European Accessibility Act 2025: What Shopify Merchants Selling to the EU Must Do Now

EAA Enforcement Has Begun

On June 28, 2025, the European Accessibility Act became enforceable across all 27 EU member states.

This is not a future deadline. Merchants offering covered ecommerce services to EU consumers may be in scope even when established elsewhere, subject to exclusions and exemptions. Each member state implements and enforces the Directive through national law.

What the EAA Requires

The EAA expressly covers "e-commerce services," defined around services provided at a distance, through websites and mobile-device-based services, at a consumer's individual request with a view to concluding a consumer contract. That is broader than online marketplaces, but it is not shorthand for every website that can receive an EU order.

The Directive's binding requirements are functional requirements in Annex I. EN 301 549 v3.2.1 is a commonly used technical reference and its web chapter incorporates WCAG 2.1 Level AA. AccessComply also checks applicable WCAG 2.2 criteria separately.

WCAG remediation overlaps across ADA, EAA, EN 301 549, procurement, and usability programs, but those legal regimes are not interchangeable. A stronger WCAG program reduces duplicated technical work; it does not replace jurisdiction-specific scope, information, process, and manual-evaluation requirements.

Who Does This Apply To?

Your Shopify service may be in scope when:

✓ You sell physical products shipped to EU countries ✓ You sell digital products (ebooks, software, downloads) to EU customers ✓ You operate a subscription service accessible to EU residents ✓ You provide a covered consumer service at a distance through the storefront

Exemptions that require a real assessment:

The EAA exempts "microenterprises providing services." The ecommerce service and the goods sold through it are distinct concepts, so a merchant selling products should not assume the exemption is unavailable—or available—without analyzing the entity and covered activity. Microenterprises dealing with products have narrower documentation relief under the Directive.

EU Member State Enforcement

EAA enforcement is handled nationally by each member state. Here's a snapshot of key markets:

Germany (Barrierefreiheitsstärkungsgesetz, BFSG)

Germany's implementation law (BFSG) went into force June 28, 2025. The enforcement body is the Bundesnetzagentur.

Penalties: up to €100,000 per violation (can aggregate to higher amounts for systematic failures). Germany has historically been aggressive in consumer protection enforcement.

France

France has multiple accessibility regimes and authorities depending on entity and service type. Merchants should use the current French EAA transposition and official competent-authority guidance for private ecommerce rather than assuming public-sector RGAA rules apply unchanged.

Netherlands (Wet gelijke behandeling op grond van handicap of chronische ziekte)

The Netherlands' enforcement body is the Netherlands Institute for Human Rights (College voor de Rechten van de Mens). Individual complaints can be filed by disabled users.

UK (PSBAR 2018)

The UK is no longer in the EU but has parallel accessibility requirements under the Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018. The private sector requirements are developing under the UK Equality Act.

Italy (AgID)

Italy's enforcement body is AgID (Agenzia per l'Italia Digitale). Enforcement typically begins with a complaint from a disabled user, followed by an investigation, a request for the business to demonstrate compliance, and — if necessary — a formal compliance order or fine. This complaint-driven pattern is common across member states.

Cross-Border Note

Customer location and the market where a covered service is offered can create obligations even when a merchant is incorporated elsewhere. Cross-border scope still depends on how the service is offered, applicable exemptions, and the member state's implementing law.

What "WCAG 2.1 Level AA" Means for Your Store

The practical requirements for WCAG 2.1 AA compliance on a Shopify store:

Perceivable:

• All images have descriptive alt text (1.1.1)
• Videos have captions (1.2.2)
• Color is not the only way to convey information (1.4.1)
• Text has sufficient contrast (4.5:1 for normal text) (1.4.3)
• Text can be resized to 200% without loss of function (1.4.4)
• Content doesn't rely on color, size, shape, or spatial position alone (1.3.3)

Operable:

• All functionality available by keyboard (2.1.1)
• No keyboard traps (2.1.2)
• Skip navigation to main content (2.4.1)
• Pages have descriptive titles (2.4.2)
• Headings and labels describe topic or purpose (2.4.6)
• Keyboard focus is visible (2.4.7)

Understandable:

• Page language is set (3.1.1)
• Navigation is consistent across pages (3.2.3)
• Error suggestions are provided (3.3.3)
• Error prevention on legal and financial transactions (3.3.4)

Robust:

• HTML is valid and well-formed (4.1.1 — removed in WCAG 2.2 but still best practice)
• ARIA roles and states are correctly implemented (4.1.2)
• Status messages are programmatically determinable (4.1.3)

Accessibility service information

For covered services, Annex I requires information explaining how the service meets accessibility requirements to be available in an accessible form. A public accessibility statement can organize useful elements such as:

1. Your WCAG 2.1 AA / EN 301 549 conformance level (full, partial, or non-conformant)
2. Any known non-compliant content
3. Alternative means of access for inaccessible content
4. A contact mechanism for users to report barriers
5. A reference to the relevant national enforcement authority

A persistent footer link is a practical way to make this information easy to find, but exact format and placement depend on national law. AccessComply includes a merchant-reviewed statement workflow on the Free plan and can publish the approved text to a Shopify page; see the accessibility statement template guide.

The Overlay Problem Under the EAA

An overlay widget is not evidence that a service meets the EAA's functional accessibility requirements. Some user controls can be useful, but they do not replace accessible source markup, keyboard behavior, content, testing, or service information. If a runtime script fails or cannot correct a complex interaction, the underlying barrier remains. Why overlays don't work covers the architecture in depth.

Genuine remediation means modifying the code that generates your pages: alt attributes and aria-labels in your Liquid templates, contrast-safe color values and focus styles in your CSS, and working keyboard behavior in your JavaScript. AccessComply can apply merchant-approved changes for eligible, safely mapped findings in supported categories, after a backup, and then re-scan the affected pages. Unsupported or judgment-heavy findings remain for manual review. Run a free scan to see the automated findings on your storefront today.

The EAA + ADA Combined Risk

For a Shopify merchant selling globally:

• US customers: ADA Title III risk (federal + state lawsuits)
• EU customers: EAA enforcement risk (national regulatory penalties)
• UK customers: UK Equality Act risk (developing)

These regimes share substantial technical accessibility work, but they are not identical. Reuse the WCAG remediation program while evaluating each law's scope, procedures, documentation, and remedies separately.

Getting Started

For merchants in scope, the practical path is:

1. Scan your store — review detected findings, the reported scan scope, and the automated accessibility score
2. Fix critical violations — keyboard access, alt text, form labels are the highest-priority
3. Publish accurate accessibility information — use a statement where it fits the applicable national requirements
4. Set up monitoring — theme updates can introduce new findings; use the cadence included in your plan to review regressions promptly
5. Document your remediation — timestamps, fix history, and scoped scan reports can record the work performed without establishing legal conformance

The good news: many source-code and content fixes benefit both US and EU accessibility programs. Keep one remediation backlog and evidence trail, then add the jurisdiction-specific review each market requires.

---

Scan supported accessibility checks on your Shopify storefront — free, no account required.

Further Reading

• EAA Compliance for German Shopify Stores: What the BFSG Requires
• EAA Compliance for French Shopify Stores: RGAA and the EAA
• ADA Lawsuits Against Ecommerce Stores: 2025–2026 Statistics and How to Protect Your Business