Imagine choosing a jacket in your shop without touching the mouse. Tab reaches the size selector, but nothing shows which size has focus. Enter opens the mini-cart. Then you’re stuck behind it, unable to reach checkout.
That’s a broken buying journey. A customer shouldn’t need a mouse, perfect eyesight or guesswork to pay you.
I’d put this test into any WooCommerce development brief, alongside shipping rules and payment setup. Start with whether someone can actually buy.
What the European Accessibility Act covers
The European Accessibility Act, Directive (EU) 2019/882, has applied since 28 June 2025. It covers specified products and services, including consumer ecommerce. In Estonia, it’s implemented through the Products and Services Accessibility Act and regulations 45 and 46, with guidance from TTJA.
This isn’t just about your homepage. TTJA describes a journey covering selection, registration, payment, purchase confirmation emails and return or exchange information.
Is your small shop exempt?
The service exemption matters. A microenterprise providing services is exempt under Article 4(5). The definition requires fewer than 10 persons AND either annual turnover not exceeding €2 million OR an annual balance sheet total not exceeding €2 million.
Both parts matter. Exactly 10 persons fails the headcount test. Exactly €2 million meets the relevant financial boundary, and either financial measure can qualify if the headcount requirement is met.
Genuinely B2B-only sales fall outside this consumer ecommerce definition. A shop serving consumers doesn’t become B2B by adding a company-name field.
Also, this is a service exemption, not a blanket exemption for microenterprises making covered products. Other legal duties may still apply to exempt shops. And an old development contract doesn’t automatically protect a shop until 2030; transitional rules are narrow. This is practical guidance, not legal advice.
Which accessibility standard should you use?
TTJA’s guidance references EN 301 549 V3.2.1, which uses WCAG 2.1 AA. AccessibleEU’s September 2026 update reports that V4.1.1 has been published and adopts WCAG 2.2, but formal Official Journal citation is still pending according to that update.
I’d use WCAG 2.2 AA as the development target. Not a certificate. EN 301 549 reaches beyond web WCAG, and completing WCAG checks alone doesn’t establish full EAA compliance. Don’t confuse a public-sector standards citation with an automatic EAA legal safe harbour. Publication alone creates no new compliance deadline.
A ten-minute first pass through your shop
Use staging with a test payment gateway. No real orders or payments. This quick pass borrows from W3C WAI checks and WooCommerce’s guidance; it finds obvious blockers, not every accessibility problem.
- Park the mouse. Use Tab and Shift+Tab to move, Enter to follow links or activate buttons, and Space for suitable controls such as checkboxes. Look for visible keyboard focus and a working skip link past repeated navigation. A noticable outline helps.
- Choose a variation. Select a jacket size and colour using only the keyboard. Test dropdowns and custom swatches. Can you tell which option is selected and which combinations are unavailable?
- Open the menu and mini-cart. Check opening, closing and sensible focus movement. Watch cart quantities update. Whether those changes are announced needs screen-reader follow-up; sight alone can’t confirm it.
- Try a bad checkout entry. On staging, deliberately enter an invalid email address. Every field needs a proper label, not placeholder-only instructions. Errors should explain the fix and be associated with the relevant field, rather than appearing as an unexplained red border.
- Check contrast and colour. W3C WCAG AA calls for at least 4.5:1 contrast for normal text and 3:1 for large text. Check actual colour pairs with a contrast checker. Stock status and errors mustn’t depend on colour alone.
- Review image alternatives. Product alt text should convey useful visual information, such as a backpack’s roll-top closure. Decorative images need empty alt text. Don’t stuff every image with search keywords.
- Zoom in. Try 200% and 400% browser zoom, then a narrow mobile layout. Check whether totals, field labels and payment buttons remain readable and usable without overlapping or disappearing.
- Trigger popups. Open promotional dialogs and the cookie banner. Can you close them and continue without a focus trap? For consent configuration itself, see the separate guide to cookie banners and analytics.
- Follow payment and delivery. Test payment iframes, authentication, bank selection and parcel-locker widgets using sandbox facilities. Never enter a real payment just to finish this check. Note any provider flow you couldn’t test.
- Play a product video. Check captions for speech and meaningful sound. Provide a text alternative for important visual information, such as assembly steps shown without narration.
Ten minutes is triage. A reassuring result still needs longer testing with NVDA or VoiceOver, including dynamic announcements and realistic payment flows.
Where WooCommerce shops usually get tangled
WooCommerce documents support for keyboard use, focus, screen readers, labels and error feedback with compatible themes. That doesn’t guarantee your configured shop.
A page builder can remove focus styling. Custom variation swatches may ignore keyboard input. Icon-only buttons can lack accessible names, while checkout extensions can replace working fields with troublesome ones. Older deprecated blocks may also have limited support.
Under TTJA’s guidance, the merchant remains responsible for the service, including selected paid payment and delivery solutions. Ask providers for evidence and test access rather than accepting a badge.
Check after-purchase actions too. If you’re implementing the EU withdrawal button in WooCommerce, that action must also work by keyboard; the EAA doesn’t itself create the withdrawal-button requirement.
Fix the buying blockers first
My priority would be a trapped checkout before a decorative homepage issue. Labels, contrast and useful alt text are often quick wins, but they don’t cancel out an unusable payment step.
Back up first, make changes on staging and regression-test the purchase path. Targeted development work on an existing site can address theme or extension problems without rebuilding everything. Then arrange a full manual audit with an accessibility specialist and disabled users, covering realistic screen-reader and payment journeys.
An in-scope Estonian provider also needs accessible information explaining compliance, available in written and oral accessible formats and maintained throughout service provision. Describe the tested scope honestly. Don’t turn a scanner result into an unsupported certification claim.
Today, open staging and choose one variable product. Put the mouse aside. See whether you can reach the test payment button.