Availability of Online Stores: Who is Covered by the Polish Accessibility Act

E-commerce obligations, exceptions for micro-enterprises, and practical testing.

Status checked: November 2, 2026. We are not a law firm. This material is for informational and educational purposes only and does not constitute individual legal advice. Before implementing solutions, check current regulations and consult a specialist regarding your specific situation.

What Services are Covered by the Act

The Polish Accessibility Act covers certain products and services, including e-commerce services offered to consumers. The fundamental provisions apply from June 28, 2025. First, determine whether a specific entity and service fall within the scope of the Act; not every website is subject to it in the same way.

Micro-Enterprise and Service

The Act provides an exemption for services offered or provided by micro-enterprises. This is not a blanket exemption for all micro-enterprises from every obligation regarding every product. Establish the correct definition, type of activity, and role in the supply chain. Other regulations or agreements may impose separate obligations.

What Accessible Purchase Means

The customer should be able to find information, select a product, and complete the purchase in a way that is accessible to various needs. Check readability, error messages, form labels, keyboard functionality, zooming, and support for assistive technologies. The mere existence of an accessibility statement does not prove that the purchase path works.

Verification and Providers

Go through the entire process from searching for a product to confirming the purchase on a phone and computer. Determine which elements you control yourself and which depend on the platform, payment operator, or external module. Ask providers for information and remove specific barriers; base the assessment of compliance with the Act on its scope and current requirements.

Examples of Barriers in Purchasing

A button without a recognizable name, a form field without a label, or an error message conveyed solely by color can hinder the purchase. Also, check whether the user can see which element has keyboard focus, whether text disappears when zoomed, and whether the transaction confirmation is understandable.

Do not base your assessment solely on an automated scanner. Combine automated tests with keyboard navigation, checking with a screen reader, and content evaluation. When commissioning an audit, establish the scope, version of the page, and how to confirm the removal of identified barriers.

Changes and Transition Periods

The Act includes transitional regulations regarding certain services and products. This does not mean a general postponement for every store or an automatic obligation to rebuild all devices. If a company uses older solutions or products, verify the exact situation and dates with the provider and advisor.

Action List

1. Determine whether the service and entity are subject to the Act.
2. Check the definition of micro-enterprise and exceptions.
3. Test keyboard functionality, labels, and error messages.
4. Identify owners of fixes and retest the purchase.

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