We took the first phone call about this last summer. The caller was the owner of a mid-sized store selling children's products - he had read somewhere that "you need WCAG from June" and wanted to know if he was facing a fine. He didn't know exactly what WCAG was, didn't know whether his store was subject to the new regulations, he only knew the deadline had passed and he had done nothing. Over the following months there were a dozen or so such conversations. That's why I'm writing this text as a way of putting the topic in order rather than as an alarm - because more panic than substance has built up around digital accessibility.
Let's start with a fact many business owners missed: on June 28, 2025, the Polish Act of April 26, 2024 on ensuring the accessibility of certain products and services by economic operators came into force.[1] It is the Polish transposition of EU Directive 2019/882, better known as the European Accessibility Act.[2] And - contrary to what you sometimes hear - it is not a regulation for public offices only. It also applies to ordinary online stores.
Who this really affects
Here the first misunderstanding appears. A digital accessibility obligation for the public sector has existed in Poland since 2019, and that's what the earlier act on the digital accessibility of public sector websites covered. What's new is that the European Accessibility Act carried these requirements over to the private sector - to e-commerce, banking, telecommunications services, transport, and e-books.
An online store is subject to the regulations if it provides services to consumers (B2C) and doesn't qualify as a microenterprise providing services. In practice the threshold has two parts: the exemption covers companies employing fewer than 10 people whose annual turnover or balance sheet total doesn't exceed 2 million euros. If you significantly exceed either of these thresholds - the regulations apply to you. Cross-border sales don't change the picture: what counts is whether you offer services to consumers in the EU, not where your registered office is.
It's worth saying this plainly, because it can be a source of false security: a small store run as a sole proprietorship may indeed be exempt. But a store with a warehouse, a team of several people, and turnover above two million euros - is not. And there are tens of thousands of those in Polish e-commerce today.
WCAG, or what this accessibility consists of
The act refers to the technical standard EN 301 549, which in turn refers to the WCAG guidelines at level AA. WCAG (Web Content Accessibility Guidelines) is a set of criteria developed by the W3C consortium describing how to build digital content accessible to people with various disabilities.[3] The regulations most often cite version 2.1, though in practice the industry already works with 2.2, which extends it.
The whole philosophy of WCAG fits into four principles that form the acronym POUR: content must be Perceivable, Operable, Understandable, and Robust. It sounds abstract, so let's translate it into things I see on the screen of almost every store we audit:
- product photos without alternative text - the screen reader tells a blind user "graphic" instead of "women's hiking boots, navy blue";
- light gray text on a white background, with contrast below the required 4.5:1 - unreadable for a visually impaired person, and often for anyone in the sun;
- a cart that can't be operated with the keyboard alone, because "add to cart" responds only to a mouse click;
- an order form where a field with an error is only highlighted in red - with no message that assistive technology can read out;
- form fields without associated labels, so a screen reader user doesn't know what they're actually typing.
None of these problems is exotic. This is everyday reality for stores built "quickly", on a ready-made template, without anyone thinking about accessibility at the design stage. And that's exactly why it's cheapest to include it from the start - when building a website or online store - rather than patching it after the fact.
The myth that costs the most: "a plugin is enough"
The most common question we get is: "can't this be solved with a single overlay?". There is indeed a whole category of products on the market - so-called accessibility overlays - promising that after pasting a single line of code the store "becomes WCAG compliant". A widget hanging in the corner of the screen with a wheelchair icon, font-size sliders, and a high-contrast mode looks convincing and tempts with a subscription price instead of the cost of a rebuild.
I'll say it bluntly, because we've seen the consequences: an overlay alone does not make a website accessible. Organizations representing blind people have repeatedly pointed out that such widgets at best duplicate functions the operating system and screen reader have had for years, and at worst conflict with assistive technologies and make the site harder to use. What's more, an overlay doesn't fix the root of the problem: if the "add to cart" button isn't keyboard accessible, no contrast slider will change that. When you buy an overlay, you're usually buying false peace of mind - and sometimes outright evidence in a case that the problem was known and "solved" with a dummy.
Accessibility can't be glued on. It has to be built in - into the code, the heading structure, the forms, the contrasts defined at the design level. It's more work than pasting a script, but it's the only path that actually works and that will hold up in an inspection.
What's at stake and why not to wait for the first fine
The act provides for administrative penalties. The upper limit depends on how the provision is constructed, but the figure circulating is up to 10% of the previous year's turnover - painful enough that it's not worth testing on your own store. A sanction is, however, preceded by proceedings and a request to remedy the violations, so catastrophe doesn't fall from the sky. The real risk today is different: a complaint from a dissatisfied user, an inspection, and further down the line the loss of customers who simply cannot buy from you.
Because that's the crux that gets lost in the discussion about fines. According to Statistics Poland (GUS), over 4.7 million people with disabilities live in Poland - about 12% of society. Add to that the growing group of seniors shopping online, people with temporary limitations (a broken arm, bright sun on a phone screen), and it turns out accessibility is not a niche but a sizable part of the market that an inaccessible store quietly turns away.
Where to start - order, not panic
In our practice, a sensible sequence looks like this. First an audit: an automated scan (tools like axe or Lighthouse will catch some of the technical errors), followed by a manual test - navigating with the keyboard alone and walking the purchase path with a screen reader on. Automated tools catch maybe half the problems; the rest only surface when someone actually tries to buy a product without a mouse.
Then prioritization. Not everything weighs the same - we fix the critical path first: entry, product page, cart, payment. A store where a purchase can be completed with the keyboard and a screen reader is already ahead of most of the competition. Only later do we polish the blog, the footer, and the peripheral elements.
Finally - and this is an obligation that's easy to forget - the accessibility statement. It's a public document describing the accessibility status of the website and the contact details for reporting problems. We maintain ours openly; if you're curious what such a document looks like in practice, take a look at our accessibility statement.
And one more thing from our practice, because it tends to surprise: the biggest obstacles in stores usually aren't in the template code itself, but in the content the owner adds day to day. Uploaded photos without alternative descriptions, banners with the entire promotional message "burned into" the graphic (and therefore invisible to a reader), headings used for visual effect instead of structure - this gets produced daily, long after launch. That's why accessibility is not a one-off project with a checked box, but an editorial habit. It's worth training the person who manages the content, because otherwise even the best-built store will become inaccessible again over time.
Accessibility pays off even when nobody is inspecting you
I have the impression that the greatest harm done to this topic was framing it purely as a legal obligation. Because even if the act were repealed tomorrow, a store well built for accessibility would be left with several real advantages. Correct semantic code, sensible headings, alternative descriptions, and a readable structure are exactly the things Google's robots like - accessibility and SEO overlap to a large extent. A faster, cleaner front end means a lower bounce rate. And a clear, high-contrast interface simply sells better - to everyone, not just people with disabilities.
If you run a store that meets the act's threshold and you've been putting the topic off - that's a sign to come back to it now, calmly, rather than under the pressure of the first formal notice. If you don't know where to start, or want someone to walk your site along the path of a real user with a screen reader, get in touch with us - we do accessibility audits and implement fixes in a way that doesn't break what already works.
Sources
- The Act of April 26, 2024 on ensuring the accessibility of certain products and services by economic operators (Journal of Laws 2024, item 731) - ISAP, Sejm of the Republic of Poland.
- Directive (EU) 2019/882 of the European Parliament and of the Council of 17 April 2019 on the accessibility requirements for products and services (European Accessibility Act) - EUR-Lex.
- Web Content Accessibility Guidelines (WCAG) 2.1, W3C Recommendation - W3C; a condensed overview of the criteria: How to Meet WCAG (Quick Reference).
