The European Accessibility Act: what every Shopify store owner needs to know

The EAA is live. Your Shopify store is in scope.

The European Accessibility Act (Directive 2019/882) took full effect on 28 June 2025.^* If your Shopify store serves customers in any EU member state, you are legally required to meet accessibility standards, wherever your business is based.

This is the law right now. Germany’s market surveillance authority has been taking complaints since September 2025,^* and Sweden’s regulator began supervising e-commerce sites in October 2025.^*

How Shopify Markets can put you in scope without you realizing

If you use Shopify Markets to sell internationally, your store may already be serving EU customers, even if Europe was never part of the plan. Shopify Markets enables localized storefronts with currency conversion, local domains, and translated content. The moment a customer in Germany, France, or any EU member state can browse your store in euros and complete a purchase, you are providing an e-commerce service within the EU.

Many Shopify merchants enable international selling as a growth lever without considering accessibility implications. Under the EAA, it doesn’t matter whether you have a warehouse in Europe or a legal entity there. If the service is available to EU consumers, the law applies.

Check your Shopify admin under Settings → Markets. If you have active markets in EU countries, you are in scope.

What the EAA requires

The EAA mandates that e-commerce services be “perceivable, operable, understandable, and robust” for persons with disabilities. The technical standard used for it today is EN 301 549 version 3.2.1, which incorporates WCAG 2.1 AA; an updated version based on WCAG 2.2 was published in September 2026 and is awaiting formal citation.^*

In practical terms, your Shopify store must:

• Provide text alternatives for all non-text content (product images, icons, buttons)
• Keep sufficient color contrast between text and backgrounds
• Make all functionality available via keyboard, including quick-add buttons, size selectors and mega menus
• Use proper heading structure and landmark regions
• Label all form fields so screen readers can announce them
• Avoid keyboard traps in modals, drawers, and cart slideouts
• Provide captions or transcripts for video and audio content (including product videos)

The same items, with where each hides in a Shopify theme, are in the checklist.

What Shopify controls vs. what you control

Most of your Shopify store is your responsibility to fix.

Shopify controls checkout. For stores on Shopify’s hosted checkout (the vast majority), Shopify builds and tests checkout against WCAG 2.2 AA and publishes a conformance report for it, which still lists a handful of criteria as partially supported.^* Checkout extensions and custom scripts are on your side of the line.

You control everything else. Your theme templates (Liquid files), the apps you install, your product content, your navigation structure, your images and alt text: all of this is your responsibility. When regulators audit a store, they test the entire customer journey. If your product pages are inaccessible, the fact that checkout is compliant doesn’t help you.

Apps are the biggest blind spot. Every Shopify app that injects markup into your storefront (review widgets, upsell popups, chat bubbles, email capture modals) is code running on your store. If that code is inaccessible, you bear the liability, not the app developer. Most merchants have 10–20 apps installed, and the majority inject some form of front-end markup; accessibility drift shows how that compounds over a quarter.

The fines are large

Each EU member state sets its own penalties. Here are some of the numbers:

• Germany: up to €100,000 under the BFSG^*
• Netherlands: up to €900,000 or, if higher, 1% of annual turnover, doubled for a repeat within five years^*
• France: a fifth-class fine per infringement, €7,500 for a company and €15,000 on repeat, plus daily penalties under consumer-authority injunctions^*
• Spain: €301 to €1,000,000 under the general disability law that Ley 11/2023 falls back on^*
• Ireland: up to €60,000 and up to 18 months imprisonment on indictment^*

Enforcement bodies can also order a product or service withdrawn from the market.

The micro-enterprise carve-out is narrow

There is a limited exemption for micro-enterprises: businesses with fewer than 10 people and an annual turnover or balance sheet of no more than €2 million.^* Both conditions must be met. Most Shopify stores with meaningful revenue do not qualify.

Even if you do qualify today, the carve-out may not survive the first round of case law. Regulators have signaled that they expect accessibility from any business capable of providing it.

What you should do now

Understand your exposure. Go to Settings → Markets in your Shopify admin. If you have active EU markets, you are in scope. Then look at your installed apps under Settings → Apps and sales channels; every app that adds visible elements to your storefront is a potential source of violations.

Fix the code, not the surface. Accessibility overlays, the JavaScript widgets in the Shopify App Store that promise one-click compliance, do not satisfy the EAA. The law requires that the service itself be accessible. An overlay changes the presentation; it does not fix the underlying Liquid templates, CSS, or HTML.

Automate ongoing compliance. Accessibility breaks every time you update your Shopify theme, install a new app, or edit a product listing. Shopify stores are living, changing codebases. A one-time audit is necessary but insufficient. Continuous monitoring and remediation is the only way to stay compliant as your store evolves.

SiteRemora does this. We connect to your Shopify store, rescan it on a schedule and after changes, and fix violations directly in your Liquid theme files. When an app injects inaccessible markup, we catch it. When a new product image is missing alt text, we generate it. Every change is logged in a versioned audit trail you can hand to a regulator or lawyer. The fixes are applied to your theme code.

In short

The EAA is binding law. If you sell to EU consumers through your Shopify store, and Shopify Markets may have put you there already, your store must be accessible. The fines are large, enforcement is active, and the micro-enterprise exemption probably doesn’t apply to you. The technical requirements are well-defined, and fixing them is achievable. If you also sell to U.S. customers, the ADA question has the same answer and the same work.