Your EU ecommerce site doesn’t legally require a dark mode by the 28th June 2025

Last time around, I talked about the probable requirement for dark mode in ecommerce sites under the European Accessibility Act. The situation has now changed somewhat.

After a lengthy thread on ETSI’s GitLab, a decision has been made: section 11.7 has been reworked to not mention web apps and sites, and the list of preferences has been removed in favour of talking about purely “platform documented accessibility features”; that is, the features a platform specifically considers are accessibility functions. For all current platforms apart from Android this then excludes dark mode.

Obviously, this is for a future version of EN 301 549, and the European Accessibility Act when it comes into effect on will use version 3.2.1. We still don’t know what the regulators will choose to enforce then, but given that this potential requirement has been clarified for a future version I would assume that the regulators won’t have an appetite to be too forceful on this point.