Accessibility overlays vs real fixes
A widget on top of the page does not make a shop accessible. Why overlays fall short, and what actually fixes a page.
Since 28 June 2025, most online shops selling to consumers in the EU must be accessible. Who is concerned, what it requires, and what to do first.
For years, digital accessibility was a public-sector obligation. Since 28 June 2025, it is a private-sector one too: the European Accessibility Act (Directive (EU) 2019/882) now applies to e-commerce. In France, it was transposed by a 2023 law and decree. Here is what it means for an online shop, in plain words.
The Act covers e-commerce services offered to consumers: a website or app where people can buy a product or a service. Selling only to other businesses is outside its scope.
One group is exempt: microenterprises that provide services, meaning businesses with fewer than 10 employees and an annual turnover or balance sheet of no more than €2 million. In France, the government's France Num guide puts it simply: since 28 June 2025, online shops run by SMEs must be accessible, except those of microenterprises.
In short: if you sell to consumers online and your business has 10 employees or more, or more than €2 million in turnover or balance sheet, your shop has to be accessible.
The Act sets functional requirements: a person who is blind, has low vision, cannot use a mouse or has cognitive difficulties must be able to find a product, understand it, add it to the cart and pay. In practice, the European standard for websites, EN 301 549, relies on the WCAG 2.1 guidelines at level AA. In France, the reference for checking a website is the RGAA 4.1, which translates WCAG 2.1 into 106 testable criteria.
The whole buying path is concerned, not just the home page: navigation, catalogue, product pages, customer account, cart, payment, order confirmation and online customer service.
In France, the Directorate General for Competition, Consumer Affairs and Fraud Control (DGCCRF) checks e-commerce services. According to France Num, breaches are fifth-class offences: up to €7,500 per legal entity (€15,000 for a repeat offence), and the fines add up per e-commerce service and per obligation. The DGCCRF can also order a business to bring its services into line.
Two more obligations are often missed:
Avoid shortcuts: an accessibility overlay widget does not make a shop compliant, and the US Federal Trade Commission fined one vendor for claiming it did. We explain why in Accessibility overlays vs real fixes.
This article explains the rules; it is not legal advice.
A widget on top of the page does not make a shop accessible. Why overlays fall short, and what actually fixes a page.
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