WCAG and E-commerce: Preparing Your Online Store for Digital Accessibility Requirements

June 28, 2025, is the day the Polish Accessibility Act comes into force. This act aims to implement the European Accessibility Act into Polish law. Unlike these, WCAG is not a legal act but a set of guidelines. So why is it so important? Why does e-commerce need to adapt to these requirements? And do these requirements apply to every online store? We explain below.

PAA, EEA, WCAG. Different documents, one common denominator – accessibility

Imagine you want to buy a t-shirt. You go to an online store, and the product descriptions are invisible, buttons are unlabeled, images lack alternative descriptions, and navigation only works with a mouse. If you are a blind person or rely solely on a keyboard and "bounce" off several pages full of such barriers, you might feel excluded. And yet, we are talking about a problem that affects a huge group – according to GUS data, in 2023, over 4 million people with disabilities lived in Poland. For many of them, digital accessibility is not a comfort but a condition for participation in social and economic life, including daily shopping.

The European Accessibility Act (EEA), a European Union directive that needed national implementation to be binding in Poland – hence the Polish Accessibility Act (PAA) – is intended to counteract this. Formally, the PAA is the Act of April 26, 2024, on ensuring compliance with accessibility requirements for certain products and services by economic entities (Journal of Laws of 2024, item 731). It will come into force on June 28, 2025, imposing the obligation of ensuring digital accessibility on, among others, online stores.

You won't find specific technical solutions in the PAA. However, it mentions perceivability, operability, understandability, and robustness. These are references to another document – WCAG, or Web Content Accessibility Guidelines – a set of international guidelines. It is WCAG 2.1 at the AA level that contains a set of standards by which the digital accessibility of websites and mobile applications is to be assessed.

Digital accessibility requirements. Who must meet them?

The PAA states that "the provisions of the act do not apply to services offered or provided by micro-entrepreneurs." Therefore, companies employing fewer than 10 people and with an annual turnover below 2 million euros do not have to implement it. They don't have to, but of course, they can and should do so to improve the experience of all consumers and reach more customers.

The situation is different for companies that are not micro-enterprises and that offer services listed in the PAA. These include:

• audiovisual media services (e.g., streaming platforms),
• electronic communication services (telephone, internet, including emergency communication),
• digital information services in passenger transport (e.g., air, bus, rail, and water – this applies, among others, to electronic ticket sales systems and providing information related to these services),
• retail banking services,
• e-book distribution services,
• e-commerce.

The act emphasizes that ensuring compliance with accessibility requirements is the obligation of service providers. If a service provider (e.g., an online store owner) fails to fulfill this obligation, they are subject to a financial penalty. This penalty will be determined based on the average salary and the entrepreneur's turnover but cannot exceed 10 times the average salary or 10% of the company's turnover for the previous year.

Main principles of WCAG

The foundation of digital accessibility consists of four WCAG principles, known by the acronym POUR:

• Perceivable – present information and user interface components in a way perceivable to their senses,
• Operable – ensure all functionalities are accessible via keyboard,
• Understandable – ensure information and the operation of the interface are understandable,
• Robust – create content robustly so it can be effectively interpreted by various user agents, including assistive technologies.

How to prepare an online store for digital accessibility requirements?

The WCAG document precisely details the criteria a website must meet to be considered digitally accessible – a total of several dozen points divided into three levels. For e-commerce, the most important is level AA, indicated in the PAA as mandatory. It covers both visual aspects (e.g., appropriate text contrast against the background) and functional ones (e.g., keyboard navigation, alternative descriptions for images, and error messages in forms).

It is best to commission a website audit in the context of these guidelines to specialists. Companies dealing with this usually also develop implementation plans for changes. These usually require the involvement of the development team, UX/UI designers, and people responsible for content (copywriters, content managers, SEO specialists).

Store adjustments may include:

• rebuilding navigation so it can be operated solely by keyboard,
• changing the graphic design to be more contrasting (brown letters on a black background absolutely do not meet accessibility criteria),
• adding alternative descriptions for product images, as well as captions for audio content and audio descriptions for video recordings,
• content must be readable and functional in both portrait and landscape orientation,
• texts should be divided into headings and labels describing their topic or purpose,
• for websites that create legal obligations or where the user conducts financial transactions, it is necessary to ensure the ability to prevent errors, i.e., allow data input reversibility, give the user the ability to make corrections, and introduce a mechanism for checking, confirming, and correcting information before final submission.

WCAG and e-commerce. Summary

Increasing accessibility for people with disabilities will become an obligation for many companies operating in Poland, including online store owners, starting June 28, 2025. Although WCAG itself is not a legal act, its principles – perceivability, operability, understandability, and robustness – have been indicated in the Polish Accessibility Act as a point of reference for assessing website compliance with regulations.

Control institutions (PFRON or the market surveillance authority) can check whether entrepreneurs have assessed the compliance of a product or service with accessibility requirements. Failure to fulfill this obligation may result in financial penalties.