Ninth Harbor

The accessibility deadline for EU shops passed a year ago. Enforcement has started. Where does your store actually stand?

A manual gap review of your shop's real purchase flows against EN 301 549, with a prioritized fix list your developer can execute. EUR 149, delivered within 2 business days.

Who this is for

Owners and e-commerce managers of small EU B2C shops. The European Accessibility Act's requirements for e-commerce services have applied since 28 June 2025, and 2026 is the year the enforcement machinery visibly switched on (evidence below, each item with its source).

First, the honest carve-out. Services provided by microenterprises are exempt: fewer than 10 persons and annual turnover or balance sheet total not exceeding EUR 2 million. Both conditions must hold, and the exemption for your services ends as soon as you cross either threshold; there is no grace period. The exemption covers service obligations, not product obligations. (Sources: Level Access EAA overview, Rivenburgh on the microenterprise exemption.) If you are safely under both thresholds, the EAA's service requirements likely do not apply to your shop and you probably do not need this report. If you are near either line, or part of a group, that boundary question is one of the things the report answers with your actual numbers.

What is verifiably happening right now

All items checked against their sources on 17 July 2026.

France: first court ruling, against an e-commerce player. On 4 June 2026 a French court ordered Carrefour to make its website and app fully accessible within six months, with a daily penalty for every day of delay. The court found the site unusable for blind customers, specifically in checkout. Source: li.solutions, EAA enforcement 2026 (8 July 2026). Disability organizations had already filed injunctions against Auchan, E.Leclerc and Picard in November 2025: Deque, early signs of EAA enforcement (19 December 2025).
Netherlands: the regulator is working through e-commerce. The ACM set an October 2025 deadline for non-conformance reporting, sent information requests to e-commerce operators including non-EU companies, and prioritized non-responders for audits from spring 2026. Active enforcement is expected in the second half of 2026. Sources: Deque, li.solutions.
Germany: two live enforcement channels. The states' joint market surveillance authority (MLBF) adopted its surveillance strategy on 29 January 2026 and is in its active control phase, checking shops both systematically and on complaint. Separately, competitors and recognized associations can send fee-bearing warning letters (Abmahnungen) over accessibility failures, with documented cases since summer 2025. That private channel reaches shops of every size. Sources: ehome-news on the MLBF control phase, anwalt-seiten.de on BFSG duties and Abmahnungen.
Sweden: first regulatory e-commerce cases open. The PTS opened its first regulatory cases against e-commerce operators, with compliance inspections continuing into 2026. Source: Deque.

What we will not tell you: that you will be fined tomorrow. No EU market surveillance authority is publicly fining small shops yet. The verified pattern is big-retailer lawsuits in France, regulator sweeps in the Netherlands and Sweden, and private warning letters in Germany. The machinery has started; the honest question is whether your shop has gaps it would find.

Two-minute self-check

Seven yes/no questions. Runs entirely in your browser; no answers leave the page.

1. Do you employ 10 or more people, or exceed EUR 2 million in annual turnover or balance sheet total?

This is the microenterprise line. Under both thresholds, the EAA's service requirements likely do not apply to your shop.

2. Does your shop publish an accessibility statement?

A published statement is a legal requirement for in-scope services, with country-specific rules such as § 14 BFSG in Germany.

3. Can a customer complete an entire purchase, from finding a product to paying, using only a keyboard?

The purchase-critical flows are what enforcement has actually examined.

4. Have you, or anyone on your behalf, ever tested your checkout with a screen reader?

The Carrefour ruling turned on a checkout that was unusable for blind customers.

5. When a checkout or contact form field fails, does the page explain the error in text near the field?

Forms are one of the purchase-critical flows a manual review covers.

6. Are you relying on an accessibility overlay widget as your fix?

The FTC fined the largest overlay vendor for falsely claiming its widget makes sites compliant. Details below.

7. Has anyone manually reviewed your shop beyond running an automated checker like WAVE or Lighthouse?

Deque's study across thousands of audits found automated testing surfaces about 57% of issues by volume. The rest takes a human. Source.

The offer

EAA Gap Report + Fix Kit, EUR 149

  • Manual review of your shop's key flows: browse, product page, cart, checkout, reviewed against EN 301 549 criteria. Not just an automated scan; a person walks your actual purchase path.
  • Prioritized fix list with code-level guidance your developer or agency can execute, ordered by what matters most in the flows enforcement has focused on.
  • Accessibility statement template for your shop.
  • Evidence log: a dated record of what was reviewed and fixed, the kind of file you want to already have if a regulator or competitor ever asks.
  • Delivered within 2 business days.
  • Money-back guarantee.
Get the Gap Report (EUR 149)

After payment we email you within hours to confirm your shop URL and the few details the applicability check needs. The report arrives within 2 business days of payment.

What this is not