E-commerce accessibility from June 28, 2025

The Polish Accessibility Act covers e-commerce services. A micro-entrepreneur providing the service is exempt, but a small or medium operator is not. Micro means fewer than 10 people and an annual turnover or balance sheet total not exceeding EUR 2 million, taking into account rules for affiliated enterprises.

What needs to be accessible#

• registration and login, including authentication;
• search engine, filters, ranking, and product card;
• information about the seller, price, warnings, and delivery;
• shopping cart, checkout, payment selection, and confirmation;
• withdrawal form, complaint form, product reporting, and contact;
• account panel and order history;
• documents, messages, and customer service related to the service.

Practical acceptance criteria#

• full keyboard operation without focus traps;
• visible focus and logical navigation order;
• correct headings, field labels, and error messages read by a screen reader;
• alternative text for meaningful images; product images cannot be the sole carrier of important warnings;
• adequate contrast, magnification, and reflow without loss of functionality;
• information is not conveyed solely by color, position, or sound;
• forms allow error correction, and data confirmation before payment;
• accessible CAPTCHA, MFA, time limits, and chat;
• understandable language and accessible downloadable files.

Information on accessibility and non-compliance#

The operator covered by the Act publishes in the terms and conditions or an equivalent document information on how the service meets accessibility requirements and keeps it up to date. If the service ceases to meet the requirements, it takes corrective actions and fulfills the obligation to notify the competent authority in accordance with the Act. Invoking disproportionate burden or fundamental change requires a documented assessment – it is not a general budget exemption.

Basis and sources: Polish Accessibility Act - E-commerce Services; Information obligations under the Polish Accessibility Act; Act of April 26, 2024; PFRON - Accessibility Guidelines.