Act No. 424/2023 Coll., on accessibility requirements for certain products and services, came into force on 28 June 2025 (§ 29). It also covers e-commerce services, which means an ordinary online shop. Supervision is carried out by the Czech Trade Inspection Authority, and under § 25(8) fines range from 1 to 10 million crowns. Micro-enterprises are exempt.
The date has already passed. This text is therefore not about preparing for a deadline but about what specifically to measure on a shop that is already running. And we start with ourselves: on our own home page, on 30 August 2026, we found three colour pairs below the required contrast. The worst was 2.53:1 against a required 4.5:1.
The law was written in Brussels but is enforced in Prague
Act 424/2023 Coll. is the Czech implementation of Directive (EU) 2019/882 of the European Parliament and of the Council, commonly known as the European Accessibility Act. One practical thing follows for you: arguments will be made under Czech law and the inspection is done by the Czech Trade Inspection Authority, not by an EU institution.
The directive is useful only where the Czech text is ambiguous and you need to know the intent. In a dispute, what counts is the section number, not the article of the directive.
Who falls under the law and who falls out of it
An e-commerce service is defined in § 3(1)(i) as a service provided at a distance through websites or mobile devices, by electronic means and at the individual request of a consumer with a view to concluding a consumer contract. In other words: a shop for end customers, whether it runs on Shoptet, Shopify or custom code.
A micro-enterprise is exempt under § 2(3)(a). The Act does not define a micro-enterprise itself; it refers to Article 2(3) of Annex I to Commission Regulation (EU) No 651/2014: fewer than 10 employees and at the same time annual turnover or balance sheet total not exceeding EUR 2 million.
That exemption breaks in two places:
- The conditions apply together. A company with eight people and turnover of 60 million crowns is not a micro-enterprise.
- The exemption is not permanent. Hire a tenth person and you lose it, and the obligation arises with no transition period.
Purely B2B selling falls outside the definition, because it says "with a view to concluding a consumer contract". The practical effect is smaller than it sounds, though: it is enough that a non-business customer can order from you and you are back under the Act. Wholesale behind a login is a different situation from a shop whose terms merely state that it sells to companies only.
The Act does not name WCAG. It will be measured against it anyway
Annex 1 to the Act describes functional requirements, not a technical standard. It requires the service to be perceivable, operable, understandable and robust. You will not find the word WCAG in the Act, and that confuses some operators.
In practice accessibility is measured against the European standard EN 301 549, which in version V3.2.1 of March 2021 incorporates the whole text of WCAG 2.1 at level AA. The newer version V4.1.1, produced under Commission standardisation mandate M/587, incorporates WCAG 2.2 and its publication is expected in 2026. EN 301 549 is not yet cited in the Official Journal as a harmonised standard to the EAA. Citation of version V4.1.1 is scheduled for 30 November 2026, and only that will establish a presumption of conformity. Until then the functional requirements of Annex 1 apply on their own.
Our recommendation does not depend on that uncertainty. We build to WCAG 2.2 AA, because the two criteria it adds are exactly the ones shops fail on: a minimum target size of 24 x 24 px (2.5.8) and the ban on focus being obscured by a sticky header (2.4.11). Meet 2.2 and you meet 2.1.
A theme that claims to be accessible guarantees nothing
This is the most expensive misunderstanding in the whole subject. An accessible theme means its default state is accessible - the demo with sample colours and text. Your shop is not the default state.
We will measure it on our own site so this is not a theory about other people's mistakes. Our home page, measured with our own tool on 30 August 2026 at a width of 390 px:
| What was measured | Result |
|---|---|
| Text and background colour pairs | 40, 3 of them below the standard |
| Worst ratio | 2.53:1 against a required 4.5:1 |
| Clickable targets in total | 111 |
| Targets smaller than 24 x 24 px | 5 |
| Targets smaller than 44 x 44 px | 60 |
| Pairs of targets closer than 8 px | 77 |
The worst pair is orange #e68900 on a #fafafa background at 11.2 px. It is a brand colour on a light background - exactly the kind of decision nobody treats as a technical error. And it is the main reason a theme moves from an accessible state to an inaccessible one.
We put this here deliberately. An agency that sells audits and has three failing contrasts on its own home page either says nothing or says it first. The fix is planned and we will publish the numbers afterwards.
Shoptet adjusted its themes in spring 2026; the rest is still on you
On 13 April 2026 Shoptet described what it changed in its themes for accessibility: it fixed the heading hierarchy in the sidebar and the footer, adjusted the contrast of colour schemes, reworked the login window in the Techno, Tango and Step themes, and converted header buttons into real HTML buttons.
The changes propagated automatically with one exception: shops with Deferred theme updates enabled did not get them. That is awkward, because the option is mostly switched on by whoever has customised the theme with their own HTML - in other words the person furthest from the default state.
And even after the update, everything else stays with the operator: custom HTML in editable blocks, banners, alt text on photos, PDF manuals, videos without captions and third-party add-ons. The chat bubble, the cookie bar and the review widget are the three most common places where a shop's accessibility ends, and none of them is supplied by the platform.
Seven places where shops fail most often
Ordered by how often we see it, not by severity.
outline: nonewith no replacement. A removed focus ring is the most common defect. Anyone driving the site from a keyboard stops knowing where they are.- Contrast below 4.5:1 on body text. Grey on white, a brand colour on a light background, text over a photo. For large text the threshold is 3:1.
- A clickable target smaller than 24 px. The cart icon, the close button on a modal, footer links set to 18 px high.
- A cart operable only with a mouse. A custom variant dropdown and plus/minus quantity buttons built on
divinstead ofbutton. - A form error conveyed by colour alone. A red border with no text does not exist for anyone who cannot see the difference between grey and red.
- An empty or decorative
alton product photos. In a shop the photo is part of the product description, not decoration. - Breaking at 320 px and at 400 % zoom. WCAG requires it at level AA and it is also the cheapest thing to test.
An hour-long test you can run yourself
You need neither a tool nor us. You need an hour and a keyboard.
Go through the whole purchase with the Tab key. From the home page through a category listing, a product detail and the cart to completing the order. Watch two things: whether you can see where you are at every step, and whether the order matches what you see on screen. When focus disappears or jumps, you have a finding.
Zoom the page to 400 % at a window width of 1280 px. That produces a layout equivalent to 320 px. Text has to stay readable without horizontal scrolling and nothing may be lost.
Measure your three most common colour pairs. Body text on the background, button text on the button, and footer text on the footer. Any public contrast tool will do. The threshold is 4.5:1 for body text and 3:1 for text larger than 24 px or bold above 18.66 px.
If all three tests pass, you are not yet compliant, but you are past the worst. If they fail, you know what to commission.
"Disproportionate burden" is not an escape route, it is a document
The Act allows you not to meet the requirements if doing so would impose a disproportionate burden or fundamentally alter the service. That exemption does not apply merely because you have thought about it.
You must have a written assessment, keep it, and produce it to the supervisory authority on request. The assessment is repeated; the directive speaks of an interval of no more than five years and on every substantial change to the service. In the Czech Act this is in § 15: the assessment is kept for 5 years and a new one is drawn up on a change to the service, and at the latest within 5 years of the date of the last one.
A practical note from our side: on an ordinary shop on a standard platform this exemption is hard to defend. Fixing contrast and target sizes is a few days' work, and that is not a disproportionate burden even for a small company.
Transitional periods run until 28 June 2030. They do not apply to the website
§ 28 contains three transitional provisions and they are worth keeping apart:
- A provider may continue to use products that do not meet the requirements until 28 June 2030 at the latest (§ 28(4)).
- Contracts concluded before the Act took effect may run until the obligation ends, but no later than 28 June 2030 (§ 28(5)).
- Self-service terminals may be used for no more than 20 years from first commissioning (§ 28(3)).
None of those periods postpones accessibility of the shop itself. That has applied since 28 June 2025 and concerns the site you have running today.
What to do now
If you are a micro-enterprise and you know it for certain, save this text and come back to it when you hire your tenth person. If you are not, run the three tests from the previous section. They take an hour and will tell you whether you are dealing with cosmetics or a rebuild.
We measure accessibility as part of a technical audit, because it overlaps heavily with what we check anyway: markup semantics, element states, behaviour at small widths. What the audit covers is on the site audit and speed page.
Write to info@lamapixel.com or call +420 775 599 009. We will include measured contrast values and target sizes from your home page and a product detail in the reply, so you know what we are talking about.
Legal position verified as of 3 September 2026: Act No. 424/2023 Coll., Directive (EU) 2019/882 and the status of EN 301 549. A review of this article is scheduled for 28 February 2027.
