Czech Act No. 424/2023 Coll., on accessibility requirements for certain products and services, has been in force since 28 June 2025. Ever since, e-shop owners keep getting emails along the lines of "your e-shop breaks the law, you face a fine of 10 million CZK, get in touch". Most of those emails are dishonest — not because the law doesn't exist, but because they leave out the exemption that covers most small Czech e-shops.
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. If you sell only to businesses (B2B), the act doesn't reach you either. All other e-shops have had to meet WCAG 2.1 Level AA under standard EN 301 549 since 28 June 2025. Supervision is handled by the Czech Trade Inspection Authority (ČOI) and the upper limit for a fine is 10 million CZK.
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 | Yes |
| Turnover above EUR 2M (roughly 49–50M CZK) | Yes |
| You sell exclusively to businesses (B2B, no consumers) | No |
| You are part of a group of linked companies | Values are added together — the group is assessed, not the single entity |
| Public administration, schools, state-funded organisations | Yes, but under a different act (No. 99/2019 Coll.) |
Two things trip people up most often:
The conditions apply together, not as alternatives. Five employees and an annual turnover of 80 million CZK means you don't get the exemption. Employees are counted in full-time equivalents (annual work units), not headcount.
Splitting the company into smaller entities doesn't secure the exemption. If the entities are linked or partner enterprises, the values are added together for the assessment. This is the standard European definition of a microenterprise, not a Czech invention, and supervisory bodies know it.
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
The act itself doesn't spell out individual rules. It refers to the harmonised European standard EN 301 549, which for the web adopts WCAG 2.1 Level AA (WCAG 2.2 AA covers those requirements as well and is the safer choice going forward).
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. Grey text on white is the single most common mistake in Czech e-commerce.
- 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.
- Accessibility statement. A document describing the state of accessibility and a contact for feedback.
What happens if you are obliged and don't comply
The supervisory authority for e-commerce services is the Czech Trade Inspection Authority (ČOI). The upper limit for a fine is 10 million CZK.
The reality of the first enforcement wave looks different from that number, though. ČOI typically doesn't open with the maximum penalty — an inspection usually starts from a complaint, a call for remedy follows, and only continued inaction leads to a fine. Ten million is the statutory maximum for the most serious cases, not the opening figure for an e-shop with missing alt text. That doesn't make it ignorable: anyone can file a complaint, competitors included.
What remediation really costs
The scope depends on the platform and how far the e-shop is from the standard. From the projects I've handled, it breaks down roughly like this:
| Situation | What gets done | Rough scope |
|---|---|---|
| Template-based Shoptet/Shopify in good shape | Contrast, alt text, labels, focus states, statement |
A few hours at the hourly rate |
| 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 |
Accessibility can't be bought as a plugin. "Accessibility overlay" widgets — those floating little-person icons — don't fix the problem; they've been criticised for years by the screen-reader user community and have become the subject of lawsuits in the US. Accessibility is done in the template code.
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 costs a fraction of retrofitting a finished e-shop.
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
This is where law ends and business begins. According to the Czech Statistical Office, more than a million people in Czechia live with a disability; visual and motor impairments directly affect shopping on the web. Add temporary impairments — a broken arm, harsh sunlight on the display, a bumpy tram ride.
Most WCAG requirements are, on top of that, things that improve the e-shop for everyone:
- Sufficient contrast improves readability on a phone in sunlight.
- Descriptive form error messages reduce abandoned orders.
- 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:
- Try completing a purchase using only the keyboard. Tab, Shift+Tab, Enter, Space. Can you still see where you are? Do you reach the cart and get through checkout?
- Run Lighthouse on a product page (Chrome DevTools → Lighthouse → Accessibility). The score isn't proof of legal compliance, but it finds the crudest errors.
- Turn on a screen reader. Windows: Narrator (Ctrl+Win+Enter). macOS: VoiceOver (Cmd+F5). Listen to how it describes the main product photo and the "Add to cart" button.
- Zoom the page to 200% (Ctrl+ / Cmd+). Did the layout fall apart? Did content disappear?
- Check the contrast of your main text — for example with the WebAIM Contrast Checker.
Pass all five and you're in better shape than most of Czech e-commerce. Fail them and at least you know what to talk about.
Summary
Most small Czech e-shops have no obligation under Act 424/2023 — the microenterprise exemption (fewer than 10 employees and turnover up to EUR 2M) covers a large part of the market. If you are obliged, the target is WCAG 2.1 AA under EN 301 549, ČOI supervises, and the upper fine limit is 10 million CZK. Accessibility is solved in template code, not with an overlay widget, and comes cheapest as part of a redesign.
And above all: obliged or not, most of these fixes will lift both conversion and search visibility. That's the reason to do it even if no law existed.
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 — harmonised European standard
- 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.