Accessible invoices, terms and forms in online shops
Invoice, order confirmation, terms and conditions, withdrawal form: almost every online shop sends these as PDFs. A shop that sells to consumers falls under the European Accessibility Act, and those PDFs are part of what has to be accessible.
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This page is not legal advice. Whether your offering is in scope and which documents belong to it depends on the individual case.
How online retail compares with other sectors is shown in Affected industries. The legal basics are in The European Accessibility Act and PDFs.
When a shop is covered
Article 3(30) of Directive (EU) 2019/882 describes e-commerce services as services provided at a distance, through websites and mobile device-based services, by electronic means and at the individual request of a consumer with a view to concluding a consumer contract. Austria adopted this in section 3(27) BaFG. Germany's BFSG refers in section 2(26) to digital services within the meaning of the German Digitale-Dienste-Gesetz (DDG), with the same core features.
That takes in the classic online shop, and equally any other website or app through which consumers conclude contracts, such as a booking portal or a subscription service. A purely B2B shop that sells only to businesses is generally not covered. Once private individuals can order as well, that changes.
Annex I Section IV of the directive adds points specific to e-commerce on top of the general service requirements. The shop has to provide information on the accessibility of the products and services it sells, where the responsible economic operator supplies that information. Identification, security and payment functions have to be accessible, and so do the identification methods, electronic signatures and payment services on offer. Germany implemented this in section 19 BFSGV, Austria in Annex 1 to the BaFG.
Invoices come out of a system
No PDF is produced more often in a shop than the invoice, and hardly ever by hand. Many shop extensions and ERP systems output PDFs with no tag structure at all. The text is there, but a screen reader reads address fields, table cells and totals in random order. Ask your vendor directly whether its PDF output supports tagged PDFs according to PDF/UA. For in-house solutions, look at the PDF library you use: many can tag if the feature is switched on and used in the template.
E-invoices in the ZUGFeRD or Factur-X format are PDF/A-3 files with embedded XML data. That is compatible with PDF/UA. One file can meet both standards at once, provided the generator supports it.
Whether a sample invoice has tags, a title, a language and properly embedded fonts at all is something a PDF/UA check shows within seconds. If you have many invoice variants, the check can go into tests or deployments via the API (Premium).
What else goes out as a PDF
| Document | Usually produced in | What to watch for |
|---|---|---|
| Invoice, credit note | Shop system, ERP or invoicing plugin | Line item table with header row, totals clearly assigned, title and language set |
| Order confirmation, delivery note | Shop system | Reading order of address block, order number and item list |
| Terms and conditions, privacy notice | Word or content management system | Heading hierarchy, lists, bookmarks for longer texts |
| Withdrawal information and withdrawal form | Word, template from a legal text service | Fillable fields with labels, tab order, an alternative to printing |
| Product data sheet, user manual | Manufacturer, PIM system | Technical data tables, images with alternative text |
| Warranty terms, return label | Manufacturer, shipping provider | Return labels are often just graphics and a barcode; the information should also be available as text |
The withdrawal form
Many shops offer the model withdrawal form from the Consumer Rights Directive 2011/83/EU as a fillable PDF. For it to work with a screen reader and a keyboard, it needs four things:
- an accessible label for every form field (tooltip or field description) that the screen reader announces,
- a tab order that follows the visual order,
- fields anchored in the tag structure rather than sitting on the page as loose annotations,
- required fields and format rules (such as for dates) that can be identified in the text, not only by colour.
An accessible HTML form in the customer account is often friendlier to use, with the PDF as an extra option. EasyPDFUA does not check form fields in detail and does not tag them; for that you need a PDF editor or the source file. What else to check is in the accessible PDF checklist.
Who is responsible for user manuals
Product duties and service duties run side by side here, and it pays to keep them apart.
For covered products such as computers, smartphones, tablets, e-readers or certain terminal equipment, the duty lies with the manufacturer. Instructions it provides, for example via a website, must be accessible, including in text formats that can be used to generate assistive formats (Annex I Section II of the directive). Before selling, the distributor checks that, among other things, the CE marking and the required documents are present. It must not make available products it has reason to believe are non-compliant.
For products not covered, such as furniture, clothing or household appliances, the EAA's product duties do not apply. If a shop offers their manuals as PDFs on its product pages, the question remains whether they form part of its e-commerce service. That has not been settled.
Data sheets and manuals usually come from the manufacturer, and a retailer can change little about them. Ask suppliers for accessible versions. Your own documents, meaning invoices, terms and forms, are your job either way.
Small shops and older files
Microenterprises with fewer than 10 employees and no more than EUR 2 million in annual turnover or balance sheet total are exempt as service providers (Article 4(5) of Directive 2019/882, section 6 BaFG, section 3(3) BFSG). Manufacturers and distributors of products cannot rely on this.
PDFs published on the website before 28 June 2025 and archive content that is no longer updated are exempt as well. That does nothing for invoices and order confirmations, which are generated continuously. National details are in BaFG in Austria and BFSG in Germany.
Where shop PDFs usually fall short
The invoice has no tag structure because the plugin never produced one. The withdrawal form has unlabelled fields. The return label is nothing but a graphic and a barcode. And a missing document title often goes unnoticed until someone opens the file with a screen reader.
EasyPDFUA finds the technical gaps: missing tags, title and language, fonts without Unicode mapping and links that are not part of the structure. For individual untagged documents without a source file, such as an older version of your terms, retroactive tagging can add a base structure. Invoices are a different matter. Tables, headings and form fields are not reconstructed semantically, so for tabular high-volume documents there is no way around fixing the generator.
Frequently asked questions
Do online shop invoices have to be accessible?
Yes, if the shop is covered and the invoice goes to a consumer after 28 June 2025. Invoices and order confirmations are part of the service. An adapted template in the shop or ERP system is the least effort.
Does the EAA apply to B2B online shops?
Not to purely B2B shops that sell exclusively to businesses, as a rule. If private individuals can also order, the shop is usually in scope.
Are small online shops exempt?
As service providers, yes, if they have fewer than 10 employees and no more than EUR 2 million in annual turnover or balance sheet total. Product duties for manufacturers and distributors of covered products still apply.
Who is responsible for accessible user manuals?
For products covered by the EAA, primarily the manufacturer. Distributors must check certain points before selling. For products not covered, the product duties do not apply.