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Digital accessibility law: what your online shop needs to implement

From 1 July 2025, all online shops in Portugal must comply with specific digital accessibility requirements. This requirement, which stems from the transposition of the European Accessibility Directive and Decree-Law No. 83/2018, represents a fundamental change in the way businesses must structure their digital presence.

This guide examines the practical implications of this legislation, the risks of non-compliance, and sets out a clear roadmap for ensuring compliance.

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Who is covered by the new legal framework?

The legislation applies to all organisations that offer products or services via websites or mobile apps, regardless of the size of the business. This means that everyone – from sole traders with a small online shop to large e-commerce platforms – must ensure they comply with the new requirements.

The deadlines are clear: existing websites must be compliant by 1 July 2025, whilst new websites must be accessible from the outset. For mobile applications, there is a transitional period until December 2025.

Compliance is based on the Web Content Accessibility Guidelines (WCAG) 2.1, Level AA. These international standards set out objective criteria to ensure that digital content is perceivable, operable, understandable and robust for all users, including those with visual, hearing, motor or cognitive impairments.

Penalties: the cost of non-compliance

The penalty system is progressive but severe. For serious administrative offences, fines range from €500 to €5,000 for micro-enterprises and may reach €20,000 for large companies. In cases of repeated non-compliance or refusal to rectify the situation – which are considered very serious administrative offences – the fines are doubled, with maximum fines of up to €50,000.

The direct financial consequences are only part of the problem. Non-compliance can result in significant reputational damage, the loss of public contracts that require proof of compliance, and potential civil liability for discrimination. Furthermore, by excluding around 20% of the Portuguese population who have some form of functional limitation, companies lose access to a substantial market segment.

Essential Requirements

Practical implementation is organised around four key principles. The content must be noticeable, ensuring that all images have alternative text, that videos include captions, and that the contrast between text and background is adequate. The interface must be operational, allowing full navigation via the keyboard and providing sufficient time for interactions.

The information must be understandable, using clear language and providing instructions where necessary. Finally, the code must be robust sufficient to work with assistive technologies such as screen readers.

Critical Elements in E-commerce

In the specific context of online shops, three areas require particular attention. The product catalogue needs comprehensive descriptions for all images, clear pricing information and filters that work without a mouse. The checkout process should feature forms with clear instructions, specific error messages and an accessible confirmation before finalisation. The shopping basket must allow for easy updates and provide clear feedback on items being added or removed.

How to Check Compliance

Using the Official Portal

The acessibilidade.gov.pt portal provides the AccessMonitor validator, an essential tool for an initial assessment. The process is simple: access the validator, enter your shop’s URL, review the detailed report and identify the critical errors that need to be corrected as a priority.

It is important to understand that automated validation may not detect all issues. Full compliance requires supplementary manual testing, validation using assistive technologies and, ideally, testing with real users.

Accessibility Statement

All online shops must publish an Accessibility Statement setting out their compliance status, elements that are not yet accessible along with the reasons why, available alternatives where applicable, and contact details for feedback. This document must be easily accessible from the website’s footer.

Implementation Strategy

The most effective approach is a phased one. Start with a comprehensive assessment using automated tools and identifying critical barriers. In a second phase, rectify the urgent issues that prevent basic use, such as a lack of keyboard navigation or insufficient contrast. Subsequently, systematically implement all the requirements for full compliance. Finally, establish ongoing maintenance processes to ensure that new content meets accessibility standards.

How Ascend Can Help

Ascend Marketing Solutions has developed a specific methodology to ensure efficient compliance with the Digital Accessibility Act. Our process begins with a comprehensive audit that identifies all instances of non-compliance and sets out a prioritised action plan.

The technical implementation involves code correction, the development of accessible components and optimisation for assistive technologies. We complement this with training for in-house teams to ensure that future content meets the necessary standards. The entire process culminates in the preparation of compliance documentation and the establishment of processes for ongoing monitoring.

Our experience shows that compliance with accessibility requirements not only helps to avoid penalties but also significantly improves the experience for all users, boosts SEO and expands market reach.

Immediate Action Required

With the penalties already in force, every day counts. The technical complexity of the requirements and the need for specialist validation mean it is advisable to seek professional support. Attempting to implement the requirements without the appropriate expertise often results in only superficial compliance, leaving organisations vulnerable to inspections.

Ascend offers a free initial assessment which includes automated testing of your shop’s main pages, identification of the most critical barriers, and a proposed action plan with an estimated investment.

Don’t put compliance off until later. Protect your business and demonstrate a genuine commitment to digital inclusion.

References

1. ACEPI - Digital Economy Association (2023). Report on E-commerce in Portugal.
2. Marketeer.pt - National E-commerce Trends 2023.
3. INE - National Statistics Institute data on e-commerce.
4. Bank of Portugal - Digital Payments Statistics 2023.
5. WooCommerce Usage Statistics - BuiltWith Technology Lookup.

Frequently Asked Questions

Yes, the law applies to all online shops, regardless of their size or turnover. There are no exemptions for small businesses.

As the shop owner, you are always legally responsible. The platforms provide tools, but it is up to you to ensure that all content and customisations comply with the requirements.

For a typical shop: diagnosis within 1–2 days, urgent fixes within 2–4 weeks, full compliance within 1–3 months. The complexity of the website directly affects the timeframe.

Not entirely. Automated tools only detect some of the issues. Manual validation and testing with assistive technologies are required to ensure full compliance.

Focus first on the purchase flow: home page, catalogue, product page, shopping basket and checkout. These are the most critical pages for the business and the ones most likely to be checked.

On the contrary. Well-implemented accessibility is seamless and often enhances the overall experience through better structure, clearer navigation and greater ease of use.

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