AppCrates
Guide chapters
§ - Important Disclaimer Regarding the Nature of the Material00 - How to use the guide01 - First choose the business and responsibility model, then build the marketplace02 - Construction plan: what must exist and when03 - Responsibility Matrix: Operator, Seller, and Suppliers04 - Seller Onboarding: Whom to Allow to Sell05 - Product card: information without which an offer cannot be published06 - GPSR: Product Safety in Practice07 - Product Category Gates08 - Packaging and EPR: who is actually responsible09 - Consumer Law: Sale, Withdrawal, and Complaint10 - Prices, Promotions, Ranking, Advertising, and Reviews11 - Payments, Payouts, VAT, and Sales Documents12 - GDPR without myths: what to record, where, and on what basis13 - DSA: reporting, moderation, and seller traceability14 - P2B: fair rules for business users15 - DAC7: seller data and annual reporting16 - E-commerce accessibility from June 28, 202517 - Cybersecurity and NIS218 - Retention: How long to store data and evidence19 - Post-launch operations: calendar and owners20 - Four business models - specific decisions21 - Document and Procedure Package to Prepare22 - GO / NO-GO Checklist Before Launch23 - Most Common Misconceptions24 - Sources and Update Principle
Chapter 16EU

E-commerce accessibility from June 28, 2025

The European Accessibility Act covers e-commerce services and each member state implements it in national law (in Poland, the Accessibility Act). 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: Accessibility Act (Poland) - e-commerce services; Information obligations under the Accessibility Act (Poland); Act of April 26, 2024; PFRON - Accessibility Guidelines.

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