A shopper who uses a screen reader reaches your checkout and finds a button that reads "button" and a field with no label. She leaves. You never learn why.
That story repeats across the web, and a growing number of laws now say it should stop. The European Accessibility Act applies to providers of e-commerce services to EU consumers, whether or not the provider is in the EU. National regulators gain enforcement powers, and consumers gain a right to bring claims. The technical reference is EN 301 549, which aligns with WCAG. (Bird & Bird)
If you sell to people in the EU, this applies to you. If you sell elsewhere, similar rules and lawsuits may already.
Why checkout comes first
Most of a store can be imperfect for a while. Checkout can't. It is where a shopper who has already decided meets a form, and any barrier there costs a sale you had already won. A product page can be worked around. A payment form cannot.
What good looks like
The Web Content Accessibility Guidelines, version 2.2, give specific tests. Here are the ones that matter most for a checkout.
- Labels and instructions. Every field has a visible label that is programmatically tied to it, so a screen reader announces "email address" and not just "edit text". (WCAG 3.3.2)
- Error handling. When something goes wrong, the error is identified in text, says which field, and suggests how to fix it. (3.3.1 and 3.3.3)
- Keyboard use. Everything works without a mouse, in a sensible order, and the focus is always visible. (2.1.1 and 2.4.7)
- Focus not hidden. A sticky header or cookie banner must not cover the field someone is typing in. (2.4.11, new in 2.2)
- Target size. Buttons and links are at least 24 by 24 CSS pixels, so a shopper with a tremor or on a small screen can hit them. (2.5.8, new in 2.2)
- No re-typing. Information already entered, such as a shipping address reused for billing, is offered again instead of demanded again. (3.3.7, new in 2.2)
- Sign-in without a puzzle. Authentication doesn't depend on solving a cognitive test, and password managers and paste work. (3.3.8, new in 2.2)
- Review before paying. For purchases with financial consequences, shoppers can check, correct or undo before the order is final. (3.3.4)
- Name, role and value. Custom components, such as a styled dropdown or a payment widget, tell assistive technology what they are and what state they are in. (4.1.2)
The last one causes the most trouble. Custom payment widgets and third-party embeds are where checkouts most often fail, because they are built outside your normal process.
The overlap with agents
A screen reader and a shopping agent need the same things from a page. Fields have labels, buttons say what they do, steps come in a predictable order, and errors name the field that caused them. Work done for one reader helps the other. An agent trying to complete a checkout is, in effect, a reader with no eyes, and it fails on the same defects.
That makes accessibility work a good use of money in two directions at once. The agent-readiness checklist includes a checkout question for this reason.
How to start
Run an automated scan across the whole site on a schedule, because it catches the same mistakes cheaply every time. Automated tools find only part of the problems, and the rest need people.
Then have people test the path from product page to payment by keyboard and with a screen reader. Add someone who uses assistive technology every day if you can. They will find things no scanner will.
Fix the checkout path first, then work outward. Add accessibility checks to your release process, so a new feature doesn't undo last month's repairs. The accessibility field guide sets out the method, including how regression monitoring keeps the gains.
Third parties
Your checkout probably includes parts you didn't build: a payment form, a booking calendar, a chat widget. Ask each vendor for their accessibility conformance report, test the embed yourself, and write the requirement into new contracts. A vendor who can't produce a report is telling you something.
A note on scope
Obligations depend on your size and sector, and the rules differ by country. Confirm which standard applies to you with a lawyer who knows the field.