Pravano · Knowledge base · Accessibility / EAA

POUR under the EAA: the four principles of an accessible online shop in practice

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.

Since 28 June 2025, every online shop selling to consumers must meet the accessibility requirements under Act No. 424/2023 Coll. The Act transposes the European Directive (EU) 2019/882 and in Annex 1, Section III, point 3 expressly names four principles: perceivable, operable, understandable and robust – abbreviated as POUR. This is neither a recommendation nor “best practice”. It is a normative requirement, and failure to meet it can lead to a fine of up to CZK 10,000,000 and to your online shop being published on the ČOI's list of non-compliant services.

This article explains what each of the four principles specifically means for an online shop operator, where the limits of certainty lie and where we are still waiting for clarification, and what to do in the next thirty, sixty and ninety days.

General information, not individual legal advice. To assess the specific situation of your online shop, use the quick check.

What applies with certainty from 28 June 2025

Act No. 424/2023 Coll. is in effect and the obligations apply to every new consumer contract concluded after 28 June 2025 – that is, to every new purchase in your online shop (Article 31 of the Directive; Section 28(2) of the Act – its subsection (1) concerns products).

A complete exemption applies only to microenterprises: 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 (Czech currency is converted into euros at the Czech National Bank (ČNB) foreign exchange market rate for the balance sheet date). This threshold also includes 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) (Article 4(5) of the Directive; Section 2(3)(a) of the Act). If your online shop exceeds this limit, the obligations apply to you in full.

The four POUR principles are enshrined in Annex I, Section III, point (c) of the Directive and in Annex 1, Section III, point 3 of the Act. This is not a reference to another standard – they are part of the normative text of the Act itself.

What implementing acts will still specify (outlook)

Neither WCAG nor EN 301 549 is directly cited in the text of the Directive or of the Act. They are the de facto standard, and EN 301 549 is the likely basis of a future harmonised standard – but a presumption of conformity (Section 16 of the Act; Article 15 of the Directive) will arise only after the harmonised standard is published in the Official Journal of the EU. As at 30 September 2026, no reference to a harmonised standard for this directive had been published in the Official Journal of the EU; ETSI issued 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.

What this means in practice: you must be able to demonstrate that you meet POUR, but the Act does not prescribe a single permissible technical method. WCAG 2.2 AA is the most reliable and most widespread route – if you meet it, you have the strongest defensible position. It is not, however, the only lawful form of demonstrating compliance.

The four POUR principles in online shop practice

Perceivable

Content must be available to all the senses the user has at their disposal – or an alternative must exist.

What this specifically means for an online shop:

• Every product image must have a text alternative (alt text) that conveys what the image shows – not just “image” or the file name.
• Videos (for example product presentations or tutorials) need captions or a transcript.
• Information must not be conveyed by colour alone. Example: if you mark sold-out goods only in red without a text label “Sold out”, you do not meet this principle.
• The contrast of text against the background must be sufficient for it to be readable even for users with impaired vision.

Practical example: You sell clothing and on the product detail page you show the available sizes as coloured squares – green = in stock, grey = sold out. If this information is not also expressed in text, you do not meet the principle of perceivability.

Operable

The entire purchase process must be operable without a mouse – using only a keyboard or another assistive input device.

What this specifically means for an online shop:

• Adding to the basket, choosing a variant, logging in, filling in the address, confirming the order – all of this must be accessible via the keyboard.
• The user must always see where the focus is (highlighting of the active element). A hidden or invisible focus is a breach.
• Time limits (for example a countdown for reserving goods) must be extendable or possible to switch off, unless they are technically necessary.
• Moving content (banners, carousels) must be possible to stop.

The Act expressly requires accessible identification, security and payment functions (Annex I, Section IV, point (g) of the Directive; Annex 1, Section IV, point 7 of the Act). The payment gateway, the login form and the verification step must be operable without a mouse and compatible with assistive technologies.

Practical example: Your online shop uses its own CAPTCHA that requires dragging an object with the mouse. A user with a motor disability cannot complete it. This closes the entire purchase process to this group – a breach of the principle of operability and also of the specific requirement for an accessible payment process.

Understandable

Content and controls must be comprehensible – the language, the instructions and the error messages.

What this specifically means for an online shop:

• The language of the page must be programmatically determined (the HTML attribute lang) so that screen readers pronounce the text correctly.
• Error messages in forms must describe what is wrong and how to fix it – not just “Error” or a red border around the field.
• Navigation must be consistent across pages – if the basket is always at the top right, it must not disappear or move at the checkout.
• Unusual abbreviations or technical terms should be explained.

Practical example: After submission, your checkout form displays the message “The form contains errors.” without marking the specific fields. A user with a cognitive disability or a screen reader user does not know what to correct. This is a breach of the principle of understandability.

Robust

Content must be reliably interpretable by different browsers and assistive technologies – today and in the future.

What this specifically means for an online shop:

• HTML validity alone is no longer a separate criterion in WCAG 2.2 (criterion 4.1.1 Parsing was removed). Errors in the code structure – for example duplicate IDs – do matter, however, where because of them assistive technologies cannot determine the name, role or state of an element (criterion 4.1.2).
• Interactive elements (buttons, modal windows, drop-down menus) must have correct ARIA roles and states so that assistive technologies know what the element does and what state it is in.
• Custom components (for example a custom select or datepicker) must communicate their state – open/closed, selected/not selected.

Mobile applications of online shops are subject to the same requirements (Article 3, point 30 and Annex I, Section III, point (c) of the Directive; Section 3(1)(i) of the Act). The principle of robustness also applies to the mobile interface – compatibility with the operating system's assistive technologies (VoiceOver, TalkBack) is part of the requirement.

What POUR does not cover: content exclusions

The Act expressly exempts the following from the accessibility requirements (Section 2(3)(c) and (d) and Section 28(6) and (7) of the Act; Article 2(4) of the Directive):

• Maps and related online mapping services – exempt if the basic information enabling navigation is provided in an accessible digital form.
• Third-party content that does not belong to the service provider – and only if the provider neither funds it, nor develops it, nor can influence it (Section 2(3)(d) of the Act).
• Archived websites and applications – that is, those containing exclusively content that is not updated or edited after 28 June 2025 (Section 28(7) of the Act). This does not mean individual old pages within a live online shop.
• Pre-recorded time-based media published before 28 June 2025 (Section 28(6) of the Act).
• Office file formats (PDF, DOCX, XLSX) published before 28 June 2025 (Section 28(6) of the Act).

Beware: the exclusion for third-party content applies only to content that you genuinely cannot influence. If you pay for a widget and have contractual influence over its form, the exclusion does not apply.

Exemptions from POUR: when and how they can be used

There are two exemptions and both require a written assessment (Section 15(1) to (4) and Annex 4 of the Act; Article 14(1) to (3) and (5) of the Directive):

1. Fundamental alteration of the nature of the service – meeting the requirement would fundamentally change what the service is.
2. Disproportionate burden – the costs of compliance are out of proportion to the company's overall costs and turnover or to the benefit for users.

You must draw up the assessment and keep it for 5 years from the day you last provided the service (Section 15(3) of the Act), and for disproportionate burden also draw up a new assessment when the service changes, but no later than 5 years from the last assessment, and also at the request of the supervisory authority (Section 15(4) of the Act). The use of an exemption is notified to the ČOI before starting to provide the service concerned – not retroactively (Section 15(5) of the Act; Article 14(8) of the Directive).

An exemption is not a blanket escape route. The ČOI may request and review the assessment. If you do not have one or it is insufficient, the exemption does not apply and a fine may follow.

A hard disqualifier that is often forgotten: 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). A solemn declaration that the provider has not received such a benefit is therefore attached to the notification to the ČOI (Section 15(6) of the Act).

Information obligation: what to publish and where

Meeting POUR is not enough – you must also provide information about it (Section 14(1) to (4) of the Act; Article 13(2) and Annex V of the Directive):

• In your general terms and conditions or an equivalent document, describe how your service meets the accessibility requirements.
• This description must be published in accessible formats – that is, it must itself meet the POUR principles.
• At a user's request, you must provide the information also in audio form.
• Under the same conditions, also publish a general description of the service and the explanations necessary to understand how it works (Section 14(2) of the Act) – and keep everything published for the whole time the service is provided (Section 14(4) of the Act).

If you find non-compliance, you must take corrective action without undue delay and immediately inform the ČOI – stating the non-compliance, its causes and the measures taken (Section 13(1) and (2) of the Act; Article 13(3) and (4) of the Directive).

Decision guide: does this apply to you?

• If you run an online shop selling to consumers and you are not a microenterprise (fewer than 10 persons, turnover or balance sheet total up to €2 million) → POUR applies to you in full from 28 June 2025.
• If you run a purely B2B online shop without consumer contracts → the EAA does not apply to you (Article 2(2) of the Directive; Section 2(2) of the Act).
• If you have an online shop mobile application → the same requirements as for the website.
• If you are a microenterprise → you are exempt from the EAA requirements for services, but voluntarily meeting POUR expands your market.

30/60/90-day action plan

Within 30 days – map the current state:

1. Go through the entire purchase process with the keyboard (Tab, Enter, Shift+Tab) – without a mouse. Note where you get stuck.
2. Run an automated accessibility test (for example WAVE or Axe) on the homepage, a product page and the checkout. Note the critical errors.
3. Check whether you have alt texts for all product images.
4. Verify whether your payment and login forms work with a screen reader (NVDA is free).

Within 60 days – fix the critical barriers:

1. Fix missing alt texts and invisible focus – these are the most common and the easiest problems to fix.
2. Make sure that error messages in forms describe the specific problem and the solution.
3. Check the contrast of text against the background – especially for buttons and links.
4. Prepare a description of how you meet the accessibility requirements for your general terms and conditions.

Within 90 days – document and maintain:

1. Publish the accessibility description in your general terms and conditions in an accessible format.
2. Set up a process of ongoing checks – every major change to the website or application should go through an accessibility review before launch, because the service must meet the requirements even after a change (Section 13(1) of the Act).
3. If you plan to use the disproportionate burden exemption, draw up the assessment and notify it to the ČOI before launching the part of the service concerned.
4. Use the quick check for an indicative assessment of the overall state.

Common misconceptions

Misconception 1: “WCAG 2.2 AA is the law, I have to meet it exactly.”
WCAG 2.2 AA is not cited in the text of the Act or of the Directive. It is the de facto standard and the most reliable route to demonstrating compliance with POUR – but the Act does not require meeting WCAG as such. A presumption of conformity will arise only after a reference to the harmonised standard is published in the Official Journal of the EU; as at 30 September 2026, it had not been published. Until then, you must meet POUR and be able to demonstrate it – WCAG 2.2 AA is the strongest defensible position, but not the only permissible one.

Misconception 2: “I have an accessibility overlay plugin, so I am fine.”
Overlay plugins (widgets that add buttons for enlarging text or changing contrast) do not replace structural accessibility. If the underlying HTML code is not accessible, an overlay will not fix it – and what is assessed under Section 13(1) of the Act is the actual accessibility of the service, not the presence of a widget. An overlay can be a supplement, never a substitute.

Misconception 3: “The transitional period until 2030 applies to my online shop.”
The transitional period under Section 28(5) of the Act (Article 32(1), second subparagraph, of the Directive) applies to services provided on the basis of contracts concluded before 28 June 2025, and only until the contractual obligation ends, at the latest until 28 June 2030; a separate branch is the relief for inaccessible products already used before for a similar service (Section 28(4) of the Act). Every new purchase after 28 June 2025 is a new contract and the obligations apply immediately. The transitional period does not protect your online shop as a whole – it protects only specific ongoing obligations from the past.

Summary

The four POUR principles – perceivable, operable, understandable and robust – have been a statutory requirement since 28 June 2025 for every online shop selling to consumers that is not a microenterprise. They are enshrined directly in Annex I, Section III, point (c) of Directive (EU) 2019/882 and in Annex 1, Section III, point 3 of Act No. 424/2023 Coll. WCAG 2.2 AA is the most reliable route to meeting them, but a presumption of conformity will arise only after a reference to the harmonised standard is published in the Official Journal of the EU – as at 30 September 2026, it had not been published. The transitional period does not protect new purchases. The fine can reach CZK 10,000,000. Start with a keyboard review of the purchase process and an automated test – and document the results.

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.