localproblems.orgvol. 2026 · no. 33
P-0020

Czech e-shops and digital services are in the European Accessibility Act's first enforcement year — ČOI is test-purchasing checkout flows while most sites remain non-compliant

Category
Retail
Locality
Czechia · national
Updated
Created
Sources
02
Proof0/3UNPROVEN

no foreign analog.

Money0/2UNFUNDED

no budget attached.

Urgency3/3FORCING

compliance date <18mo (forcing function live) (2/2); newest source < 90 days (1/1).

S1 · reg-accessibility-act-cz · reg-scan · CZ · 2026-06-28Accessibility Act — first full enforcement year

European Accessibility Act as CZ zákon č. 424/2023 Sb., in force since 28 Jun 2025 — 2026 is the first full enforcement year. ČOI runs mystery-shopping test purchases on e-shops (whole checkout flow) and can order corrective measures and fines. Every non-micro CZ e-shop, bank, ticketing and e-book service must meet accessibility requirements now, not at a future date.

reg-accessibility-act-cz: European Accessibility Act as zákon č. 424/2023 Sb., in force since 28 Jun 2025; 2026 is the first full enforcement year — ČOI runs mystery-shopping test purchases across whole checkout flows and can order corrective measures and fines. Forcing function live: deadline 2.

S2 · complaint · 2026-08-13complaint — shop5.cz

E-commerce industry FAQ traffic (shop5.cz and peers) documents merchant confusion about scope and obligations — scattered but real industry pressure; demand scored 1.

Demand1/2SCATTERED

scattered complaints.

S2 · complaint · 2026-08-13complaint — shop5.cz

E-commerce industry FAQ traffic (shop5.cz and peers) documents merchant confusion about scope and obligations — scattered but real industry pressure; demand scored 1.

Gap0/2UNCHECKED

CZ incumbent check not done.

Total04/12FAINT

score = proof + money + urgency + demand + gap · every point is justified by a source on file · bands: PRIME 10–12 · STRONG 8–9 · FAIR 5–7 · FAINT 0–4

The problem

The European Accessibility Act became Czech law (zákon č. 424/2023 Sb.) in June 2025, and 2026 is its first full enforcement year: ČOI conducts mystery-shopping test purchases that walk entire e-shop checkout flows, with power to order corrective measures and levy fines. In scope: e-shops, banks, transport ticketing, e-book sellers and consumer-device makers — with an exemption only for micro-enterprises providing services. The Czech e-commerce sector, one of Europe's densest per capita, is largely non-compliant with WCAG-level accessibility.

Why now: the obligation is no longer approaching — it is live, and the enforcement mechanism is a regulator that shops your site. Merchant-facing FAQ content and industry confusion about scope show the market discovering the obligation only as enforcement starts.

Who pays: e-shops and digital-service providers buying audits, remediation and continuous monitoring; e-commerce platforms (Shoptet's ~30k+ merchants) are the structural channel — one platform integration reaches thousands of obligated shops at once.

Existing non-solutions: global accessibility-overlay vendors (accessiBe, UserWay) sell widgets of contested effectiveness and no Czech legal mapping; a handful of Czech agencies do manual audits at consulting prices. No productized CZ compliance offering with zákon č. 424/2023 mapping was verified this cycle (gap unchecked, scored 0).

Next moves: a gap check on Czech accessibility-tooling, a ČOI enforcement-statistics receipt (first fines would be a demand=2 upgrade), and a Shoptet-ecosystem probe to validate the platform channel.

Sources

  1. Accessibility Act — first full enforcement year
  2. complaint — shop5.cz