Accessibility reached European commerce through a text about products and services, not through a design manual. That changes who answers for it. It is no longer the taste of whoever built the site; it is a characteristic of what you sell, in the same family as a label or a declaration of conformity, and it is asked of the seller. An exporter who files it under marketing will discover the mistake the day a customer, a marketplace or an authority asks for the statement by name.
What is in scope: the site, the app, the checkout and the after-sales
Selling to consumers at a distance through a website or an application is treated as a service, and the obligation follows the whole purchase path rather than the home page. Finding the product, reading what it is — including the information about the accessibility features of the product itself — creating an account, paying, receiving the confirmation and the invoice, asking for a return, and reaching a human in after-sales: all of it is in scope. Certain hardware has its own separate requirements, which matters if you sell terminals, readers or devices with an interface, but for an online seller the burden sits on the interface and the documents.
What it means on a real product page
- Everything reachable with a keyboard. Menus, filters, image galleries, size selectors, modals and the payment step, in a logical order, with a focus outline you can actually see — and nothing that traps the focus inside a popup with no way out.
- Contrast that survives your brand palette. Text against its background, and also the parts that carry meaning: buttons, form borders, error messages, icons that stand alone. Pale grey on white is the most common failure on an otherwise beautiful shop.
- Alternative text that says what the image shows. Not the file name, not the product reference repeated. If the photograph carries information — a connector shape, a colourway, a dimension drawing — the alternative says that information, and a purely decorative image is marked as decorative.
- Form fields with real labels, and errors tied to the field. A placeholder that disappears when you type is not a label. An error has to say which field is wrong and what is expected, in text, next to the field, and be announced rather than only coloured red.
- Documents readable by a screen reader. The manual, the safety sheet, the warranty and the invoice as real text with a structure — not a photograph of a printed page, which is silent to assistive technology and invisible to search engines at the same time.
- No information carried by colour or shape alone. Stock status, the selected variant, a required field, a promotion: each needs a word as well as a colour. The same rule applies to text baked into a marketing image, which nothing can read.
- Headings in order, and zoom that does not break the page. One page title, sections nested properly, and a layout that reflows when the visitor enlarges the text instead of forcing a horizontal scroll through the checkout.
Which standard the requirements point to
The law states outcomes rather than code: the service must be perceivable, operable, understandable and robust for people with disabilities. Conformity is then presumed when you follow the harmonised European standard on accessibility requirements for information and communication products and services, which itself takes over the international web content guidelines. That is the useful consequence for a seller: you do not argue about the law with your developer, you hand over the standard and ask for the funnel to be tested against it. Alongside it comes a declaration: you publish the state of conformity of your service, with a channel through which a visitor can report a barrier and get an answer.
Escape routes exist, and each is narrower than it looks. Service providers below the size at which the service obligation bites — the micro-enterprise regime — may be relieved of it, but the assessment is made on your own headcount and turnover, not your reseller's, it does not extend to products, and it does not remove the consumer-information duties that live elsewhere. The other route is the disproportionate burden argument, which has to be documented, reasoned and revisited rather than asserted, and which an authority can read. Treat each as a position you might have to defend in writing, not as a reason to skip the work.
Why a theme bought off the shelf does not make you compliant
A theme ships a skeleton, tested on demo content, by someone who did not know what you would add. What breaks it is everything you add afterwards: the review widget, the size-guide popup, the currency switcher, the chat bubble, the cookie banner, an icon font with no text behind it, photographs with the offer written inside them, and a manual uploaded as a scan. The checkout is frequently a separate application, sometimes hosted by your payment provider, and it is the single place where a barrier costs an order rather than a visit. A vendor's accessibility claim describes the demonstration shop; the obligation applies to yours, with your apps, your content and your edits.
Where to start when the catalogue is already online
- Walk the purchase path with the keyboard only, then with a screen reader, from the category page to the order confirmation. Write down where you got stuck. That list, not an audit report, is your work order.
- Fix the funnel first — cart, delivery choice, payment, confirmation — before touching the home page. A barrier there costs money today and is the first thing anyone testing you will try.
- Put the content rules into the product sheet template and into the brief of whoever fills it: alternative text, headings, no text inside images, labels on every field. A rule in a template is applied; a rule in a document is not.
- Replace scanned documents with real text — manuals, warranty terms, safety information — and keep the source file so the next language version is a translation rather than a new scan.
- Publish the accessibility statement with a contact that works, and answer what arrives through it. An honest statement describing known gaps and a plan reads better to an authority than a claim of full conformity that the first test contradicts.
- Add accessibility to the acceptance test of every new app, theme update and landing page. The work is only expensive once; letting it decay is what makes it expensive again.
Before commissioning an audit, do the keyboard walk yourself on your best-selling product and through to payment. It takes an afternoon, it needs no tool, and it produces the one artefact an agency cannot sell you: the list of barriers that sit between a customer and your order button, ranked by what they cost. Hand that list and the harmonised standard to your developer as the brief, keep the scanned documents as a separate workstream because they belong to whoever writes the manuals, and only then publish a statement you can stand behind.
Where to read it yourself
Official pages, opened and checked on 15 October 2026. Where a rule changes, these are the addresses that change with it — this article does not.