Ecommerce Europe publishes new Position Paper on the European Accessibility Act


In December 2015, the European Commission published a Proposal for a Directive on the approximation of laws, regulations and administrative provisions as regards the accessibility requirements for goods and services (European Accessibility Act), which also targets “e-commerce” in its scope. First of all, Ecommerce Europe welcomes the objectives of the proposed legislation, and overall strongly supports the principle of accessibility as a means of promoting the inclusion of disabled people in society.

Despite this, Ecommerce Europe views the Proposal as deeply problematic in several key ways, and in particular fears the impact that the proposal would have on the e-commerce sector. For this reason, Ecommerce Europe, the European e-commerce association, decided to publish a new Position Paper on the European Accessibility Act, which gives European legislators policy recommendations and presents potential consequences of the Proposal on online merchants, especially on SMEs. The new position paper of Ecommerce Europe can be summarized in a few key recommendations for EU legislators, which represent the online merchants’ perspective on this dossier:

  • Take into account market-based solutions to the issue of accessibility
  • Provide further evidence of single market barriers resulting from differences of national legal frameworks for accessibility
  • Develop a more clearly defined and more targeted scope
  • Take into account the cost of compliance for businesses, especially SMEs (see also separate German study on implementing costs of accessibility requirements for online merchants here and here)
  • Reduce the compliance burden placed on importers and distributors by the Act
  • Develop a less burdensome framework for exemptions and notification, especially for SMEs
  • Re-consider the ‘design for all approach’ taken by the Accessibility Act
  • Develop a more suitable alternative to the CE mark to demonstrate accessibility

Progress made by EU policymakers on the draft EU Accessibility Act Directive and remaining issues

The Draft Report on the Act, published by Rapporteur Morten Løkkegaard (ALDE, Denmark), has put forward some key changes to the Proposal, many of which are welcomed by Ecommerce Europe. In particular, the exclusion of microenterprises from the scope of the legislation is welcome, as is the removal of provisions conflating accessibility with safety. In addition, Ecommerce Europe views favorably the clarification in the Løkkegaard Draft Report concerning the design for all approach. Finally, Ecommerce Europe acknowledges MEP Løkkegaard’s efforts to clarify and limit the scope with regards to e-commerce, but nonetheless continues to have concerns about its clarity and the impact on online marketplaces.

Further explanation on our position and on the policy recommendations can be found in our new Position paper on the European Accessibility Act (March 2017) available here.


  1. Temporary evaluation of the costs for a small or medium-sized e-commerce company in Germany
  2. Temporary evaluation of the costs for a medium-sized e-commerce company in Germany with several and multilingual online shops