The European Accessibility Act (Directive (EU) 2019/882) has applied since 28 June 2025 and requires consumer e-commerce services in the EU to be accessible. For product content this means text alternatives for images, captions for video, accessible documents and information about the accessibility features of the products being sold.
The European Accessibility Act (EAA, Directive (EU) 2019/882) has applied since 28 June 2025 and requires e-commerce services offered to consumers in the EU to be accessible to persons with disabilities. For product content teams, compliance reaches beyond the storefront code: images need text alternatives, video needs captions, documents must be readable with assistive technology, and shops must pass on information about the accessibility features of the products they sell.
What the European Accessibility Act requires from online shops
Annex I, Section IV of the directive sets three requirements specific to e-commerce services:
- Providing information about the accessibility of the products and services being sold, when the responsible economic operator supplies that information.
- Making identification, security and payment functions accessible when they are delivered as part of the service.
- Making identification methods, electronic signatures and payment services perceivable, operable and understandable.
General service requirements also apply, including making websites and mobile applications accessible in a consistent and adequate way and presenting information in more than one sensory channel. In practice, organisations use EN 301 549, which incorporates WCAG 2.1 level AA, as the technical reference.
Manufacturers of products in scope, such as computers, smartphones, e-readers and self-service terminals, carry a separate duty under Annex I, Section I: information on use, including labelling, instructions and warnings, must be available via more than one sensory channel and in accessible formats.
Who is in scope and from when
| Topic | Rule |
|---|---|
| Application date | 28 June 2025 (Article 31) |
| E-commerce scope | Services provided at a distance, by electronic means, to consumers |
| Microenterprise exemption | Service providers with fewer than 10 persons and turnover or balance sheet up to €2 million (Article 4(5)) |
| Transitional period | Until 28 June 2030 for products already used to provide services (Article 32) |
| Disproportionate burden | Assessed and documented case by case (Article 14) |
Enforcement sits with national market surveillance authorities under transposing laws such as Germany's Barrierefreiheitsstärkungsgesetz (BFSG). Penalties and procedures differ by Member State.
The information requirement also creates a dependency along the supply chain. Retailers and marketplaces can only display accessibility information that manufacturers and brands provide, so that data has to travel through supplier templates, GDSN or syndication feeds alongside other product attributes. Brands selling through several retailers gain from publishing it once in a structured form.
Which product content elements are affected
Many accessibility defects on product pages trace back to missing or unstructured content, which makes the PIM and DAM the logical place to fix them.
| Content element | Accessibility need | Data action |
|---|---|---|
| Product images | Text alternative describing the relevant content | Alt-text field per image and locale |
| Product video | Captions, transcript and, where needed, audio description | Caption and transcript files linked in DAM |
| Manuals, datasheets | Tagged PDF or HTML with headings and reading order | Accessible document version as an asset |
| Colour and variant swatches | Meaning conveyed without colour alone | Text colour name attribute per variant |
| Size charts, spec tables | Structured tables with headers | Tables rendered in HTML from attributes |
| Product accessibility features | Information for buyers with disabilities | Dedicated attributes for features such as screen reader support, hearing aid compatibility or tactile markings |
Text embedded in images is a frequent issue. Promotional banners and infographic-style product images with key specifications baked in fail unless the same information is available as text.
How to model accessibility data in PIM and DAM
Accessibility content behaves like any other localised attribute and needs the same governance:
- Alt text: store in the DAM as asset metadata, with an override per product context in PIM where one image serves several products. Follow the DAM metadata taxonomy and translate per locale through the multilingual content workflow.
- Accessibility features: add a controlled list of feature values per product family, supplied by manufacturers through supplier onboarding templates.
- Documents: hold the accessible version as the primary asset and add an accessibility conformance flag.
- Completeness rules: treat alt text and captions as required for publication to consumer channels.
AI image description can produce first drafts of alt text at scale, but descriptions of technical details still need review. For DAM vendor comparisons that include metadata and accessibility capabilities, see DAM Atlas.
Practical next steps
- Confirm which storefronts, apps and marketplaces sell to consumers in the EU.
- Audit a sample of product pages against EN 301 549 and WCAG 2.1 level AA, focusing on content defects.
- Add alt text, caption, accessible document and accessibility feature fields to the data model.
- Request accessibility feature data from manufacturers for products in scope of the EAA.
- Add completeness rules that block consumer publication without required accessibility content.
- Document any disproportionate burden assessments and review them periodically.
Frequently asked questions
Does the European Accessibility Act apply to B2B web shops?
The e-commerce provisions cover services provided to consumers. Pure B2B shops that do not sell to consumers are generally outside the e-commerce scope, although mixed B2B and B2C storefronts usually fall within it.
Which technical standard is used to meet the EAA for websites?
Most organisations use EN 301 549, which incorporates WCAG 2.1 level AA for web content, as the practical reference while harmonised standards under the EAA are finalised. National guidance may add detail.
Are existing product pages exempt until 2030?
No general exemption exists for web content. The transitional period to 28 June 2030 concerns products already used to provide services and service contracts concluded before 28 June 2025, and Member States apply it through national law.