The European Accessibility Act (EAA) is the name commonly used for Directive (EU) 2019/882 of the European Parliament and of the Council of 17 April 2019 on the accessibility requirements for products and services. In Lithuania, it has been transposed by the Law on Accessibility Requirements for Products and Services (Gaminių ir paslaugų prieinamumo reikalavimų įstatymas) No XIV-1633, which was adopted on 8 December 2022 and came into force on 28 June 2025. In everyday business language, it is often simply called ‘the Accessibility Directive’.
The idea behind the Law is that blind and deaf people, as well as people with mobility or cognitive impairments, must be able to use everyday products and services independently. For website owners, the most relevant part covers e-commerce services. The Law was amended in 2026 (the amendments took effect on 1 April), so always refer to the consolidated version in the e-TAR register of legal acts.
The requirements apply when you use a website or app to offer a consumer – that is, a private individual – the chance to conclude a contract at a distance: to buy a product, a service, a ticket or a subscription. The Law calls these e-commerce services. The exemptions are microenterprises providing services and stores that sell only to businesses.
| Situation | Does it apply? | Note |
|---|---|---|
| An online store where consumers buy; the company has 10 or more staff | Yes | The entire purchase journey must be accessible – from search to order confirmation. |
| The same online store, but run by a microenterprise | No | A microenterprise has fewer than 10 employees and an annual turnover or balance sheet total of no more than €2 million. |
| A store where only businesses can buy (B2B) | Not directly | If the basket is also open to private individuals, the store is already aimed at consumers. |
| A booking or service ordering system, e.g. for a salon or a gym | Most likely yes | Booking or paying online means concluding a contract at a distance. |
| An informational company website with service descriptions and an enquiry form | Usually not | An enquiry is not yet the conclusion of a contract, but accessibility is worthwhile here too. |
| State and municipal institutions | Yes, but under a different directive | Directive (EU) 2016/2102 applies – see the next section. |
The table is a guide, not legal advice. The guidelines of the Ministry of Social Security and Labour stress that service providers must assess for themselves whether their service falls within the scope of the Law. Company size is determined under the Law on the Development of Small and Medium-Sized Business (Smulkiojo ir vidutinio verslo plėtros įstatymas); if in doubt, consult a lawyer.
Article 2(6) of the Law lists exemptions for website and app content:
State and municipal institutions are covered by a separate directive, (EU) 2016/2102, whose requirements took effect in 2019–2021. The European Accessibility Act, aimed at businesses, applies from 2025 and covers only certain services provided to consumers.
| Criterion | Public sector | Businesses |
|---|---|---|
| Legislation | Directive (EU) 2016/2102 | Directive (EU) 2019/882 and the Law on Accessibility Requirements for Products and Services |
| Applies to | websites and mobile apps of public sector bodies | e-commerce, banking, electronic communications, passenger transport, e-book and certain other services provided to consumers |
| From | new websites – from 23 September 2019, all websites – from 23 September 2020, apps – from 23 June 2021 | from 28 June 2025 |
| What to publish | an accessibility statement | information on how the service meets the accessibility requirements |
Article 30(3) of the Law allows service providers to keep using products they lawfully used before the Law came into force until 28 June 2030, and service contracts concluded before 28 June 2025 remain valid unchanged until they expire, but no later than 28 June 2030. For an online store, this provision changes very little: every purchase is a new contract, so the Ministry's guidelines state that an e-commerce service must be accessible for new contracts from 28 June 2025.
The Law does not name a single technical standard – Annex 1 describes what the service must be like: perceivable, operable, understandable and robust. In practice, compliance is assessed against the European standard EN 301 549, whose section on websites is based on Level AA of the WCAG guidelines.
In September 2026, a new version of the standard, EN 301 549 v4.1.1, was published. It is based on WCAG 2.2 and, for the first time, is directly linked to the European Accessibility Act. Until the European Commission references it in the Official Journal of the EU, EN 301 549 v3.2.1, based on WCAG 2.1 AA, remains the benchmark. Since WCAG 2.2 includes all the WCAG 2.1 criteria and adds new ones, it makes sense for a new or updated website to aim for WCAG 2.2 AA straight away.
In an online store, the shopper's entire journey must be accessible: search, product selection, registration, the basket, payment, order confirmation, delivery and returns terms, and the option to ask for help. The requirements apply to the whole platform, not just its new parts.
| Stage | What to check |
|---|---|
| Search and filters | The search field has a label, filters can be selected with a keyboard, and a change in the number of results is announced to screen readers. |
| Product page | Images have alt text, the price and stock level are given as text, and size or colour can be chosen by more than just a coloured square. |
| Basket | The buttons for changing the quantity and removing items have clear names and work with a keyboard. |
| Checkout form | Every field has a visible label, errors are explained in text next to the field, and the browser can autofill the name, address and email. |
| Login and bot protection | Logging in doesn't require remembering or re-typing characters without an alternative; the password can be pasted or filled in by a password manager. |
| Payment | Bank and payment method icons have text names, and the payment window can be navigated with a keyboard. |
| Emails and documents | The order confirmation, invoice, and delivery and returns terms are provided as text, not as an image or a scanned PDF. |
The payment window is often displayed by the payment provider rather than your website, so the Ministry's guidelines recommend choosing providers whose interface is accessible. In addition, Article 13 of the Law requires you to publish information on how the service meets the accessibility requirements. This is a free-form document, usually a separate page linked from the website footer.
No. An accessibility widget (an overlay) is a button at the side of the website that lets visitors enlarge the font or change the colours, but it does not reliably fix errors in the website's code. If a form doesn't work with a keyboard, a button has no name or an error is signalled only by a red border, the widget won't fix these problems.
Screen reader users usually have their own tools, so what matters most to them is a properly built website. In 2025, the US Federal Trade Commission (FTC) ordered the maker of one such widget to pay USD 1 million over unsupported claims that the tool could make any website WCAG-compliant.
In Lithuania, the accessibility of e-commerce, consumer banking services and e-books is supervised by the State Consumer Rights Protection Authority (Valstybinė vartotojų teisių apsaugos tarnyba, VVTAT). It also handles consumer complaints. Article 23 of the Law sets a fine of €500 to €2,500 for providing a service that does not meet the accessibility requirements.
| Infringement | Fine |
|---|---|
| Providing a service that does not meet the accessibility requirements | €500–2,500 |
| Continuing to provide the service after the supervisory authority has ordered it to stop | €1,000–6,500 |
| A non-compliant service or product has harmed a consumer's health | €2,500–15,000 |
The fine is calculated from the midpoint of the range, taking the circumstances into account, and does not release you from the obligation to fix the shortcomings. Other areas are supervised by the Lithuanian Transport Safety Administration (passenger transport), the Communications Regulatory Authority (RRT, electronic communications) and the Radio and Television Commission of Lithuania (audiovisual media services).
You can get a first impression of your website's accessibility within an hour by using free tools and trying to buy a product yourself without a mouse. Such a check does not replace a thorough assessment, but it shows where the biggest barriers are.
You'll find a detailed list with specific WCAG 2.2 criteria and examples in our article ‘How to make your website accessible to people with disabilities: 12 checks based on WCAG 2.2’.
First, fix whatever stops people from buying: forms, buttons, keyboard navigation and the payment step. Many shortcomings lie in the theme, so a single fix often sorts out hundreds of pages.
If the theme is outdated and can't be fixed, it is usually more sensible to replace it. Saitai.lt updates WordPress, WooCommerce, Joomla and VirtueMart websites, replaces themes and reworks forms – more on our page about website redesign and rebuild (from €299). If you'd first like to know what needs fixing, a website accessibility audit against WCAG 2.2 AA costs from €120 and usually takes 1–3 working days. When updating a website, we agree in advance which shortcomings we will fix, and once the work is done, we check that they have been fixed. Compliance with the Law is assessed by the service provider itself, so we do not give any guarantee of compliance.
Want to make your online store accessible? In the enquiry form, give us your website address and the system it's built on. Within 1 working day, we'll tell you where it's best to start: a website accessibility audit (from €120) or going straight to a website update.
It depends on the size of the company, not the size of the store. If a company has fewer than 10 employees and an annual turnover or balance sheet total of no more than €2 million, it counts as a microenterprise and is exempt from the requirements. A small company with, say, 15 employees no longer qualifies for this exemption, even if its store has only a few dozen products.
Yes, if the Law applies to you – although the Law calls it not a statement but information on the accessibility of the service: Article 13 requires you to publish how the service meets the accessibility requirements and to provide this information in an accessible format. The document can take any form. The W3C's guidance on writing an accessibility statement is helpful when preparing it, and for public sector bodies, such a statement is mandatory.
Not directly, because the Law applies to services provided to consumers. However, if anyone can buy and the company code field is optional, the store is in practice aimed at consumers too. The Ministry's guidelines also point out that accessibility requirements may be passed down the supply chain when the end user is a consumer.
No. In the WordPress.org theme directory, this tag means the theme has been checked against the basic accessibility requirements. But compliance also depends on plugins, your content, form settings, payment modules and any colours you change. A good theme is a sound foundation, but you still need to check the entire purchase journey.
It depends on the theme, the plugins and the amount of content, so the timeline can only be estimated after a check. A Saitai.lt website accessibility audit costs from €120 and usually takes 1–3 working days. Template errors can often be fixed quickly; content takes the most time: alt text for hundreds of product images, PDF documents, video subtitles. A technical website update by Saitai.lt (CMS, theme, plugins) takes from 5 working days, while the time needed to sort out the content depends on how much there is.
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