 2025.
2. Who it applies to: Generally all businesses offering products and services covered by the Act (including e-commerce).
3. Exemption for micro-enterprises: Micro-enterprises (fewer than 10 employees and < EUR 2 million annual turnover/balance sheet total) providing services (e.g. running an online store) are exempt from the obligations of this Act. However, if they place on the market products covered by the EAA (e.g. e-readers, payment terminals), they are subject to the Act in respect of those products.
4. Penalties: Non-compliance risks financial penalties (up to 10% of annual turnover or up to 10 times the average salary), compliance orders and even the withdrawal of products/services from the market.
5. Recommendation: Regardless of formal exemptions, taking care of digital accessibility is an investment in business growth, better user experience (UX), better search rankings (SEO) and a positive brand image.

It is advisable to start preparations as early as possible to ensure a smooth transition and avoid problems once the provisions come into force.