A service agreement that was already running before 28 June 2025 does not need to be renegotiated immediately to meet the new requirements. The directive provides a transition arrangement for this: agreements that existed on that date may in principle continue unchanged until the end of their term, with 28 June 2030 as the absolute deadline. A contract concluded or renewed after 28 June 2025 does not fall under that exception and must comply with the requirements of EN 301 549 from the start.
This is a different question from whether your webshop itself must already be accessible. The transition arrangement concerns the agreement with a supplier, not the obligation that rests on you as the provider of the service. In other words: an old contract with your website builder may formally still fall under the exception, while the legal obligation to be accessible for your own webshop already applies as of 28 June 2025, unless you fall under the exemption for micro-enterprises.
What the transition arrangement does and does not cover
The logic behind the arrangement is practical: companies that concluded a multi-year contract with a supplier just before the implementation date for, for example, their ordering system or content management system, do not need to immediately renegotiate or reopen that contract. As long as the agreement continues unchanged, there is flexibility until 2030 at the latest.
That flexibility does not automatically apply to everything that happens between you and that supplier. An extension, a substantial change to the service, or a new module that is added, can cause the exception to lapse for that part of the agreement. Supervisory authorities and courts look at the nature and scope of the change, not the date the original contract was signed. A minor maintenance update is different from a new billing module.
Your own obligation continues regardless
Even if a supplier contract formally falls under the transition arrangement, that does nothing to change the obligation that rests on you as the provider. The directive is directed at the party offering the service to the consumer, not at the subcontractor providing the technology. A retailer who has their webshop built by an external agency remains personally responsible for the accessibility statement and for demonstrating their own assessment.
In practice, this means that an old contract with a supplier does not exempt you from the question of whether your checkout process, your login environment and your forms are usable with a screen reader or keyboard alone. Where exactly the boundary lies between what an ongoing contract covers and what remains your own responsibility is a question that varies from situation to situation and for which a lawyer or the competent supervisory authority is the right party to consult.
Why waiting until 2030 is rarely wise
Even when a contract formally still falls under the exception, deferring action until the last month before 2030 is not advisable for practical reasons. Accessibility rarely affects a single isolated module; it usually involves underlying templates, the theme of the webshop and the way forms are structured. The longer that is left unaddressed, the more work it will be to fix everything at once just before a hard deadline.
Moreover, a supplier contract often changes more frequently than expected: a migration to a new version of the platform, a switch to a different hosting provider or an expansion of product range can already be enough to be considered a change to the original agreement. From that point on, the original contract date no longer applies as the starting point.
What you can do now
It makes sense to know, independently of your contract's legal status, where your web shop currently stands. A quick scan shows the most common issues on a handful of core pages, without requiring you to create an account. That gives you an honest picture, even though an automated scan does not test everything the standard requires.
If you want to know whether your specific situation, including an ongoing supplier contract, falls under the transition arrangement or not, that is a question for a lawyer or for the market surveillance authority in your country. What you can document yourself, such as your own assessment and improvement plan, you will find back in the knowledge base with explanations per situation. For the question of when a scan is and is not sufficient, the page about where the information in a report comes from is a good starting point, and frequently asked questions about data and transition periods are collected under frequently asked questions.
Are you curious about how your own webshop is performing right now, regardless of what your supplier contract stipulates? Take the free quick scan and then review which topics are relevant to your situation via get an initial indication in just a few minutes.