Pravano · Knowledge base · Accessibility / EAA

The EAA has applied since June 2025 – the “we have until 2030” misconception

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 7 October 2026 · based on primary sources

Updated 7 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.

If you run an online shop and someone told you that you have until 2030 to deal with accessibility, you were given wrong information. Act No. 424/2023 Coll., which implements the European Accessibility Act (EAA, CELEX 32019L0882), took effect on 28 June 2025 (Section 29 of the Act), and the obligations for new purchases have applied since that day. A transitional period until 2030 does exist, but it covers a very narrow group of situations – and the ordinary operation of an online shop is not one of them.

This article explains precisely where the transitional period applies and where it does not, what you must meet from day one, and how to avoid a fine of up to CZK 10,000,000.

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

What applies with certainty from 28 June 2025

Every new purchase on your online shop after 28 June 2025 must meet the accessibility requirements. The transitional period until 2030 (Article 32 of the Directive) concerns only products and contracts from the period before 28 June 2025, not new purchases.

Act No. 424/2023 Coll. (Section 28(1) and (2)) and Article 31 of the Directive are unambiguous on this: the obligations apply to services provided after that date. Under the Act, an online shop is an “e-commerce service” – a service provided at a distance through websites or a mobile application, by electronic means, at the individual request of a consumer, with a view to concluding a consumer contract (Article 3, point 30 and Article 2(2)(f) of the Directive; Section 3(1)(i) of the Act).

The key mechanism: every new purchase is a new contract. A customer who orders goods from you on 1 July 2025 concludes a contract after the Act's effective date. The transitional period does not apply to this transaction.

What exactly your online shop must meet

The Act lays down three main groups of requirements:

1. Technical accessibility of the website and the application (Annex I, Section III, point (c) of the Directive; Annex 1, Section III, point 3 of the Act): the content must be perceivable, operable, understandable and robust – the so-called POUR principle. In practice this means, for example, text alternatives for images, keyboard operability, sufficient text contrast and predictable behaviour of the interface.

2. E-commerce specifics (Annex I, Section IV, point (g) of the Directive; Annex 1, Section IV, point 7 of the Act): the identification, security and payment functions must be accessible – i.e. login forms, the basket and the payment gateway. If you sell products for which information on their accessibility is provided by the responsible manufacturer, authorised representative, importer, distributor or service provider, you must state it on the online shop.

3. Information obligation (Article 13(2) and Annex V of the Directive; Section 14(1) to (4) of the Act): 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 commonly accessible formats, available in audio form on request, and published for the whole time the service is provided.

A practical example: you run a clothing online shop. On 15 July 2025 a customer chooses goods, adds them to the basket and pays by card. This entire flow – product page, basket, payment form – must meet the accessibility requirements. If a third-party payment gateway is not accessible and you cannot influence it, you must deal with it contractually or by choosing a different provider.

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. Without such a reference, there is no standard whose fulfilment would automatically give rise to a presumption of conformity.

In Section 16 (Article 15 of the Directive), the Act provides for harmonised standards – the de facto standard is EN 301 549, which is based on WCAG. Meeting this standard will give rise to a presumption of conformity, but only once it 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. Until then, the POUR principle from the Act is binding, but the specific technical metric for “automatic compliance” has not yet been formally settled.

What this means for you: do not tell yourself “I will wait for the standard”. The statutory POUR requirement has applied since 28 June 2025, regardless of whether or not a harmonised standard is cited. The standard will make compliance easier for you and help you demonstrate it – but the obligation already exists.

The transitional period until 2030: what exactly the law says

The transitional period has three separate branches: older contracts, older products and self-service terminals. None of them postpones the accessibility of the online shop itself.

First branch – older contracts (Article 32(1), second subparagraph, of the Directive; Section 28(5) of Act No. 424/2023 Coll.): services provided on the basis of a contract concluded before 28 June 2025 may continue to be provided in unchanged form until the obligation under the contract expires, but no later than 28 June 2030.

Second branch – older products, which is often forgotten (Article 32(1), first subparagraph, of the Directive; Section 28(4) of the Act): until 28 June 2030 at the latest, a service provider may provide services using products that do not meet the accessibility requirements – but only if it lawfully used them to provide similar services before the Act took effect and at the same time those products were placed on the market no later than 28 June 2025. This is a relief for equipment, not for the website or the mobile application.

Third branch – self-service terminals (Section 28(3) of the Act): inaccessible self-service payment terminals and self-service terminals lawfully used before the Act took effect may be used to provide similar services for no longer than 20 years from when they were first put into operation. For an online shop without a physical store, this branch has no practical significance.

When the transitional period really helps

The transitional period makes sense, for example, in these situations:

• A long-term service contract or subscription concluded before 28 June 2025 that continues unchanged.
• A contract for regular deliveries concluded before that date where the terms do not change.
• Inaccessible equipment (for example a terminal, a reader or a kiosk) that you demonstrably already used to provide a similar service before 28 June 2025 and that was placed on the market no later than that day (Section 28(4) of the Act).

When the transitional period does not help – and this is the key point

• Every new purchase on the online shop after 28 June 2025 is a new contract. The transitional period does not apply to it.
• If you change a contract concluded before that date (price, terms, scope), the transitional period ceases to apply.
• Your online shop as a platform – website, application, payment flow – must be accessible for all new transactions from day one.

Example: in January 2025 a consumer took out a two-year subscription with regular deliveries from you. You may perform this contract in unchanged form until it expires (i.e. until January 2027), but no later than 28 June 2030. Every new purchase – even by the same customer – must, however, go through an interface that has met the EAA since 28 June 2025. Contracts with traders, for example on the use of a SaaS e-commerce platform, do not fall under the EAA at all, because they are not services provided to consumers.

Who is exempt: the microenterprise exemption

If you meet the definition of a microenterprise, you are, as a service provider, fully exempt from the EAA.

Conditions (Article 4(5) and Article 3, point 23 of the Directive; Section 2(3)(a) and Section 3(1)(p) of the Act):

• fewer than 10 persons – not necessarily just employees; they are counted under the rules of Annex I to Commission Regulation (EU) No 651/2014, to which the Act refers, and at the same time
• an annual turnover or an annual balance sheet total not exceeding €2 million.

Beware of two pitfalls:

1. Aggregating enterprises: the headcount and the financial indicators include the data of partner enterprises with a holding of 25% or more, proportionally to the size of the holding, and the data of linked enterprises in full (Annex I, Article 6(2) of Regulation 651/2014). If you are part of a group, you are not necessarily a microenterprise even if your company on its own falls below the thresholds.
2. Exchange-rate conversion: the €2 million limit is converted at the Czech National Bank (ČNB) exchange rate (Section 27(1) of the Act).

Decision guide:

• If, after including partner and linked enterprises, you employ fewer than 10 persons and at least one of the financial indicators – annual turnover or annual balance sheet total – does not exceed €2 million → the microenterprise exemption applies to you and the EAA does not apply to your services.
• If you employ 10 or more persons, or if both of your financial indicators exceed €2 million → the exemption does not apply and the obligations have applied since 28 June 2025.

Beware of a common simplification: exceeding one of the financial thresholds does not in itself cancel the exemption. Under Article 3, point 23 of the Directive, a microenterprise is “an enterprise which employs fewer than 10 persons and which has an annual turnover not exceeding EUR 2 million or an annual balance sheet total not exceeding EUR 2 million” (official English wording). A company with a turnover of €3 million and a balance sheet total of €1.5 million is therefore still a microenterprise. Only the headcount condition is cumulative.

Exemptions from the requirements: disproportionate burden and fundamental alteration

Even where the EAA applies, there are two exemptions from specific requirements – but both are conditional and administratively demanding.

The Act (Article 14(1) to (3) and (5) and Annex VI of the Directive; Section 15(1) to (4) and Annex 4 of the Act) allows an exemption if meeting a requirement:

• would result in a fundamental alteration of the nature of your service, or
• would impose a disproportionate burden (criteria: the ratio of the costs of the adjustment to overall costs and turnover, and the ratio of the costs to the benefit for users).

What you must do before invoking the exemption:

1. Draw up a documented assessment (the Act expressly says “shall draw up an assessment”).
2. Keep 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 submit them to the supervisory authority on request (Article 14(3) of the Directive).
3. For disproportionate burden, draw 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. Notify the ČOI of the exemption before starting to provide the service concerned (Article 14(8) of the Directive; Section 15(5) of the Act) – stating the service concerned, the reason, the requirements not met and the date of the assessment, 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).

One additional hard obstacle: 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.

The exemption is neither automatic nor permanent. If you invoke it without an assessment or without notifying the ČOI, you are in breach of the Act just as if you had no exemption.

Supervision and penalties: the ČOI and fines of up to CZK 10 million

Online shops are supervised by the Czech Trade Inspection Authority (ČOI) (Section 19(2) of the Act); the maximum fine is CZK 10,000,000.

Specific penalties (Section 25(7)(a), (b) and (l) and (8)(a) and Section 24(2) of the Act):

• A fine of up to CZK 10,000,000 for failing to ensure the accessibility of a service, failing to take corrective action or failing to comply with a request from the ČOI.
• The ČOI publishes a list of non-compliant services – a public register that also represents a reputational risk beyond the financial penalty.

When non-compliance is found (Article 13(3) and (4) of the Directive; Section 13(1) and (2) of the Act), you must take corrective action without undue delay and immediately inform the ČOI of the non-compliance, its causes and the measures taken. You must maintain compliance on an ongoing basis, including when the website or application changes.

What the EAA does not apply to

The exclusions are of two kinds and follow from different provisions – do not confuse them.

A) Outside the scope of the Act (Article 2(2) in conjunction with Article 3, point 30 of the Directive; Section 2(2)(d) of the Act) – the Act applies only to services provided to consumers:

• A purely B2B online shop (you sell exclusively to businesses, not to consumers).
• A purely presentational website without an e-commerce function. As soon as the website allows a consumer to place an order or make a booking, it falls within the scope.

B) Excluded content on a website that otherwise falls under the Act (Article 2(4) of the Directive; Section 2(3)(c) and (d) and Section 28(6) and (7) of the Act):

• Archived content – websites and applications containing exclusively content that is not updated or edited after 28 June 2025.
• Pre-recorded time-based media and office file formats published before 28 June 2025.
• Maps and related online mapping services, provided that the essential information for navigation is provided in an accessible digital form.
• Third-party content that does not belong to the service provider – unless the provider funds it, develops it or can influence it.

Beware: the exclusion for archived content concerns content that you do not update. As soon as you edit the content or add new content, the exclusion ceases to apply.

30/60/90-day action plan

First 30 days – find out where you stand

1. Verify whether you meet the definition of a microenterprise (fewer than 10 persons and no more than €2 million in at least one of the indicators – annual turnover or balance sheet total – after including partner and linked enterprises). If you do, the EAA does not apply to your services – but document it.
2. Carry out an indicative accessibility check of the website and the mobile application – focus on the POUR principles: text alternatives, keyboard operability, contrast, the login form, the basket and the payment flow.
3. Check your general terms and conditions: do they contain information on how your service meets the accessibility requirements? If not, add it.
4. Map the contracts concluded before 28 June 2025 that are still running – they can benefit from the transitional period, but only in unchanged form.

Days 31–60 – remove critical shortcomings

1. Fix the most serious accessibility barriers in the payment flow and in logging in – these functions are expressly named in the Act (Annex 1, Section IV, point 7 of the Act; Annex I, Section IV, point (g) of the Directive).
2. If you are considering invoking the disproportionate burden exemption, commission the assessment and prepare the notification for the ČOI.
3. Verify whether your payment gateway and other integrated third-party services meet the accessibility requirements – if not, negotiate with the supplier or look for an alternative.

Days 61–90 – systemic safeguards

1. 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; Article 13(3) of the Directive).
2. Document the measures taken – in the event of a ČOI inspection, you will need to show what you did and when.
3. Plan a repeat accessibility check – at least with every major update of the website.

Common misconceptions

Misconception 1: “The transitional period until 2030 applies to the whole online shop.”
The transitional period protects exclusively contracts concluded before 28 June 2025 in unchanged form. Every new purchase after that date is a new contract, and the transitional period does not apply to it. Your online shop as a platform must be accessible from day one.

Misconception 2: “I will wait until a binding technical standard is published and deal with it then.”
The statutory POUR requirement (perceivable, operable, understandable, robust) has applied since 28 June 2025, regardless of the status of the harmonised standard. The standard will make compliance easier for you and help you demonstrate it, but it does not postpone the obligation. Anyone waiting for the standard is already in breach of the Act now.

Misconception 3: “I am a small company, so it does not concern me.”
The microenterprise exemption is precisely defined: fewer than 10 persons and at the same time no more than €2 million in at least one of the indicators (annual turnover or balance sheet total), with partner and linked enterprises added. A “small company” in the everyday sense of the word need not be a microenterprise under the Act. If you have, for example, 15 employees, the exemption does not apply to you. Mere membership of a group does not cancel it, however – what matters are the aggregate values after including partner and linked enterprises.

Summary

The EAA has applied to online shops since 28 June 2025. The transitional period until 2030 covers contracts concluded before that date in unchanged form and, separately, also inaccessible products that you already used for a similar service before – but every new purchase is a new contract and the transitional period does not protect it. The obligations include the technical accessibility of the website and the application (POUR), the accessibility of the payment flow and the information obligation in the general terms and conditions. The microenterprise exemption applies to companies with fewer than 10 persons for which, after including partner and linked enterprises, at least one of the indicators – annual turnover or balance sheet total – does not exceed €2 million. Supervision is carried out by the ČOI, with fines of up to CZK 10,000,000. Waiting for a binding technical standard or relying on the transitional period is a concrete legal risk – not caution.

For an indicative assessment of your situation, use the quick check.

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.