Does a chatbot on my site also have to be accessible?

A chatbot is subject to the same accessibility requirements

Yes, a chatbot or live chat on an e-commerce site is subject to the same requirements as the rest of the site. WCAG 2.1 level AA makes no distinction between a contact form, a checkout process and a chat window: as soon as a visitor needs to be able to use it to place an order, ask a question or arrange something, the same criteria apply. This means, among other things, that the window must be operable using only a keyboard, that a screen reader must be able to read aloud what is happening in the chat, and that labels and buttons must not be indicated only by colour or an icon.

In practice, live chat is often one of the more challenging components to make accessible, because the content appears dynamically: new messages must be announced in a way that a screen reader can recognise, and the window must not trap focus or become inaccessible to keyboard users. Many chat widgets come from an external provider, but that does not change the requirement — the widget runs on your own site and counts as part of it. The same logic applies more broadly: also PDF invoices and order confirmations sent by the e-commerce site are subject to accessibility requirements, even if they are generated by a separate system.

Where this follows from: EN 301 549 and WCAG 2.1

The basis for this comes from EN 301 549, the European standard that brings interactive functionality on websites and apps under accessibility requirements without exception for specific components such as chat. In practice, that standard amounts to WCAG 2.1 level AA, and the criteria within it — on keyboard operation, status messages and recognisable operation — are formulated in a technology-neutral way, so they apply just as much to a chat window as to a menu or form. Whether a specific chatbot meets those criteria in some respects is something that an automated scan can only assess in part: dynamic content and the logic of a conversation cannot be fully tested by machine, and that applies to every scan, including the full one. Anyone who wants to know what that AA standard means in plain language for this type of component will find the explanation under what WCAG 2.1 level AA means in plain language.