Does Your E-commerce Site Have to Meet Accessibility Requirements?

Most likely, and headcount decides it before revenue does.

Since June 28, 2025, the European accessibility directive has applied to online retail.

Only micro-enterprises are exempt, and the threshold works in this order: fewer than ten people first, then annual revenue or a balance sheet total that doesn't exceed €2M.

The benchmark

Here is what the law says, and what the DGCCRF has done with it since.

• The law. Directive (EU) 2019/882 lists e-commerce among the covered services. In France, its rules are in the consumer code.
• The threshold. Both micro-enterprise conditions must be met, though you can pick either of the two financial amounts. A brand selling €5M with nine employees can therefore stay exempt if its balance sheet stays under €2M. Once it hires a tenth person, it's covered, whatever its revenue.
• The standard. In France, compliance is assessed against the RGAA, which is built on the WCAG 2.1 Level AA criteria that the European standard EN 301 549 also uses.
• The disclosure. Article D. 412-57 and its annex require you to explain, in your terms and conditions or an equivalent document, how the service meets the requirements. In practice, this page is called an accessibility statement. A noncompliant service must also be reported to the enforcement authority.
• The enforcement. It falls to the DGCCRF. In its September 4, 2026 report, relayed by a law firm, it says it has reviewed more than twenty online stores since January and is considering follow-up action against half of them. The failures it found concern the checkout path: insufficient contrast, navigation that's impossible by keyboard, inaccessible delivery or payment options, and images with no alt text.

The rule

Start with the purchase path. Home page, collection, product page, cart, payment: that's where an obstacle costs you a sale, and the failures the DGCCRF found are concentrated there.

That leaves the question the official texts don't answer: cost. In September, our team audited the accessibility of six sites from brands we support.

Each audit produced 11 to 24 fixes, estimated at 20 to 73 development hours per site, or three to ten working days.

Many of the fixes rated urgent were on the path to checkout, like a size selector that couldn't be used by keyboard or a cart drawer that screen readers couldn't announce.

The accessibility statement took two to five hours, writing included.

The steps

1. The keyboard. Go through the whole path without a mouse, from the home page to payment, and note every spot where you lose track of the selected element.
2. The basics. Check contrast, image alt text and field labels, including the promo code field and the cart quantity.
3. The screen reader. Turn on VoiceOver or TalkBack on your phone and try to add a product to the cart.
4. The theme, then the apps. Fix the theme code first, then check what review or translation widgets add.
5. The statement. Publish it, link to it from the footer, list the known defects and a way to contact you, then update it after each round of fixes.
6. The line for leadership:

"We're covered once we reach ten employees, the upgrade is a few days of development work, and the statement can be live this week."

The trap

First, there's blind trust in the Shopify admin. On one of the six sites, the theme did pull the alt text entered in the admin.

One line below, though, it passed a different, empty variable to the image tag, so all 172 images on the home page came out with no alt text. Nothing on screen showed it, and we only spotted it by reading the code.

The fix took half an hour, and it also gave search engines their descriptions back. What the admin shows tells you nothing about what a screen reader receives.

Next comes the module that promises compliance in one click. These overlays don't rewrite the site's code.

In the United States, the FTC ordered the vendor accessiBe to pay $1 million for claiming its widget made any site WCAG compliant, when, according to the agency, it left navigation menus and form fields inaccessible.

Accessibility is handled in the theme, and every customer benefits, starting with people who shop on a phone in bright sunlight.

This guide offers benchmarks and is not a substitute for legal advice.