Czech Act No. 424/2023 Coll. regulates accessibility of selected products and services from 28 June 2025. Before commissioning an audit, distinguish statutory scope, the microenterprise service-provider exemption and actual website barriers. A threatening email alone establishes none of these.
This article says plainly who is obliged, who isn't, what exactly has to be met and what remediation really costs. I'm not a lawyer and this isn't legal advice, it's a practical overview with links to sources so you can verify it yourself.
If you have fewer than 10 employees and at the same time an annual turnover (or balance sheet total) of up to EUR 2 million, the accessibility obligation does not apply to you as a service provider. Both conditions must hold simultaneously. Pure B2B selling is outside the consumer e-commerce service category; other roles or products may need separate assessment. In-scope shops must meet applicable statutory requirements. Testing covers the purchase journey, not just one automated score. A website alone does not determine the duty.
What the law actually is
Act No. 424/2023 Coll. is the Czech transposition of EU Directive 2019/882, commonly known as the European Accessibility Act (EAA). The goal is that people with visual, hearing, motor or cognitive impairments can use everyday digital services on their own, without assistance.
It isn't only about e-shops. The act also covers banking services, e-books, electronic communications, ticketing and banking terminals. For e-shop owners one category matters: e-commerce services, meaning websites and apps where a consumer concludes a distance contract.
Who is obliged and who isn't
This is the core of the matter, and exactly the part the scare emails omit.
| Who you are | Does the act apply? |
|---|---|
| Fewer than 10 employees and at the same time turnover / balance sheet up to EUR 2M | No, microenterprise exemption |
| 10 or more employees | Fails the microenterprise staffing limit; assess the service |
| Turnover and balance sheet total both above EUR 2M | Fails the financial limit; assess the service |
| You sell exclusively to businesses (B2B, no consumers) | No |
| Partner or linked enterprises | Verify calculation rules; do not assess one set of accounts alone |
| Public-sector body | Separately assess the scope of Act No. 99/2019 Coll. |
Two things trip people up most often:
Headcount and the financial limit apply together. You meet the financial limit through turnover or balance sheet total: it is enough if one of the two stays within EUR 2 million. Five employees and an annual turnover of 80 million CZK therefore don't decide it alone: if the balance sheet total stays within EUR 2 million, the exemption applies. Check borderline cases with your accountant. Employees are counted in full-time equivalents (annual work units), not headcount.
Business relationships require a separate calculation. Partner and linked enterprises are not interchangeable and not every figure is automatically added at 100%. An accountant or lawyer should determine relevant relationships, proportions and periods. Commission SME definition.
If someone writes that "every e-shop must comply with the accessibility act from June 2025 or face a 10-million fine", and never asks about your headcount or turnover first, they're selling fear, not a service. An honest offer starts with the question of whether the act applies to you at all.
What an accessible e-shop must actually meet
Legal requirements, a technical standard and a WCAG test are distinct. EN 301 549 v4.1.1 with WCAG 2.2 was published in September 2026. AccessibleEU reported that its Official Journal citation was still pending. Specify the exact version in an audit and verify its legal status; publication alone is not a new legal deadline or website certification.
In practice that means roughly this:
- Keyboard operation. The whole purchase flow, from catalogue filters to completing the order, must be usable without a mouse, with a visible focus state.
- Text alternatives. Product photos have meaningful
alttext, icons and buttons have accessible names. Decorative images getalt="". - Contrast. At least 4.5:1 for body text, 3:1 for large text and UI components. Measure the actual text and control in their real states.
- Forms. Every field has a
<label>, and error messages explain what is wrong and how to fix it, not just a red border. - Assistive technology compatibility. Correct semantics (headings, lists, ARIA only where needed) so a screen reader can describe the page.
- Text resizing. Zooming to 200% must not break the layout or hide content.
- Video captions. If your e-shop has product videos carrying audio information, they need captions.
- Service accessibility information. Explain how the service meets applicable requirements; derive documentation from the relevant regime, not automatically a public-sector template.
Responding to an identified barrier
Record the location, reproduction steps and impact on purchasing. Establish the provider's duty, specify remediation and retest. This article does not predict the regulator's procedure or penalty amount; do not assume that a fine is possible only after an ignored remedy request.
What remediation really costs
The scope depends on the platform and how far the e-shop is from the standard. The table describes possible work scopes, not measured client projects:
| Situation | What gets done | Rough scope |
|---|---|---|
| Template-based Shoptet/Shopify in good shape | Contrast, alt text, labels, focus states, statement |
Scope after testing the complete journey |
| Customised template with bespoke components | Audit + fixes to filters, modals, cart and checkout | Scope of a smaller development package |
| Older e-shop with broken semantics | Realistically worth solving together with a redesign | Scope of a redesign |
An overlay widget alone does not establish accessibility. Changes must remove observed barriers in actual components and the purchase journey, followed by manual checks.
If you're planning a redesign or a platform move anyway, the cheapest path is to handle accessibility as part of that work rather than as a separate project. Fixing contrast and focus states while building a new template can reduce repeated work; the actual scope determines cost.
Transitional provisions: careful with "you have until 2030"
You'll occasionally read that "older e-shops have until 2030". EAA transitional provisions do exist, but they point somewhere else than is commonly claimed, they mainly concern products lawfully in use before 28 June 2025 (typically self-service terminals) and contracts concluded before the effective date. An e-shop website doesn't automatically fall into that category.
So don't treat 2030 as a blanket deferral for websites. If you're unsure about your specific situation, that's a question for a lawyer, not for a developer or a blog post.
Why bother even if you're exempt
People with visual, hearing or motor impairments may need different controls. Temporary circumstances, such as an injured hand or magnified text, can also reveal barriers.
Most WCAG requirements are, on top of that, things that improve the e-shop for everyone:
What improves the e-shop for everyone
- Sufficient contrast improves readability on a phone in sunlight
- Descriptive form errors explain how to correct an input; measure business effects separately
- Semantic headings and
alttext are read by search engines too, accessibility and SEO overlap heavily - Keyboard operation is appreciated by ordinary users tabbing between checkout fields
Accessibility isn't a tax. It's a subset of decently done frontend work.
How to check your status in ten minutes
Before paying anyone for an audit, go through this yourself:
Five steps of the quick check
- Keyboard complete a purchase using only the keyboard (Tab, Shift+Tab, Enter, Space); can you still see where you are, and do you reach the cart and get through checkout?
- Lighthouse on a product page (Chrome DevTools, Lighthouse, Accessibility); the score isn't proof of legal compliance, but it finds the crudest errors
- Screen reader Narrator on Windows (Ctrl+Win+Enter) or VoiceOver on macOS (Cmd+F5); listen to how it describes the main product photo and the "Add to cart" button
- Zoom to 200% (Ctrl+ / Cmd+); did the layout fall apart, or did content disappear?
- Contrast of your main text, for example with the WebAIM Contrast Checker
This quick check can reveal some barriers, but does not establish legal or complete WCAG conformance. Follow it with a representative audit of important states.
Summary
The exemption for microenterprises providing services concerns businesses with fewer than 10 employees whose annual turnover or annual balance-sheet total does not exceed EUR 2 million. If the Act applies to you, establish the specific requirements and exact version of the assessment standard. An audit should identify actual shopping barriers and prioritise fixes; neither an overlay widget nor an automated test result establishes compliance.
Obliged or not, removing barriers helps people use the site. Measure effects on orders and search visibility separately. That's the reason to do it even if no law existed.
If the changes affect the template, cart or checkout, they belong in an audit first and then a controlled e-shop redesign, not in a universal overlay widget.
Sources and links
- Act No. 424/2023 Coll. on accessibility requirements for certain products and services, full text (Czech)
- Directive (EU) 2019/882, European Accessibility Act, the European basis
- WCAG 2.1, Web Content Accessibility Guidelines, W3C, the technical standard
- EN 301 549, European standard; verify legal status for the exact version
- Czech Trade Inspection Authority (ČOI), supervisory body for e-commerce
- WebAIM Contrast Checker, contrast checking
This article is a practical overview, not legal advice. For edge cases, linked companies, a mix of B2B and B2C, transitional provisions, consult a lawyer.