How to prepare your Shopify store for the European Accessibility Act

The Act covers “e-commerce services”: services provided at a distance, through websites and mobile apps, at the request of a consumer, with a view to concluding a consumer contract (Article 3(30)). It applies to services provided to consumers after June 28, 2025 (Article 2(2)). Nothing in that definition depends on where the seller is based.

So the question is who you sell to. Three things decide it for a Shopify store: whether EU consumers can order, whether you are a microenterprise, and whether you sell to consumers at all.

To check your own store, open Settings > Markets and look at which EU countries are active, then look at last year's orders by country in Analytics > Reports. If EU consumers can check out, the Act can apply. Our main European Accessibility Act guide covers the law itself in more depth.

A microenterprise employs fewer than 10 persons and has an annual turnover or annual balance sheet total of no more than 2 million euros (Article 3(23)). Microenterprises that provide services are exempt from the service accessibility requirements (Article 4(5)).

You need both conditions. A store with 8 staff and 3 million euros in sales is not a microenterprise. If your store is part of a larger group of companies, ask a lawyer how to count, because the group can matter. Even if you are exempt, marketplaces and EU retail partners may ask for accessible pages in their contracts, and accessible pages help every shopper.

The Act looks at the whole path a shopper takes to buy. On Shopify, that path is shared. Shopify publishes an accessibility conformance report for its checkout. The version dated March 2026 (checked October 17, 2026) rates 13 WCAG 2.2 A and AA criteria as “partially supports”, including contrast, focus visible and target size. It notes that PayPal, Venmo and Amazon Pay controls may create barriers, and says remediation is ongoing. Its disclaimer says merchants are responsible for making sure their store meets applicable laws, and it names the EAA.

Annex I, Section IV of the Act lists extra requirements for e-commerce. In plain words, and in Shopify terms:

• Product accessibility information. If a manufacturer gives you accessibility information about a product, such as whether a device works with a screen reader, show it on the product page (point (g)(i)). A product metafield works well for this. See the snippet below.
• Accessible identification, security and payment. Sign-in, account creation and payment must be perceivable, operable, understandable and robust (points (g)(ii) and (iii)). That covers your customer account links, any login app, and the payment step.
• The service itself. Your storefront must meet the general accessibility requirements. The accepted way to show that for a website is the harmonised standard EN 301 549, whose web section is WCAG 2.1 AA in version 3.2.1.
• Information and upkeep. Explain how your service meets the requirements (Annex V) and keep procedures in place so it stays that way after theme updates and new apps (Article 13).

The cookie banner

Most stores that sell in the EU show a cookie consent banner, and it is often the first thing a shopper meets. If a keyboard user cannot reach its buttons, or a screen reader cannot tell it is open, the shopper is stuck before seeing a product. Test it first: press Tab from the top of the page and check you can accept or decline without a mouse. If you use Shopify's own banner, its settings are under Settings > Customer privacy. If an app provides it, test that app.

Languages

WCAG asks that the page language is set correctly (criterion 3.1.1), so a screen reader reads French as French. Shopify themes set this from the shopper's language, as long as you publish the language in Settings > Languages. The common gap is content: alt text, button labels added by apps, and the accessibility statement stay in English while the rest is translated.

Payment buttons

Express payment buttons come from the payment provider. Shopify's own report notes partial support for some of them. You cannot fix their code, but you can make sure the standard checkout path works with a keyboard and a screen reader, so a shopper always has a way to pay.

Most fixes are settings and content. These two need a look at theme code, in Online Store > Themes > Edit code on your theme copy.

First, the page language. Open layout/theme.liquid and check that the opening html tag has a lang attribute like this. Shopify's Dawn and Horizon themes do. Older or heavily edited themes sometimes have a fixed lang="en".

Second, product accessibility information. Create a rich text product metafield in Settings > Custom data > Products (for example custom.accessibility_info), fill it in for products where the maker gives you this information, and show it on the product page. In most themes you can do this without code: in the theme editor, add a text or collapsible row block to the product template and connect it to the metafield. If your theme has no such block, a developer can add this:

Use a heading level that fits where you place it, so headings on the page stay in order.

• Assuming Shopify covers it. Shopify builds checkout. It does not fix your theme, content or apps, and it says merchants are responsible.
• Relying on a widget. An overlay toolbar does not change the code shoppers use. The barriers stay in the theme.
• Translating the store but not the alt text. A German shopper hears English descriptions, or none at all.
• An English-only statement. Publish the statement in each language you sell in.
• Brand colours that fail contrast at checkout. A pale accent colour on buttons or error text can make checkout hard to read.
• Showing a compliance badge. No badge or score proves you meet the Act. Describe what you have done and what is still open instead.

Give it an hour, on your home page, one collection, one product and the cart:

1. Run the free accessibility checker on each page. It finds the problems software can detect.
2. Put the mouse away. Use Tab, Shift+Tab, Enter and Space to accept the cookie banner, open the menu, pick a variant, add to cart and reach checkout. You should always see where you are.
3. Turn on a screen reader (VoiceOver on a Mac or iPhone, NVDA on Windows, both free) and listen to a product page in each language you sell in.
4. Zoom the browser to 200% and check that nothing is cut off or overlaps.
5. Repeat on a phone, with the screen reader on.

Automated checks cover only part of WCAG. In Deque's 2021 study, automated tests found about 57% of accessibility issues by volume, so the manual steps matter. The results of our Shopify theme tests show what usually fails.

There is no single EU regulator. Each country names authorities that check services, follow up complaints and verify fixes (Article 23), and sets its own penalties, which must be “effective, proportionate and dissuasive” (Article 30). Consumers, and associations acting for them, can also go to court or to an administrative body (Article 29).

• Germany. A joint authority of the 16 states, the MLBF in Magdeburg, has been fully responsible for enforcing Germany's law (the BFSG) since September 26, 2025, according to the Bavarian market surveillance office. The BFSG allows fines of up to 100,000 euros for the main violations.
• France. Two disability associations, apiDV and Droit pluriel, took large grocery retailers to court over their online shops. On May 5, 2026, a Lille judge dismissed the claim against Auchan's online store because its turnover was under the 250 million euro threshold in the French rule the court applied, while noting a generally low level of accessibility (Handicap.fr with AFP, May 7, 2026).

The French case shows that national rules differ, and that the people bringing claims are often shoppers' groups, not only regulators. Check the law in the countries where most of your EU customers live. The EAA checklist walks through what to have ready.