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Does the EAA apply to your online shop? The answer under Czech Act No. 424/2023

Methodology: Marek Galetka, founder of Pravano. English translation of our Czech article, which a person approved before publication; every number, date and legal reference of the translation is checked automatically against the original.

Cross-checked as of 5 October 2026 · based on primary sources

Updated 5 October 2026. Based on Czech Act No. 424/2023 Coll. and Directive (EU) 2019/882 (EAA). An informative readiness check, not a legal service or an official audit. Original: česká verze.

Act No. 424/2023 Coll., by which the Czech Republic transposed the European Accessibility Act (Directive (EU) 2019/882, EAA for short), has affected most operators of online shops since 28 June 2025. Yet there is confusion: who exactly has obligations, who is exempt and what happens if you do nothing. This article gives you a clear answer – no padding, with specific article numbers and practical examples.

General information, not individual legal advice. To assess the situation of your specific company, we recommend the quick check.

What the EAA is and why it applies to online shops

The EAA is not just a law for large corporations or government websites. Act No. 424/2023 Coll. defines an “e-commerce service” as a service provided at a distance through websites or mobile devices, by electronic means, at the individual request of a consumer, with a view to concluding a consumer contract. This definition fits a classic online shop exactly – your Shoptet, WooCommerce or custom solution.

Legal basis: Article 3, point 30 and Article 2(2)(f) of Directive 2019/882; Section 3(1)(i) and Section 2(2)(d) of Act No. 424/2023 Coll.

The aim of the act is to ensure that people with visual, hearing, motor or cognitive disabilities can use your online shop fully – from browsing the catalogue through logging in to completing the payment.

What applies with certainty from 28 June 2025

The date of 28 June 2025 is fixed and cannot be changed (Czech article). From that day, every online shop that does not fall under an exemption must meet the requirements of Act No. 424/2023 Coll. for every new consumer contract.

A key detail that many operators overlook: every new purchase is a new contract. It is not enough to say “our online shop has been running since 2019, so we have a transitional period”. The transitional period under Section 28(5) of the act applies to obligations from contracts concluded before 28 June 2025 – for example a subscription or recurring performance agreed before that date. Such obligations may be performed in unchanged form until 28 June 2030 at the latest. There is also a separate relief for products: under Section 28(4) of the act (Article 32(1), first subparagraph, of the directive), until 28 June 2030 a service provider may continue to provide services using inaccessible products that it lawfully used to provide similar services before and that were placed on the market no later than 28 June 2025. Neither of these branches, however, covers the website or the mobile application. But every new purchase after 28 June 2025 is subject to the obligations immediately.

Example: You run an electronics online shop. A customer who bought a laptop from you in April 2025 is not relevant from the EAA point of view. A customer who orders headphones in July 2025 does – and your website must be accessible throughout that purchase.

Decision guide: does the EAA apply to you?

Before reading the rest of the article, go through this sequence of questions. Answer each one honestly.

Question 1: Do you sell to consumers (B2C)?

• If you sell exclusively to other businesses (a purely B2B online shop) and consumers cannot buy from you, the EAA does not apply to your e-commerce service. The act applies only to services provided to consumers (Section 2(2) of the act; Article 2(2) of the directive).
• If you also sell to consumers – even if only to some of your customers – go on to question 2.

Question 2: Does your website have an e-commerce function (basket, order form, payment)?

• A purely presentational website without the possibility of buying is not subject to the EAA – it is not an e-commerce service, because the element “with a view to concluding a consumer contract” is missing (Section 3(1)(i) of the act; Article 3, point 30 of the directive). This is an a contrario interpretation: as soon as the website allows a consumer to place an order or make a booking, it falls within the scope.
• If the website allows a consumer contract to be concluded, go on to question 3.

Question 3: Are you a microenterprise? (Czech article)

• A microenterprise is fully exempt from the EAA obligations for services (Section 2(3)(a) of the act; Article 4(5) of the directive).
• The headcount condition is cumulative, the financial indicators are alternatives: fewer than 10 persons and at the same time an annual turnover or an annual balance sheet total not exceeding €2 million. So it is enough to stay below €2 million in one of the two financial indicators – exceeding the other one does not in itself cancel the exemption.
• The definition refers to Annex I to Regulation No 651/2014. Beware: the headcount and the financial indicators also include the data of partner enterprises with a holding of 25% or more (proportionally to the size of the holding) and of linked enterprises (in full). If your online shop is a subsidiary or has an investor with a holding of 25% or more, you may not be a microenterprise even if you yourself employ only 5 people.
• To determine whether you are a microenterprise, amounts in Czech currency are converted into euros at the foreign exchange market rate announced by the Czech National Bank (ČNB) for the balance sheet date (Section 27(1) of the act).

Result of the decision tree:

Mobile applications: a separate chapter

If you run a mobile application for purchases, the same obligations apply to it as to the website – there is no special relief for applications.

Act No. 424/2023 Coll. expressly includes services provided on mobile devices in the definition of an e-commerce service (Section 3(1)(i) of the act; Article 3, point 30 of the directive). The accessibility requirements for the web interface and applications are part of Annex I, Section III of the directive.

Example: You have a fashion online shop and alongside the website you run an iOS and an Android application. Both applications must meet the accessibility requirements just like the website – logging in, choosing products, the basket and payment must all be accessible.

What exactly an accessible online shop must meet

This section summarises the obligations for those who fall under the act. A detailed technical analysis goes beyond the scope of this article – here are the key areas.

Technical requirements for the website and the application

The act requires the web interface and mobile applications to be perceivable, operable, understandable and robust – the so-called POUR principle (Czech article) (Annex 1, Section III, point 3 of the act; Annex I, Section III, point (c) of the directive). These are the four basic pillars of accessibility.

E-commerce specifics

Beyond the general requirements, the act lays down specific obligations for online shops (Annex 1, Section IV, point 7 of the act):

• Accessible identification, security and payment functions – a customer with a visual impairment must be able to log in, pass authentication and pay.
• Accessible methods of electronic identification, electronic signatures and payments.
• Information on the accessibility of the products and services sold, where it is provided by the responsible manufacturer, authorised representative, importer, distributor or service provider.

Information obligation

In your general terms and conditions or an equivalent document you must publish how your service meets the accessibility requirements, including a description of those requirements. You must also publish a general description of the service and the explanations necessary to understand how it works. The information must be on the website in accessible formats, at the customer's request also in audio form, and published for the whole time the service is provided (Section 14(1) to (4) of the act; Article 13(2) and Annex V of the directive).

What you risk for non-compliance

The supervisory authority for online shops is the Czech Trade Inspection Authority (ČOI). The maximum fine for failing to ensure the accessibility of a service, failing to take corrective action or failing to comply with a ČOI request reaches CZK 10,000,000 (Section 25(7) and (8) of the act).

In addition to the fine, the ČOI publishes a list of non-compliant services (Section 24(2) of the act) – a reputational risk that can deter customers and business partners.

When non-compliance is found, you must take corrective action without undue delay and immediately inform the ČOI of the non-compliance, its causes and the measures taken (Section 13(1) and (2) of the act).

Exemptions from the requirements: when you do not have to meet everything

Certain types of content are excluded from the requirements without any assessment – maps for which the basic information for navigation is provided in an accessible form, third-party content that you neither fund nor develop nor can influence, pre-recorded media and office file formats published before 28 June 2025, and websites and applications whose content has not been updated or edited since 28 June 2025 (Section 2(3)(c) and (d) and Section 28(6) and (7) of the act). In addition, the act allows two exemptions from specific requirements – but neither is automatic.

Exemption 1: Fundamental alteration of the nature of the service. If meeting a specific requirement would fundamentally alter the nature of your service, you do not have to meet it. You must, however, document this by an assessment.

Exemption 2: Disproportionate burden. If the costs of meeting the requirement would be disproportionate in relation to the overall costs and turnover, or in relation to the benefit for users with disabilities. The criteria are laid down in Annex 4 to the act (Annex VI to the directive).

Both exemptions require (Section 15(1) to (6) of the act; what applies only to disproportionate burden is stated expressly):

1. Drawing up a documented written assessment (Section 15(2) of the act).
2. Keeping the assessment and the documents used to draw it up for 5 years from the day you last provided the service (Section 15(3) of the act), and submitting them to the supervisory authority on request.
3. For disproportionate burden, drawing up a new assessment when the service changes, but no later than 5 years from the day the last assessment was drawn up – and also at the request of the supervisory authority if it has reasonable doubt about the disproportionate burden (Section 15(4) of the act).
4. Notifying the ČOI of the use of the exemption before starting to provide the service concerned – stating the service concerned, the reason, the requirements not met and the date of the assessment (Section 15(5) of the act; Article 14(8) of the directive) – and, for disproportionate burden, attaching a solemn declaration that you have not received a subsidy, donation or other similar benefit for ensuring accessibility (Section 15(6) of the act).

Beware of a hard disqualifier: anyone who has received a subsidy, donation or other similar benefit for ensuring compliance with the accessibility requirements may not invoke disproportionate burden at all (Section 15(2), second sentence, of the act; Article 14(6) of the directive). This restriction does not apply to the “fundamental alteration of the nature of the service” exemption.

An exemption is not blanket consent to inaccessibility. It is a precisely defined tool for specific requirements that are demonstrably disproportionate – not for the whole online shop.

What implementing acts will still specify (outlook)

As at 30 September 2026, no reference to a harmonised standard for this directive had been published in the Official Journal of the EU, so no standard currently gives rise to a presumption of conformity. The de facto standard is EN 301 549 (based on WCAG), but neither the act nor the directive names WCAG directly. A presumption of conformity under Article 15 of the directive (Section 16 of the act) will arise only once a harmonised standard is cited in the Official Journal. ETSI published a revision of EN 301 549 built on WCAG 2.2 in September 2026 (V4.1.1), but it has not yet been cited in the Official Journal of the EU – check the status at the source before making a decision.

Practical impact: meeting WCAG 2.2 AA is the most sensible approach today and is likely to form the basis of the harmonised standard – but the formal “presumption of conformity” does not apply yet. Follow the Official Journal of the EU or rely on updated information from the ČOI.

30/60/90-day action plan

If you have read this far and know that the EAA applies to you, here is a specific procedure.

First 30 days – find out where you stand

1. Verify that you really are not a microenterprise (count your employees and check your turnover and balance sheet total in EUR – always including the proportional share of the data of partner enterprises with a holding of 25% or more and the full data of linked enterprises).
2. Map all channels: website, mobile applications, any B2B portals with B2C access.
3. Carry out an indicative accessibility check – go through the key purchase steps (logging in, basket, payment) with an automated tool (e.g. WAVE or Axe) and manually with a screen reader.
4. Use the quick check for an indicative assessment of your situation.

Days 31–60 – prioritise and plan

1. Draw up a list of specific shortcomings ranked by severity (blocking barriers in the payment process take priority).
2. Decide whether you will deal with it internally or with an external accessibility specialist.
3. Check whether your terms and conditions contain the mandatory accessibility information (Section 14 of the act).
4. If you are considering the disproportionate burden exemption, start preparing the assessment – and remember that you must notify the ČOI of it before providing the service concerned.

Days 61–90 – implement and document

1. Fix the critical barriers in identification, logging in and the payment process.
2. Update your terms and conditions with an accessibility statement.
3. Set up an internal process for maintaining compliance on an ongoing basis with every change to the website or application (Section 13(1) of the act).
4. Archive the assessment and documentation – in case of a ČOI inspection.

Common misconceptions

Misconception 1: “We have a transitional period until 2030, so we do not need to do anything.”
The transitional period until 28 June 2030 has two branches: performance of obligations from contracts concluded before 28 June 2025 (typically a subscription or recurring performance) and the use of inaccessible products that you already used before for a similar service (Section 28(5) and (4) of the act). Neither of them covers the website or the application for new orders. Every new purchase after that date is subject to the obligations immediately. If your online shop accepts new orders, the transitional period will not protect you.

Misconception 2: “We are a small company, so the EAA does not apply to us.”
The microenterprise exemption has precise conditions: fewer than 10 persons and at the same time no more than €2 million in at least one of the indicators – annual turnover or annual balance sheet total. A company with 8 employees, a turnover of €3 million and a balance sheet total of €5 million does not have the exemption; a company with the same turnover but a balance sheet total of €1.5 million is still a microenterprise. In addition, the data of partner enterprises with a holding of 25% or more (proportionally to the size of the holding) and of linked enterprises (in full) are added – an investor or a parent company can push you over the threshold without you realising it.

Misconception 3: “Our website is accessible because we meet WCAG 2.1 AA.”
WCAG is not named directly in the act or in the directive. It is the de facto standard and the likely basis of a future harmonised standard, but the formal presumption of conformity does not apply yet. Meeting WCAG 2.2 AA is a sensible goal, but it is not enough just to tick “done” – the act also requires compliance with the information obligation, accessibility of the payment process and ongoing maintenance of compliance.

Summary

The EAA in the form of Act No. 424/2023 Coll. applies to every B2C online shop that is not a microenterprise – from 28 June 2025 for every new purchase. The microenterprise exemption has precise conditions (fewer than 10 persons and turnover or balance sheet total up to €2 million, including the proportional share of the data of partner enterprises with a holding of 25% or more and the full data of linked enterprises). Purely B2B online shops and presentational websites without an e-commerce function do not fall under the act. Mobile applications are expressly included. Non-compliance can lead to a fine of up to CZK 10,000,000 from the ČOI. The transitional period until 2030 does not protect new purchases – it protects only obligations from contracts concluded before June 2025 and the use of older inaccessible products.

This article is a general explanation, not individual legal advice. A specific overview for your company (Pravano Kompas) comes with the free check – in writing, within 2 working days.