The e-commerce industry in Poland and across the European Union has become an integral part of everyday life and modern business. With the rapid growth of online trade and digital technologies, ensuring digital accessibility of services and products for people with disabilities is becoming essential.
On 26 June 2025, the Polish law on the accessibility of certain products and services for persons with disabilities will come into effect. The Act transposes Directive (EU) 2019/882, commonly known as the European Accessibility Act (EAA). Under this regulation, all online stores operating in the EU market will be required to meet specific technical and functional accessibility standards for their websites and mobile applications.
Who is affected by the EAA?
The new rules apply to all e-commerce platforms and online stores offering products or services to consumers within the EU. The only general exception concerns micro-enterprises, defined as businesses with fewer than 10 employees and an annual turnover below EUR 2 million.
What are the new obligations under the EAA?
The European Accessibility Act introduces a requirement for full digital accessibility of online stores, which includes:
- compliance with the international WCAG (Web Content Accessibility Guidelines),
- the ability for people with disabilities to complete a purchase independently (without third-party assistance),
- use of alternative text descriptions (alt text) for product images and graphics,
- support for keyboard navigation throughout the site,
- adapting mobile applications for compatibility with screen readers,
- offering multiple accessible communication methods (e.g., live chat, voice assistants, accessible forms),
- making all user-facing documents – including manuals, terms & conditions, and warranty cards – accessible,
- providing digital accessibility training for staff managing e-commerce platforms,
- conducting regular accessibility audits and promptly implementing necessary updates.
What is WCAG?
WCAG (Web Content Accessibility Guidelines) is an internationally recognized set of standards for designing web content accessible to all users, regardless of their disability.
WCAG is based on four principles:
Perceivable – content must be presented in a way that users can perceive, whether by sight or hearing,
Operable – interface elements must be usable via keyboard or assistive technologies,
Understandable – content and navigation must be easy to comprehend,
Robust – content must be compatible with current and future assistive technologies.
What are the penalties for non-compliance?
Compliance with EAA requirements will be subject to regulatory oversight. Failure to meet accessibility obligations can result in fines imposed by: the State Fund for the Rehabilitation of Persons with Disabilities (PFRON), or the President of the Office of Competition and Consumer Protection (UOKiK).
Fines may reach: up to 10 times the national average salary, or up to 10% of the company’s annual turnover, depending on which amount is lower.
Why implement the EAA now?
Failure to implement the European Accessibility Act not only poses a legal risk, but also creates a real obstacle to business growth. Non-compliance may result in exclusion from public tenders or partnerships with larger corporate clients.
On the other hand, a well-prepared EAA and WCAG-compliant implementation can:
- increase your market reach (including customers with disabilities),
- strengthen your brand image as a socially responsible business,
- minimize legal and financial risks,
- improve SEO rankings and mobile accessibility.
How can SKLAW help?
The SKLAW Law Firm provides comprehensive support for online businesses and digital service providers aiming to comply with the EAA:
we conduct website and mobile app accessibility audits,
assist with WCAG implementation,
draft and update terms & conditions, privacy policies, and customer documentation,
offer team training on digital accessibility requirements,
advise on handling consumer accessibility requests.