You are spot on here.
The legal requirement is not specifically to have a customer account. It is to, and this is my own translation, “allow users to access their orders and correct mistakes if necessary”. By “correcting mistakes”, I don’t think they mean like cancel the order - although in some cases this might apply - but more be able to do things like updating contact details for exemple.
So from a technical approach, to me this means :
- Creating a “customer account” who’s data is retain by the store is not mandatory. Users could just to the purchase as “guests”.
- But, from a functionality point of view, this means customer should have a way of accessing their order details and make some changes, which feels pretty close to a customer account functionality (but I’m no dev, so I could be wrong here)
PS : and for orders for 120€ or more, the store should keep the order data accessible for at least 10 years…