European Accessibility Act on Shopify: check if it applies, then fix what buyers touch

Before you buy a Shopify accessibility app, answer three questions. The European Accessibility Act (EAA) only reaches your store if all three are yes:

1. Do you sell to consumers? The EAA covers e-commerce "with a view to concluding a consumer contract" (Art. 3(30)). A wholesale-only store is a different reading; ask your lawyer.
2. Do you offer to buyers in the EU? Where you are based doesn't matter. Offering to consumers in the Union does (Art. 3(4)).
3. Are you bigger than a microenterprise? A microenterprise employs fewer than 10 people and has turnover or balance sheet total of EUR 2 million or less (Art. 3(23)). Microenterprises providing services are exempt (Art. 4(5)).

Three yeses: the rules below apply to you now. Since 28 June 2025 (Art. 2(2), 31(2)). The 2030 transition covers only products already in use and contracts agreed before that date, so it rarely helps a storefront (Art. 32).

Exempt? Write it down with your figures and re-check yearly.

Not legal advice. This guide follows the directive's text. Your national law and your lawyer decide the edge cases.

What the EAA requires from a store in scope

1. A storefront people can use with a keyboard and a screen reader: perceivable, operable, understandable and robust (Art. 4(3), Annex I §III and §IV(g)).
2. Login, security and payment that are accessible too, not only the product pages (Annex I §IV(g)(ii), (iii)).
3. Product accessibility information, where the manufacturer provides it (Annex I §IV(g)(i)).
4. A public explanation of how you meet the requirements, in your terms and conditions or an equivalent document, in written and oral format, kept for as long as the store runs (Art. 13(2), Annex V).
5. Procedures that keep it that way when your store, the requirements or the standards change (Art. 13(3)).
6. Corrective action when something fails, and an immediate notice to the authority in each country concerned (Art. 13(4)).

The directive names no technical standard. In practice the measure is EN 301 549, which maps to WCAG. Version 3.2.1 (WCAG 2.1 AA) is the one cited in the EU Official Journal. Version 4.1.1 (WCAG 2.2 AA) was published on 2 September 2026 and, as of 21 October 2026, is not yet cited.

Build to WCAG 2.2 AA now. It contains 2.1 AA, so it covers both versions.

The problem: Shopify covers its part, not yours

Shopify's checkout is tested; your theme and apps are not. Shopify's accessibility statement (opens in a new tab) names its own services under the EAA, and its checkout conformance report (opens in a new tab) covers WCAG 2.2 A and AA. Your theme edits, sections and every app that renders on the storefront are yours.

Skipping it has a price, set per country. The directive asks for penalties that are "effective, proportionate and dissuasive", together with remedial action (Art. 30). National law must let consumers and associations take you to court or to the authority (Art. 29).

How it looks on a real store

An external accessibility audit came back on a mid-size store with configurable products. The high-severity findings were not in the checkout. They were in the parts every buyer touches:

• Variant swatches and size pickers that a keyboard couldn't reach or a screen reader couldn't name.
• Icon buttons (cart, search, close) with no name.
• Links acting as buttons, and the other way round.
• No visible focus, so a keyboard user lost their place.
• Images without useful alt text.

The fix was code, not an overlay. Focus styles, labels, real <button> elements, alt text and headings: about 40 theme files in one branch. Every change was checked with a keyboard and a screen reader before merging.

What we learned:

• A scan alone is not enough. Automated tools cover a third of WCAG criteria to 57% of issues, depending on how you count. The manual pass is not optional.
• Theme updates overwrite patches. Keep the fixes in a branch and re-check after every update.
• Apps are someone else's code. Ask each vendor for an accessibility conformance report.

Set it up yourself: 8 steps on Shopify

1. Run the scope test. Write down your three answers with the date and figures.

2. List what to test. Home, collection, product, cart, checkout, plus search, login and contact. Then every app that renders on the storefront or in checkout (Online Store → Themes → Customize → App embeds).

3. Scan. Run axe DevTools (opens in a new tab) or Lighthouse on each template, desktop and mobile. In checkout, use the WAVE extension (opens in a new tab) in your browser.

4. Unplug the mouse. Tab through the menu, drawers, variant pickers, cart, discount field and form errors. Then 60 seconds with VoiceOver or NVDA. Focus must stay visible, never trapped.

5. Fix in order: theme, apps, content.

• Theme: critical and serious first, in a duplicate theme.
• Apps: keep, configure, replace with a native Shopify feature (Search & Discovery, Shopify Forms, Shopify Inbox) or remove.
• Content: alt text on product images, captions on videos, contrast of 4.5:1 for text. PDFs published after 28 June 2025 must be accessible too, or rebuilt as pages (Art. 2(4)(b)).

6. Check what you control in checkout. Branding colours and contrast, checkout UI extensions, and your payment providers. Their 3-D Secure and redirect pages are theirs: ask for their report.

7. Publish an accessibility page. Footer link on every template, linked from your terms (Annex V). Include:

• what the store sells and how to use it, including with assistive technology;
• the standard you test against, what you tested, when, and the known gaps with fix dates;
• how you keep it accessible;
• a contact for accessibility problems and an oral channel, such as your phone line.

Never write "fully compliant." Write what passes and what is open.

8. Make it a gate. Every release and every new app gets the keyboard test and a scan before it goes live. Re-scan monthly, re-audit yearly and after a redesign.

Where this applies

Any store past the microenterprise line that sells to EU consumers, wherever it's based. Ask:

1. Can a buyer choose a variant and pay using only a keyboard?
2. Is there an accessibility page linked from your terms?
3. Does every new app get checked before it goes live?

Any no: start with steps 4 and 7.

Sources: Directive (EU) 2019/882 (opens in a new tab) · BFSG §37 (opens in a new tab) · Polish Act of 26 April 2024 (opens in a new tab) · Shopify accessibility statement (opens in a new tab) · WCAG 2.2 quick reference (opens in a new tab)