EAA Compliance for Shopify Stores in the European Union — 2026

Answer

The European Accessibility Act (EAA, Directive 2019/882) became enforceable across all EU-27 member states on 28 June 2025. Germany's Bundesnetzagentur is sending warning letters under BFSG with up to €100,000 per-violation fines. France saw the first EAA lawsuits filed in November 2025 against Carrefour, Auchan, E.Leclerc, and Picard — emergency injunctions are pending with up to €250,000 maximum penalties. The EAA references EN 301 549 v3.2.1 which incorporates WCAG 2.1 Level AA. Shopify merchants selling to EU consumers must comply regardless of where the merchant is based.

Top 5 jurisdictions by enforcement signal

Primary law

European Accessibility Act (Directive 2019/882) and EN 301 549 v3.2.1

Enforcement status

In force since 28 June 2025

No formal fines yet; complaint/warning phase. Landmark fines anticipated H2 2026.

EU-27 jurisdictions covered

Scan your Shopify store free — see your EU-27 risk in 30 seconds

No signup. No credit card. WCAG 2.1 + 2.2 AA scan with severity tiers and per-jurisdiction risk callout.

Frequently asked questions

Does the EAA apply to my Shopify store?

Yes if you sell goods or services to consumers located in any EU-27 member state. The EAA covers e-commerce services regardless of where the merchant is established. Microenterprises (under 10 employees AND under €2M turnover) are exempt for goods but not for services. For most Shopify merchants, the answer is "yes — comply by 28 June 2025 or face Member State enforcement."

What standard does the EAA require?

Article 4 of the EAA requires that ICT products and services meet the accessibility requirements in Annex I. The European harmonized standard EN 301 549 v3.2.1 implements those requirements; Section 9 (Web Content) directly references WCAG 2.1 Level AA conformance. AccessComply scans against WCAG 2.1 + 2.2 Level AA criteria — the same standard EAA Member State authorities apply during inspections.

What are the per-country enforcement penalties?

Germany BFSG: up to €100,000 per violation. France: up to €250,000 in aggregate plus €25,000/year for missing accessibility statement. Italy Stanca Law: €40,000 or 5% of turnover. Spain: up to €1M for major violations. Netherlands: €103,000. Belgium: €200,000. Austria: €80,000. Member States designate a competent authority — typically the national post/telecom regulator (Bundesnetzagentur in Germany, ACM in NL, ARCEP in France).

Has any EU country issued an actual EAA fine yet?

As of May 2026, the publicly tracked count of formally issued EAA fines is zero. Enforcement is in the complaint/warning phase. Germany has Bundesnetzagentur warning letters and active Abmahnung activity from private warning-letter firms. France has emergency injunctions pending in Tribunal judiciaire de Paris (filed Nov 2025) but no court ruling yet. Landmark fines are anticipated H2 2026 onward as the first cohort of cases progresses.

How does AccessComply handle multi-language compliance?

WCAG 2.1 SC 3.1.1 (Language of Page) and 3.1.2 (Language of Parts) apply at the markup level; AccessComply's LanguageAgent verifies that html lang and per-section lang attributes match the actual content language. The agent fixes mismatches automatically. For per-locale content quality, the Shopify multi-locale feature handles translation; AccessComply scans each rendered locale separately.

Source: https://eur-lex.europa.eu/eli/dir/2019/882/oj