Accessible e-commerce for everyone - Customer needs and legal requirements

From 28 June 2025, e-commerce among other things, must live up to accessibility requirements for people with disabilities – even temporary ones. In the past, this has only been a legal requirement for the public sector. What do the new EU rules mean in practice and what do customers' needs look like?

Accessible e-commerce for everyone

In an article series on Accessible e-commerce for everyone, we at 3bits will also go through structured and inclusive design, well-thought-out frontend and texts that guide as well as tips for customizing and improving your site.

EU Accessibility Directive

When equal accessibility requirements in different EU countries are introduced through the European Accessibility Act (EAA) it will partly facilitate trade with more effective competition and also ensure respect for people with various disabilities so that they can more easily participate in society. The meaning is that the solutions should be usable by everyone to the greatest extent possible without the need for adaptation or special design.

Accessible EU centre and Svensk Handel organized a longer seminar on the new legal requirements for accessibility that will be introduced in June 2025 through the Act on the Accessibility of Certain Products and Services (2023:254) in Sweden. If you have not already started looking at adapting your business to the new requirements, it is good to plan it as soon as possible. We've summarized some of the things that are worth considering.

In addition to e-commerce, which we focus on in this series of articles, electronic communication services, media services, certain passenger transport services, banking services and e-books are also affected. Among the products covered by the new directive are smartphones, computers, payment terminals, ATMs, interactive information terminals, equipment used to access communication and media services, and reading tablets.

Since 2019, the Web Directive (DOS Act in Sweden) exists for the public sector and now comes the Accessibility Directive for products and services aimed at the consumer market:

  • Accessibility requirements – For websites and apps, the interface and content must be perceivable and operable, understandable and robust. This is based on WCAG (Web Content Accessibility Guidelines) and standards such as EN 301 549. For example, the ability to zoom and read, ALT texts, clear error messages, good enough contrasts and tab navigation. There are four priority functions for e-commerce services where accessibility requirements must be considered – identification, electronic signature, security and payment. There must be an accessible way to accomplish these even if they are sometimes provided separately and not on the e-commerce site.
  • Information requirements – You must inform about the availability of what is sold if there is such information from the supplier. For example, access to a lift, width of doors or whether a telephone supports connecting a hearing aid.
  • Distributor requirements – Check that products covered by the directive that are sold have the correct CE marking and documentation. This responsibility is particularly great in the case of imports. Among other things, you must then add your own contact details to the documentation. If you distribute a product under your own brand, or change a product's availability, you take on the manufacturer's obligations, which are quite extensive.
  • Support services – Customer service, support and the like must be able to inform about the store's availability or how a product is used with aids, and it is also important that they can be contacted via available means of communication. There will be a separate standard for that in 2025.
  • Procedures and documents – Affected e-merchants must have procedures to ensure availability. Review and document how the requirements are met or why exceptions are made and ensure that the documentation is saved for 5 years. It is also important to report any exceptions and deficiencies to the authorities and to have a register of deficiencies and complaints.

There is a lot to handle to meet all requirements for both services and products. Those who do not meet the requirements risk problems for customers and losing customers. But there are also sanctions because it is a law. In addition to not being allowed to provide products on the market if they do not meet the requirements, there are also penalty fees. The amounts vary in the different EU countries, but in Sweden it is between 10 thousand and 10 million SEK. And there may also be a question of several penalty charges if there are several deficiencies.

Accessible e-commerce for everyone

Exceptions and transitional rules

There are three categories of exceptions to the accessibility requirements:

  • Certain content on websites and apps – Like the DOS Act, certain content is excluded. Maps and map services because it can be visually difficult, but you have to offer an accessible option for navigation. Third-party content that you don't pay for or control yourself – primarily user-generated content. Older recordings and documents published before the law came into effect and content that can be considered archived that has not been edited after June 28, 2025.
  • Small organizations – Micro-enterprises that have less than 2 million euros in annual turnover and fewer than 10 employees are exempt from the accessibility requirements for services but only partially for the requirements for products.
  • Unreasonable requirements – Another exception is if the requirement is unreasonable in relation to the benefit, but only as large exceptions as are necessary and only for as long as necessary. Or if it would involve a major change in the fundamental nature of the service or product. There, assessment takes place on a case-by-case basis because all requirements cannot be exempted.
There are also various transitional rules such as for example that routers can continue to be used for another five years even if they do not meet the new rules. Self-service terminals that are already in place can remain until they are 20 years old.

Please read more about digital accessibility at, there are also other links that are relevant to the accessibility directive.

Many stand outside today

Many stand outside of e-commerce today, there is talk of different numbers, but in Sweden it can be almost one in ten, some digital solutions exclude those with, for example, cognitive impairments. According to the WHO, approximately 16% of the world's population has some form of significant disability. It can be anything from the absence of an arm, dyslexia, reduced color vision, concentration difficulties to problems with motor skills. Some consumers end up in contracts or purchases that they didn't really want. It may be about concealed or hidden contractual terms and options that are not really the best for the customer. Some may not even be able to complete the purchase.

Not all disabilities are permanent either, but can be temporary or situational. It could be a temporary eye infection, stress or a broken arm.

Web accessibility is about designing and developing websites and tools so that as many people as possible can use them and absorb the information they offer.


Accessible e-commerce for everyone

The benefits of an accessible e-commerce for everyone are less inconvenience for customers, which leads to more satisfied customers. Fewer obstacles for customers means increased conversion. And with the same requirements throughout the EU, the market becomes larger. In the next part, we will talk more about structured and inclusive design.

Accessible e-commerce for everyone – Structured and inclusive design

In the first part of the article series on Accessible e-commerce for everyone, we reviewed the customers' needs and legal requirements. In the future, we will also look at well-thought-out frontend and texts that guide as well as tips for customizing and improving your site. In this part, we focus on inclusive design and structured flows and processes.

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Sofia Winterlén

Sofia Winterlén Head of Marketing