Since 28 June 2025, the European Accessibility Act (EAA), Directive (EU) 2019/882, applies to online shops that sell to consumers in the EU. If you run a Shopify store, this article explains who the rules cover, what you can rely on Shopify for and what remains your job, and how to check your store step by step.

Who the rules cover

The EAA is a directive: every EU country has turned it into its own law. For online shops, the rules cover e-commerce services, which means selling products or services to consumers through a website or an app.

  • Micro-enterprises are exempt. Under Article 4(5) of the directive, micro-enterprises that provide services do not have to meet the accessibility requirements. A micro-enterprise has fewer than 10 employees and an annual turnover or balance sheet total of no more than 2 million euros.
  • Countries differ in the details. In the Netherlands the rules are in the Civil Code and the ACM supervises them. In Belgium, micro-enterprises are outside the rules until 28 June 2030. In Germany the Barrierefreiheitsstärkungsgesetz (BFSG) applies, with the MLBF as the authority.
  • Selling in several countries? Check the rules of each country where you sell to consumers. The core requirements are the same, but the authority, the procedures and the fines differ.

If you are unsure whether you fall under the exemption, write down how you calculated it. That way you can show later why the rules do or do not apply to you.

What the EAA asks of an online shop

For a Shopify store, two obligations matter most.

An accessible service. Customers with disabilities must be able to find products, choose a variant, add items to the cart and check out, for example with only a keyboard or with a screen reader. The directive does not name a WCAG version itself. The European standard EN 301 549 follows the Web Content Accessibility Guidelines, and WCAG 2.2 at level AA is the current version of the common benchmark.

Information about accessibility. Annex V asks you to describe your service, how it works and how it meets the accessibility requirements, in your general terms and conditions or an equivalent document. National rules add to this:

  • the Dutch regulator ACM asks for a statement on your website and in your app, which you can also provide orally;
  • in Germany, the information must name the competent market surveillance authority, according to Annex 3 of the BFSG.

In practice this information is often called an accessibility statement. It works best when it is honest: name the standard you test against, the shortcomings you know about and when you plan to fix them.

What Shopify covers, and what stays with you

Shopify publishes accessibility conformance reports for parts of its platform. The report on the checkout is from March 2026 and is based on WCAG 2.2. For 13 criteria it says the checkout “partially supports” them. The same report states that merchants are responsible for making sure their online store complies with applicable laws, and it names the EAA.

So even the checkout, whose code you cannot change, is part of your responsibility. What you do control:

  • Your theme. It determines most of what customers see and use: the menu, product pages, the variant picker and the cart drawer. Every change to the theme code can make accessibility better or worse, and a theme update may not carry over your own code changes.
  • Your apps. Reviews, chat, pop-ups, cookie banners and filters all add parts to your store. Each of them can add new problems, such as a chat button that hides the focus or a pop-up you cannot leave with the keyboard.
  • Your content. Alt text for product photos, real headings and lists in product descriptions, clear link texts and captions for videos with speech.
  • Your checkout settings. Payment methods, extensions, texts and branding.

Why an overlay is not the answer

Some apps promise to make your store accessible with one line of code or a widget. Such an overlay puts a layer on top of your store, but the code underneath stays the same. A button without a name or a variant picker that does not work with the keyboard remains a problem for people who use their own assistive technology.

In April 2025 the US Federal Trade Commission ordered accessiBe to pay 1 million dollars. According to the FTC, the company had claimed its tool could make any website conform to WCAG. Accessibility is fixed in your theme, your apps and your content.

How to check your Shopify store

  1. Duplicate your theme and test changes in the copy first.
  2. Walk through your ordering flow with only the keyboard: home page, collection, product, variant, add to cart, search, login, contact form, cart page and the start of checkout. Can you reach and use everything, and do you always see where the focus is?
  3. Use a screen reader, such as VoiceOver on a Mac or iPhone, or NVDA on Windows. Listen for buttons without a name and for a message after adding to cart.
  4. Submit forms empty and with mistakes. Check whether the error messages are clear and linked to the right field.
  5. Zoom to 200 percent and look at your store on a narrow screen.
  6. Check the contrast of text, buttons and the borders of input fields.
  7. Look at your apps where they appear in the store.
  8. Check the checkout with the keyboard, including your payment methods and extensions.
  9. Repeat after every theme update or new app, and update your statement.

An automated scan is a useful start, but it finds only part of the problems. In our own measurements on a W3C demo site, our scanner found fewer than half of the known failures; judging titles, headings and the order of the page needs a human.

Write your accessibility statement

With the free statement generator you create a web version, an annex to your terms and conditions or a short version for customer service, in English, Dutch, German or French. It names the right authority for the Netherlands, Belgium and Germany. Everything stays in your browser.

Help from an app

The Shopify app from this website walks through your ordering flow up to the start of checkout and never places an order. It tests with axe-core and with its own tests for keyboard use, focus, forms and messages, and gives you a report with priorities and fix examples in Liquid and CSS. You apply those examples yourself: the app does not change your theme. It remains an automated and partial test, so combine it with your own checks.