The European Accessibility Act (EU) 2019/882 is a directive, not directly applicable legislation. This means each Member State has transposed the text into its own national law. The technical requirement that follows is in practice the same everywhere: EN 301 549, which amounts to WCAG 2.1 level AA. But the system around it — who supervises, where you report, what the declaration must look like and what sanctions apply for non-compliance — is set out in each country's own transposition law, and that varies.
For a webshop selling to customers in multiple EU countries, the general principle is that the legislation of the country of establishment applies, not that of every country from which a customer comes. This is a general principle in the directive itself; how it applies in a specific case depends on where the business is actually established and what the competent authority says about it. For your own situation, this is something to clarify with a legal advisor or the authority in your country of establishment.
What stays the same everywhere
The substantive standard does not change by country. A checkout process that cannot be navigated with a screen reader, a form without labels or a colour contrast that is too low remains a problem regardless of whether the visitor is from the Netherlands, Germany or Portugal. The directive is designed precisely so that this technical standard is identical across the Union, so that a service that is accessible in one country is in principle also accessible in other Member States. To see how this looks in practice for your own site, you can see in five questions where you stand.
What does differ by country
Three elements are determined nationally and vary. First, the authority: each country has its own designated body responsible for overseeing compliance, with its own procedures and priorities. Second, the complaint procedure: where and how a complaint is received, and what steps follow, differs by transposition law. Third, the format of the mandatory accessibility declaration: some countries prescribe a fixed template, others allow more flexibility in form as long as the content is complete. An overview of what this means concretely in each country is set out in the knowledge base with the requirements for each situation and country.
Germany: supervision plus an additional route
One difference stands out. In most Member States, enforcement occurs solely through the public authority. Germany also has the Abmahnung: a warning letter that does not come from a government body, but from a competitor, industry association or consumer organisation, requesting that the alleged breach be remedied and often including a cost claim. This is a private law mechanism that exists alongside public supervision and which other Member States do not have in this form. For those also supplying the German market, this is a reason to look somewhat more carefully at what is on the site, regardless of whether the German authority itself has raised an issue.
What this means for a webshop with multiple sales markets
In practice, it comes down to this: the substantive assessment — does the checkout, the account, the forms comply with WCAG 2.1 AA — needs to be done only once, while the administrative side — which declaration, to which authority, in which format — requires attention for each country in which you operate. That is precisely why a generic checklist falls short once an organisation sells beyond its own borders: the technical findings are reusable, the administrative handling is not. An example of how such an implementation looks is on the page where the information in the report comes from.
Check for yourself what applies to your organisation
The scope check and quick scan are free and can be completed without an account, and show whether the directive is relevant to your service and where the first issues lie. For the country-specific implementation — the authority, the notification route and the declaration format for each country in which you operate — the subscription is intended; what this includes is on the pricing page showing what is included per component. If you are uncertain about where exactly to begin, the frequently asked questions about scope and oversight provide a quick answer to many of those questions.
If you wish, start with the free scope check and quick scan to see whether the directive applies to your organisation and where the first points of attention lie — the country-specific details can follow.