European Accessibility Act: a 30-minute Shopify checklist
Check a Shopify store against the European Accessibility Act in 30 minutes: automated scan, keyboard walk, alt text, contrast, checkout and your statement.
Thirty minutes is enough to find the barriers that most often stop shoppers with disabilities on a Shopify store, and to see roughly how far you are from what the European Accessibility Act (EAA) asks. It is not enough to prove anything. Treat this checklist as a first measurement: run it, write down what you find, then fix and test properly.
Does the European Accessibility Act apply to my Shopify store?
The EAA is Directive (EU) 2019/882. It covers e-commerce services: services sold at a distance, through websites and mobile apps, to consumers. Member states had to write it into national law by 28 June 2022, and those laws have applied since 28 June 2025.
Three things decide whether it reaches you:
- Who you sell to. The directive covers services offered to consumers in the EU. A store based outside the EU that offers products to EU consumers can be covered, so check the national law in the countries you ship to.
- How big you are. Microenterprises that provide services are exempt. The directive defines a microenterprise as an enterprise with fewer than 10 persons and an annual turnover or annual balance sheet total not exceeding EUR 2 million. Above that, there is no size exemption.
- Consumers, not businesses. The EAA is about consumer contracts. A store that sells only to other businesses isn’t an e-commerce service in the directive’s sense.
Our full guide to the European Accessibility Act for online stores goes through the details, including transition periods and penalties.
What does the EAA ask an online store to do?
The directive doesn’t list technical checks. Annex I asks service providers to make their websites and mobile services accessible “by making them perceivable, operable, understandable and robust”, the same four principles that organize the Web Content Accessibility Guidelines (WCAG). For e-commerce services, Annex I adds three specific points:
- give information about the accessibility of the products and services you sell, when the responsible economic operator provides it;
- make the functions for identification, security and payment accessible, so that logging in, proving who you are and paying are perceivable, operable, understandable and robust;
- offer identification methods, electronic signatures and payment services that are perceivable, operable, understandable and robust.
Article 13 and Annex V add a paperwork duty. Service providers have to prepare information that explains how the service meets the accessibility requirements, and include it in their general terms and conditions or an equivalent document: a general description of the service in accessible formats, what’s needed to understand how the service works, and a description of how the Annex I requirements are met. That information has to stay available for as long as the service is offered.
The technical bridge between the law and your store is the European standard EN 301 549. Version 3.2.1 is built on WCAG 2.1 Level AA. Version 4.1.1, published on 2 September 2026 for the EAA, moves to WCAG 2.2 Level AA, and it gives a presumption of conformity once the European Commission cites it in the Official Journal. WCAG 2.2 builds on 2.1, so the practical target is simple: work toward WCAG 2.2 Level AA.
The 30-minute checklist
Set a timer for each step and write down what you find as you go. You need your store open in one browser tab, your Shopify admin in another, and nothing else.
Minutes 0 to 5: run an automated check on four pages
Open the free website accessibility checker and check your home page, one product page, one collection page and your cart page. It runs Google Lighthouse’s accessibility checks and lists every failing check with the WCAG criterion it affects.
Note the score for each page and the top three issues. Missing alt text, low-contrast text, unnamed icon buttons and unlabeled fields are the usual results, and each one maps to a criterion you’ll meet when you fix it. A score of 100 means the automated checks passed, not that the page is accessible, which is why the next 25 minutes exist.
For Shopify stores
Find and fix accessibility issues on your store
CodeInspire Accessibility Tool adds an accessibility widget for your shoppers, audits your pages against WCAG, and gives you step-by-step fixes for your Shopify admin, theme editor or theme code.
Minutes 5 to 10: walk the shopping path with a keyboard
Put the mouse away. Starting on your home page, use only Tab, Shift+Tab, Enter, Space and the arrow keys to open the menu, reach a collection, open a product, choose a variant, add it to the cart, open the cart and start checkout.
Three things to watch for:
- You can always see where you are. Every link, button and field shows a visible outline when it has focus (2.4.7 Focus Visible, Level AA).
- You can reach and use everything, including the menu drawer, variant swatches, the quantity buttons and the cart drawer (2.1.1 Keyboard, Level A).
- Nothing swallows the keyboard. Pop-ups and drawers close with Escape, and you are never stuck (2.1.2 No Keyboard Trap, Level A).
Anything that fails here is a barrier for shoppers who use a keyboard, a switch device or a screen reader. Our keyboard accessibility guide explains the fixes.
Minutes 10 to 15: check a sample of product images
In your Shopify admin, open five products from different collections. For each one, click a media item and look at its alt text. Every image that carries information needs a text alternative that says what a shopper needs to know (1.1.1 Non-text Content, Level A).
Bad: IMG_2291.jpg
Bad: (empty)
Good: Brown leather ankle boot with a side zip, seen from the side
If three of your five products have missing or useless alt text, assume the rest do too, and plan a catalog-wide pass. Our guide on adding alt text to all Shopify products at once shows how to do that with a CSV export instead of product by product.
Minutes 15 to 20: check your theme’s colors
Go to Online Store › Edit theme › the settings icon › Colors. Most current themes manage colors as schemes. For each scheme, put the text color and the background color into the free contrast checker. Normal text needs a ratio of at least 4.5:1 and large text 3:1 (1.4.3 Contrast (Minimum), Level AA). Check button labels on button colors too, and the muted color your theme uses for prices, compare-at prices and footer text.
One fix in a color scheme corrects every section that uses it, so this is often the quickest win on the list.
Minutes 20 to 25: forms, pop-ups, apps and checkout
Look at the places where other people’s code meets yours:
- Forms. The footer newsletter box, the search field and the contact page. Each field needs a visible label, not just placeholder text (3.3.2 Labels or Instructions, Level A).
- Pop-ups. Open any discount, newsletter or cookie pop-up with the keyboard. Focus should move into it, Escape should close it, and focus should come back to where you were.
- Apps. Reviews, chat, size charts, upsells and wishlists are part of your store once they’re installed. Tab through each one.
- Checkout. Shopify controls most of the checkout and publishes an accessibility conformance report for it, dated March 2026, against WCAG 2.2 Levels A and AA. It lists a few criteria as partially supported. You can’t change those parts, but the EAA’s points about identification and payment make checkout worth a keyboard run of your own, including any express payment buttons and checkout apps you’ve added.
Minutes 25 to 30: your statement, your terms and a contact
The last five minutes are about the information duty. Check three things:
- An accessibility statement that says which standard you aim for, what you know doesn’t work yet and how to reach you. Our accessibility statement guide has a template, and the free statement generator builds one you can paste into a Shopify page.
- Your terms and conditions, or an equivalent document, describe how your store meets the accessibility requirements, as Annex V asks. A short section that links to the statement is a reasonable start; ask your lawyer what the national law expects.
- A contact method for accessibility problems that someone actually reads, listed in the statement and in the footer.
If none of these exist yet, you now have the first item on your to-do list.
What won’t 30 minutes tell you?
Be honest with yourself about the limits of a quick check:
- Automated checks find a fraction of problems. W3C notes that evaluation tools “cannot check all accessibility aspects automatically” and that “human judgement is required.” A clean scan is a start, not a result.
- A keyboard walk isn’t a screen reader test. VoiceOver on a Mac or iPhone, or the free NVDA on Windows, shows you whether product names, prices, variants and the add-to-cart button are announced clearly. That takes longer than five minutes, and it’s the test that matters most for blind shoppers.
- A sample isn’t your catalog. Five products tell you whether you have an alt text problem, not how big it is.
- The law is national. Each member state sets its own enforcement and penalties. The directive only requires them to be effective, proportionate and dissuasive, and it names no amounts. What counts as meeting the requirements, and what happens if you don’t, depends on where you sell.
- Nothing here is a certificate. No scan, checklist or app makes a store compliant, and anyone who tells you otherwise is selling something.
What should you do after the 30 minutes?
Turn your notes into a plan ordered by who each problem blocks: keyboard and screen reader barriers first, then alt text, then contrast, then the rest. Fix what you can in the theme editor and the Shopify admin, send the theme code items to a developer, and re-run the checks after each change. Publish your statement with the known issues listed, update it as you fix them, and keep a dated record of what you changed. Then repeat the 30 minutes every quarter and after every theme update or new app.
If you haven’t started the timer yet, start with the scan: run the free website accessibility checker on your home page now and keep the result as your baseline.
Related guides
- The European Accessibility Act for online stores
- How to write an accessibility statement
- Shopify store accessibility checklist
Frequently asked questions
Does the European Accessibility Act apply to my Shopify store?
It can, if you offer products to consumers in the EU and your business is not a microenterprise, which the directive defines as an enterprise with fewer than 10 persons and an annual turnover or annual balance sheet total not exceeding EUR 2 million. The rules that bind you are the national laws of the countries you sell to, which have applied since 28 June 2025. Check with a lawyer who knows those laws.
Can a 30-minute check show that my store meets the European Accessibility Act?
No. It shows you the most common barriers and roughly where you stand. Meeting the requirements means fixing what you find, testing by hand with a keyboard and a screen reader, publishing information on how your store meets the requirements, and keeping all of it up as your store changes.
Which WCAG version should a Shopify store aim for under the EAA?
Aim for WCAG 2.2 Level AA. The European standard EN 301 549 version 3.2.1 is built on WCAG 2.1 Level AA, and version 4.1.1, published in September 2026, moves to WCAG 2.2 Level AA. WCAG 2.2 builds on 2.1, so working toward 2.2 AA covers both.
Does Shopify's checkout meet the European Accessibility Act?
Shopify controls most of the checkout and publishes an accessibility conformance report for it against WCAG 2.2 Levels A and AA, dated March 2026, which lists a few criteria as partially supported. You can't change those parts yourself. You can still test checkout with a keyboard, report problems to Shopify, and check the payment and checkout apps you add.
Do I need an accessibility statement under the EAA?
The directive asks service providers to explain, in their general terms and conditions or an equivalent document, how the service meets the accessibility requirements, and to keep that information available for as long as the service is offered. An accessibility statement linked from your footer and your terms is a common way to do it.
Sources
- Directive (EU) 2019/882 on the accessibility requirements for products and services (EUR-Lex)
- European Commission: European Accessibility Act (EAA)
- ETSI EN 301 549 V4.1.1 (2026-09): Accessibility requirements for ICT products and services
- ETSI EN 301 549 V3.2.1 (2021-03): Accessibility requirements for ICT products and services
- Web Content Accessibility Guidelines (WCAG) 2.2
- Shopify Accessibility Conformance Report: Shopify Checkout
- W3C WAI: Selecting Web Accessibility Evaluation Tools
- Understanding Success Criterion 1.1.1: Non-text Content
- Understanding Success Criterion 1.4.3: Contrast (Minimum)
- Understanding Success Criterion 2.1.1: Keyboard
- Understanding Success Criterion 2.1.2: No Keyboard Trap
- Understanding Success Criterion 2.4.7: Focus Visible
- Understanding Success Criterion 3.3.2: Labels or Instructions