European Accessibility Act (EAA) for WooCommerce: How to Audit Your Store
The European Accessibility Act (EAA), Directive (EU) 2019/882, has applied since 28 June 2025 to e-commerce services sold to consumers in the European Union. Whether it applies to you is a separate question worth settling first — Article 4(5) exempts microenterprises providing services altogether. If it does apply, accessibility stops being only a good practice.
In this guide, we'll explain how to audit your WooCommerce store against WCAG 2.2 standards and how to generate the required EAA documentation.
Why E-Commerce Needs Accessibility Testing
Under the EAA, e-commerce services must meet specific accessibility requirements outlined in Annex I of the Directive. To prove compliance, businesses must also provide detailed information on how the service meets these requirements, as specified in Annex V.
Most store owners attempt to use automated scanning APIs to find accessibility issues. However, API scanners often fail on modern WordPress sites because they scan the raw HTML your server sends, not the final page rendered by the browser. They miss contrast issues caused by translucent overlays or inherited CSS from parent elements.
The Solution: Rendered Page Scans in wp-admin
The Accessibility Audit plugin solves this by loading your published WooCommerce product pages and checkout flows into a frame inside wp-admin.
It checks the rendered result—the exact page your customer sees.
- No scanning API: Your page content is never uploaded anywhere and there is no account to create. The plugin does contact WPBay to validate a purchase code and to check for updates, which carries licence and site metadata only — never page content, scan results, or anything about your visitors.
- Accurate Contrast: Colour contrast is measured on resolved styles.
- Grouped Fixes: Findings are grouped by rule. If your theme's primary button colour fails contrast on 12 different product pages, it's flagged as one single fix, saving you hours of redundant work.
Generating the EAA Annex V Document
Fixing the errors is only half the battle. The European Accessibility Act requires documentation.
With a licensed version of the Accessibility Audit plugin, it automatically builds the information required by Annex V of Directive (EU) 2019/882. This includes:
- A description of your service in accessible formats.
- An explanation of how it works.
- Details on how the Annex I requirements are met.
- How your delivery process ensures it stays accessible.
(Note: If you are a public sector body, the plugin instead builds the model required by Implementing Decision (EU) 2018/1523. Our tool correctly distinguishes between the two, whereas most tools conflate them).
Honest Limits of Automation
We believe in being honest about the numbers. Our plugin runs 25 automated checks: 18 map directly to a WCAG 2.2 success criterion (levels A and AA), and 7 are recommended best practices.
However, automated testing finds roughly a third of real accessibility barriers. A clean report from our tool is a fantastic start, but it is not a legal conformance statement. You still need a human to perform keyboard navigation and screen reader testing. Publishing a page is not a legal filing, and this article does not constitute legal advice.
Audit Your Store Today
You can start auditing your WooCommerce store against WCAG 2.2 right now. Get your baseline report and start improving your store's accessibility in less than two minutes.
Get Accessibility Audit on WPBay
FAQ
Does the free version check my WooCommerce products? Yes, the free version runs 20 checks on up to five pages per scan, allowing you to test your most critical pages (like a top-selling product and the checkout page). The licensed version unlocks unlimited pages and the EAA document generator.
Do I need a separate tool for public sector compliance? No. If your site operates as a public sector body, the licensed version will automatically generate the model in Implementing Decision (EU) 2018/1523 instead of the EAA Annex V document.
Will this slow down my store? Not at all. The auditing happens entirely inside your WordPress admin dashboard on demand. There are no tracking scripts or continuous scanning APIs running on your front-end to slow down your customers' experience.
Sources: Directive (EU) 2019/882 · WCAG 2.2
I am a developer, not a lawyer, and none of this is legal advice. Article 4(5) of the EAA exempts microenterprises providing services altogether, which is worth reading before you buy any compliance tooling — ours included.