Responsibilities for e-commerce

Accessibility Act

Since June 28, 2025, a law implementing the European Accessibility Act (EAA) has been in force in Poland. This regulation introduces uniform requirements for the accessibility of digital products and services, including online stores and trading platforms.

For e-commerce, this means ensuring that websites, mobile applications, and purchasing processes are understandable, navigable, and usable by all users, including people with disabilities and older people.

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What is accessibility in e-commerce?

Accessibility in e-commerce means adapting online stores to the diverse needs of users so that everyone can freely use the services offered.

In practice, this includes both the design of the website and application, which allows them to be operated without a mouse, using only a keyboard, voice, or assistive technology, as well as the preparation of content, which must be legible, appropriately contrasted, and accessible to screen readers.

Equally important is the design of purchasing processes – so that going through the shopping cart, selecting a payment method, and completing the transaction is intuitive and possible for every user. Regulations require online stores to eliminate digital and technological barriers by creating an interface that does not exclude any group of consumers and ensures equal access to the services offered.

What requirements must an online store meet?

Ensuring clear navigation and full keyboard support, without the need for a mouse.
Adapting content—including product descriptions, instructions, and terms and conditions—to screen readers and ensuring adequate contrast and heading structure.
Include alternative text for graphics and photos so that people using assistive technology can understand their meaning.
Ensuring compatibility with screen readers and assistive technologies such as voice control and eye-tracking devices.
Prepare purchase forms in a way that makes them easy to fill out, with a clear error communication system.
Adapting authorization and payment methods so that they do not exclude people with disabilities (e.g., alternatives to CAPTCHA).

It is also worth remembering to adapt mobile applications to the same accessibility standards as web versions.

Why is it worth implementing solutions now?

What risks does implementing accessibility eliminate?

Adapting your online store to the requirements of the European Accessibility Act reduces the risk of problems that may be both legal and operational in nature.

In particular, it helps avoid situations where customers are unable to complete a purchase due to inaccessible content, incorrect navigation, or incompatibility with assistive technologies. It also protects against supervisory proceedings and financial penalties imposed for violations of the obligations under the Act.

Accessibility Act

Entrepreneurs who take action early enough gain an advantage in several areas:

  • can reach a much larger group of customers, including people with disabilities and the elderly,
  • build a positive image of a company that designs services responsibly and inclusively,
  • improve the quality of the shopping experience, increasing conversion and gaining customer loyalty,
  • improve search engine positioning, as accessible websites have a more organized content structure,
  • avoid rush, delays, and costly implementations carried out under the pressure of statutory deadlines.

Accessibility is therefore an investment in development, not merely the fulfillment of an obligation.

Who is affected by the obligations of the European Accessibility Act?

Learn about the groups covered by the regulation
Online retailers
Marketplace platforms

As a rule, the regulations cover all online stores and trading platforms operating on the European Union market.

The exceptions are few and include:


  • micro-entrepreneurs , i.e. companies employing fewer than 10 employees and with a turnover of less than EUR 2 million,

  • businesses for which compliance would be disproportionately expensive – where it is necessary to demonstrate that compliance with the requirements would constitute an excessive financial burden.

Consequences of non-implementation

Financial sanctions

Violations of the new obligations may result in the initiation of proceedings and the imposition of financial sanctions.

Amount of financial penalties
What does it look like in Poland?

Fines imposed by PFRON or the relevant market surveillance authority may reach up to ten times the average monthly salary, but not more than 10% of the company's annual turnover.

Scope of responsibility

The obligations arising from the Accessibility Act apply to all entities participating in the process of offering digital products and services.

Don't wait - implement accessibility solutions now

The risk of sanctions, combined with the technical requirements, means that postponing implementation can be costly – both financially and operationally.

How to adapt an online store to the requirements?

The accessibility implementation process encompasses both technical and legal elements. Key activities include:

1
Adapting the website and application to the WCAG 2.1 standard

Importantly, this also includes adding alternative texts, ensuring appropriate contrast and full keyboard navigation.

2
Content optimization

In particular, product descriptions, instructions and sales documents – so that they are legible and compatible with screen readers.

3
Providing alternative content formats

Primarily such as transcriptions, subtitles or the ability to listen to the text.

4
Compatibility verification

First of all, the technological compatibility of the website and purchasing processes with assistive tools.

It's worth knowing!

In many e-commerce stores, implementing accessibility also involves streamlining design processes and the way content is published, which in the long run improves the quality of the overall customer service.

Accessibility implementation and further legal support

For entrepreneurs who want to not only meet statutory requirements, but also ensure ongoing support in updating content, procedures and compliance checks, our legal subscriptions are available.

As part of our solution, we will monitor regulatory changes and ensure that your online store complies with accessibility standards – even when new obligations arise or the website architecture needs to be revised.

The subscription is a complement to the implementation process - not an obligation - but for many companies it becomes a natural tool for maintaining compliance in a systematic way.

Legal packages for e-commerce

Need more comprehensive legal support for your business? Choose the package that best suits your online store's needs and ensure you're operating in full compliance with legal regulations. Have questions about our packages or need a package for international markets? Contact us at subskrypcja@ecommercelegal.pl.

Choose a package

Legal Start

Perfect for beginner shops

99 PLN / monthly*

  •  Access to the Customer Zone (an updated database of templates, documents and training courses - including regulations, privacy policies, payment reminders, guides, training recordings)
  •  Email/SMS newsletter with urgent changes in the law
  •  Discounts on ecommerce.legal services (preferential pricing and reduced hourly rate)
  •  Discounts on training and e-books

Legal Flow

Suitable for growing companies

599 PLN / monthly*

  •  Everything from the Legal Start package
  •  Annual legal audit (store audit, preparation/modification of documents) with full report
  •  Free consultation - expansion into foreign markets
  •  Free legal consultations in the form of meetings (once a month)
  •  1 hour of legal services per month (legal advice, preparation of documents)
Recommended

Legal Force

Suitable for medium and large online stores

1499 PLN / monthly*

  •  Everything from the Start and Legal Flow packages
  •  Quarterly legal audit with full report – continuous assurance of legal security
  •  Free legal consultations in the form of meetings (once a month)
  •  Free participation in training courses
  •  A total of 3 hours of legal services per month (legal advice, drafting of documents)

Legal Partner

Comprehensive legal services for e-commerce leaders

2999 zloty
net/month
  • Everything from the Start, Flow and Force packages
  • A team of dedicated lawyers to serve your company
  • Monthly legal audit with a full report on the implementation of changes
  • A total of 6 hours of legal services per month (legal advice, drafting of documents)
  • Free legal consultations in the form of meetings (twice a month)
  • Legal training for the team
  • Priority 24/7 support, priority assistance in the event of PIH/UOKiK/UODO inspections

Summary of the selected package

Legal Start

Perfect for beginner shops

99 PLN / monthly

Contact

Contact us and schedule a free consultation with our expert.

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Alice Christensen
Legal Counsel ecommerce.legal

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