The European Accessibility Act for Shopify stores: what an automated scan can and can't find
Published
The European Accessibility Act (EAA) has applied to online stores since 28 June 2025. If you sell to consumers in the EU, your storefront is expected to be usable by people with disabilities: people who use a screen reader, navigate with a keyboard, zoom the page or can’t tell low-contrast colours apart.
This guide is for Shopify merchants who want to know where they stand. It is not legal advice.
Does the EAA apply to my store?
The EAA (Directive (EU) 2019/882) covers e-commerce services offered to consumers in the EU. Three points decide most cases:
- Where your customers are, not where you are. A store in Canada or the US that sells to consumers in Germany or France is in scope for those sales.
- Microenterprises are exempt from the service requirements. A microenterprise has fewer than 10 people and an annual turnover or balance sheet total of at most €2 million. Many small Shopify stores fall under this; check both numbers.
- Each EU country enforces it through its own law. Germany’s is the Barrierefreiheitsstärkungsgesetz (BFSG). Penalties and procedures differ by country.
What the EAA asks of a storefront
The law sets outcomes, not code. In practice, the harmonised European standard, EN 301 549, points to WCAG 2.1 level AA, and that is what auditors test against. For a Shopify store, the usual failures are:
- text whose colour contrast is too low against its background
- product images without alt text, or with alt text like “IMG_2041.jpg”
- icon-only buttons and links (cart, search, social icons) with no accessible name
- form fields (newsletter, search, quantity) without a label
- a page without a language set, so screen readers pronounce it wrong
- popups and menus that keyboard users can’t reach or close
The EAA also asks you to publish how your service meets the requirements, usually as an accessibility statement: a public page that says what is accessible, what isn’t yet, and how customers can report a problem.
What an automated scan finds
Scanners such as axe-core, the open-source engine behind many accessibility tools, test the rendered page against WCAG rules. In a large study of real audits, its maker Deque found automated tests caught about 57% of the issues a full audit found, by volume. They’re good at the failures above that can be measured: contrast ratios, missing alt attributes, missing labels and names, missing language.
That’s why a scan is the right first step: it finds the common, repeated failures quickly, and on a Shopify theme many of them come from a handful of theme settings and templates.
What a scan can’t tell you
The other half needs a person:
- Is the alt text right? A scanner sees that alt text exists, not whether “red shoe” describes the photo.
- Does the page make sense to a screen reader? Reading order, headings that describe their section, and error messages that say what went wrong.
- Does it work with a keyboard? Whether focus gets trapped in a size picker or a cookie banner.
- Checkout. Shopify runs checkout, not your theme; scanners usually can’t reach it, and you can’t edit it on most plans.
So be wary of any tool that says it makes your store “compliant”. In 2025 the US Federal Trade Commission fined an overlay vendor US$1 million for claims like that.
A practical order of work
- Scan your home page, a collection, a product page, search and the cart.
- Fix the theme-wide failures first: colour settings, icon buttons, labels. One change fixes every page.
- Write alt text for product images. Describe what a shopper needs to know: colour, shape, what’s shown.
- Do a short manual check: tab through the store with the keyboard, and try a screen reader (VoiceOver on a Mac, NVDA on Windows) on a product page.
- Publish an accessibility statement and keep a record of what you checked and changed, with dates.
- Rescan after theme or app changes. Apps that inject reviews, popups or chat widgets are a common source of new failures.