European Accessibility Act for Websites Outside the EU: Does It Apply to Your Indian Online Store?
Most Indian business owners have heard of GDPR. Far fewer have heard of the European Accessibility Act, even though it has applied since June 28, 2025 and reaches online stores based anywhere in the world. If your website lets consumers in the EU buy from you, the law may require your site and checkout to be usable by people with disabilities, whether or not you have any presence in Europe.
Note: this is general information as of October 2026, not legal advice. Enforcement is handled country by country and the technical standard is mid-update, so confirm how it applies to your business with a legal adviser.
The Short Answer
The European Accessibility Act (Directive (EU) 2019/882) covers e-commerce services and several other consumer services offered to people in the EU. It applies to any business offering those services to EU consumers, including businesses based outside the EU. The sources are consistent that you don't need an EU company, an EU warehouse, or an EU bank account to be in scope. If you only sell to customers outside the EU, it doesn't apply. A narrow exemption exists for very small service businesses, covered below.
Who Is Likely in Scope
As a rough guide, which is not a legal determination:
| Your Situation | Likely In Scope? |
|---|---|
| An online store that accepts orders from EU consumers | Yes, unless an exemption applies |
| A website or app where an EU consumer can conclude a contract, such as a consumer software subscription | Yes |
| A store that sells only within India or outside the EU | No |
| A service sold only to businesses, with no consumer purchases | Generally outside the consumer-focused scope |
| A service business with fewer than 10 staff and turnover or balance sheet of no more than €2 million | Exempt as a microenterprise, for services |
| A microenterprise that makes or supplies covered products | Not exempt for products |
The microenterprise exemption is narrower than it sounds. It requires both a headcount below 10 and the financial threshold, so a business with eight staff and €5 million in turnover doesn't qualify. It applies to services such as online shops, not to products.
Which Standard You Have to Meet
The Act doesn't spell out WCAG in its own text. Instead, a service that conforms to the harmonised European standard, EN 301 549, is presumed to meet the requirements. The picture is changing, so here is where things stand:
- Today in practice: EN 301 549 points to WCAG 2.1 Level AA for web content, and conforming to it is the accepted benchmark.
- What's coming: a new version, EN 301 549 V4.1.1, was published in September 2026 and is based on WCAG 2.2. According to the most recent source I found, it hadn't yet been formally cited in the EU's Official Journal, which is the step that would give it a presumption of conformity.
- The sensible target: WCAG 2.2 Level AA. It builds on 2.1 AA, so meeting it covers the current benchmark and gets you ahead of the update.
What It Means for Your Website in Practice
The standard boils down to four ideas: content must be perceivable, operable, understandable, and robust. For an online store, these are the areas that matter most:
- Text alternatives for meaningful images, such as product photos.
- Keyboard access. Every function, including menus, forms, and checkout, must work without a mouse, with no keyboard traps and a clearly visible focus indicator.
- Colour contrast. Normal text needs a contrast ratio of at least 4.5 to 1 against its background at Level AA.
- Usable touch targets. WCAG 2.2 sets a minimum target size of 24 by 24 CSS pixels for interactive elements, with some exceptions, which matters on mobile.
- Properly labelled forms with clear, specific error messages.
- Captions and transcripts for video and audio.
- Resizable text. The page should still work when text is enlarged to 200%.
- Consistent navigation and a correct language declaration, so assistive technology reads the page properly.
- Accessible payment and identification steps, since the checkout is part of the service that must be accessible. Our guide to accepting international payments covers choosing and setting up a gateway, and the gateway's checkout needs to be tested for accessibility too.
The Accessibility Statement
The Act requires you to publish information about how your service meets the accessibility requirements. In practice that means an accessibility statement, either in your terms and conditions or on a dedicated page. A good one names the standard you aim to meet, describes any known limitations honestly, and gives a monitored way for users to report problems. It should reflect your real level of conformance, not an aspirational one.
Enforcement and Penalties
Enforcement and penalties are set by each EU member state through its own law, so the details differ by country, although the underlying work on your site doesn't. Consequences can include orders to fix the problem and financial penalties. One reported example from June 2026 is a French court ordering a major retailer to make its website and app accessible within six months, with daily penalties for any delay, which shows regulators and courts are acting.
Realistically, a small non-EU business may face less direct regulatory attention than a large EU retailer. Even so, European marketplaces, partners, and larger customers are increasingly likely to ask suppliers about accessibility, and building it in from the start is far cheaper than retrofitting later.
Why Accessibility Overlays Don't Solve It
Some vendors sell a widget that promises instant compliance. Accessibility specialists consistently warn that these overlays adjust the page in the browser without fixing the underlying code, and that they don't produce conformance with EN 301 549. If you're in scope, the reliable route is to fix the actual site.
A Practical Checklist
- Decide whether you're in scope. Do EU consumers buy from you, and are you a microenterprise offering services only?
- Audit your site with both automated tools and manual testing, since automated tools only catch part of the issues.
- Fix the highest-impact areas first: checkout, forms, navigation, contrast, alt text, and keyboard access.
- Test with a keyboard and a screen reader, not just a scanner.
- Publish an accessibility statement with an honest description and a working contact route.
- Build accessibility into your design system so new pages and features don't undo your fixes.
- Re-test after updates, and keep records of what you tested and fixed.
Common Mistakes to Avoid
- Assuming it only applies to EU-based companies. Where you're based doesn't decide it, who you sell to does.
- Relying on an overlay widget as a substitute for fixing the site.
- Forgetting the checkout, which is often the least accessible part of an online store.
- Testing only with automated tools and never trying the site by keyboard.
- Publishing a statement that overstates conformance instead of honestly listing limitations.
- Treating it as a one-off project, then letting new content and features reintroduce barriers.
5 Frequently Asked Questions About the European Accessibility Act
1. Does the European Accessibility Act apply to my Indian website?
If your website lets EU consumers conclude a purchase or contract, very likely yes, since the Act applies to businesses offering covered services to EU consumers wherever they're based. If you only sell outside the EU, it doesn't apply. Confirm your specific situation with a legal adviser.
2. Is my small business exempt?
Only if you're a microenterprise offering services: fewer than 10 employees and annual turnover or balance sheet total of no more than €2 million. Both conditions matter, so a business with few staff but higher turnover isn't covered by the exemption, and it doesn't extend to products.
3. Should I aim for WCAG 2.1 or 2.2?
WCAG 2.2 Level AA is the sensible target. EN 301 549 currently points to WCAG 2.1 AA, but its new version, published in September 2026, is based on WCAG 2.2, and meeting 2.2 AA builds on 2.1 AA, so you're covered both now and after the update.
4. Will an accessibility overlay make my site compliant?
No. Overlays alter the page in the browser without fixing the underlying code, and specialists warn they don't achieve conformance with EN 301 549. Fixing the site itself, then publishing an honest accessibility statement, is the reliable approach.
5. Do I need an EU company or representative to be in scope?
No, scope depends on offering covered services to EU consumers, and the sources state that you don't need an EU entity, warehouse, or bank account to be covered. Some member states may have their own procedural requirements, so check with a legal adviser rather than assuming either way.
How RS Info Solutions Can Help
Accessibility is mostly a build-quality problem, and it's much cheaper to get right during development than to retrofit. We run accessibility audits that combine automated scanning with manual keyboard and screen-reader testing, fix the issues in your theme, templates, and checkout flow, and help you draft the technical content of an accessibility statement. We're web developers rather than lawyers, so we work alongside your legal adviser on the question of scope. If you also sell to European customers, our guide to GDPR for Indian websites covers the privacy side, and our international SEO guide covers reaching them.
Selling to customers in Europe? Get a free website accessibility audit from our team.
