Guide · EAA
Accessibility statement for a Shopify store: what the EAA asks for, with a template
Last updated
General information, not legal advice. Laws differ by country; for your situation, ask a lawyer.
Since 28 June 2025, online shops that sell to consumers in the EU have had to meet the accessibility requirements of the European Accessibility Act (Directive (EU) 2019/882). Part of that is an information duty: you publish how your service meets the requirements. Merchants usually call this an accessibility statement. This guide explains what the Act asks for, how national laws name and extend it, where to put it in Shopify, and gives an outline you can adapt.
Nothing here is legal advice. The country templates in Testamur are drafts pending counsel review per country, and the same applies to the outline below.
In short
- Annex V asks for a description of the service, how it works and how it meets the requirements, plus how you monitor that.
- The information must be public, in written and oral format, and accessible itself.
- Countries name it differently and add items; Germany, for example, requires the market surveillance authority.
- In Shopify, a page linked from the footer and referenced from your terms is a common setup.
- Describe what you checked and what still has barriers. Date every version.
What the European Accessibility Act requires
Article 13(2) says that service providers "shall prepare the necessary information in accordance with Annex V and shall explain how the services meet the applicable accessibility requirements." The information "shall be made available to the public in written and oral format, including in a manner which is accessible to persons with disabilities", and kept "for as long as the service is in operation."
Annex V sets out the content. The information goes "in the general terms and conditions, or equivalent document". It describes the applicable requirements and covers, as far as relevant, the design and operation of the service. Where applicable it contains:
- (a) "a general description of the service in accessible formats";
- (b) "descriptions and explanations necessary for the understanding of the operation of the service";
- (c) "a description of how the relevant accessibility requirements set out in Annex I are met by the service".
Point 2 allows you to apply harmonised standards in full or in part. For websites the reference today is EN 301 549 V3.2.1, which incorporates WCAG 2.1 level AA. Point 3 asks for "information demonstrating that the service delivery process and its monitoring" ensure the service meets the requirements.
The Act also says (Article 13(4)) that a provider whose service does not meet the requirements must inform the competent authorities immediately. Whether listing known barriers in a public statement interacts with that duty is a question for counsel in each country.
Microenterprises that provide services (fewer than 10 persons and annual turnover or balance sheet of at most €2 million) are exempt; see our guide to the microenterprise exemption. If your company is outside the EU, read the EAA for non-EU Shopify brands.
Same duty, different names and extras by country
Each member state wrote the duty into its own law. The core is Annex V everywhere, but the name and some items differ. Based on our research of the national texts (drafts, pending counsel review):
| Country | Title (official usage or our draft) | Notable differences |
|---|---|---|
| Germany | Informationen zur Barrierefreiheit | The authority MLBF distinguishes it from the public-sector "Erklärung zur Barrierefreiheit". BFSG Anlage 3 adds naming the competent market surveillance authority (the MLBF) and leaves out Annex V point 3. |
| Austria | Informationen zur Barrierefreiheit | BaFG § 14(2) spells out "schriftlicher und mündlicher Form" (written and oral); Anlage 3 keeps the monitoring point. |
| Netherlands | Toegankelijkheidsverklaring | The ACM says the statement must also be offered verbally and the helpdesk must be able to give the information. |
| Belgium | Toegankelijkheidsverklaring / déclaration d'accessibilité | The law asks you to explain whether or not the service meets the requirements; Dutch and French versions are usually needed. |
| France | Informations sur l'accessibilité de notre service | "Déclaration d'accessibilité" belongs to a separate regime (loi 2005-102, RGAA) which may also apply to large companies in parallel. |
| Italy | Informazioni sull'accessibilità del servizio | The "dichiarazione di accessibilità" under Law 4/2004 does not apply to EAA service providers. |
| Sweden | Information om tillgänglighet | If you rely on an exemption such as disproportionate burden, the information must say which requirements it covers. |
The monitoring item (Annex V point 3) appears in the Austrian, Dutch, Belgian, French, Italian, Irish, Spanish and Swedish texts. For the full German list, see our article on BFSG Anlage 3 (in German).
Where to publish it in Shopify
Every national text uses the "general terms and conditions or equivalent document" wording. A practical setup that many stores use:
- Create a page: in the Shopify admin, go to Online Store > Pages and click Add page (Shopify: creating and editing pages). Use a clear title in the shopper's language.
- Link it from the footer: go to Content > Menus, open the menu your theme shows in the footer, and add a menu item that links to the page (Shopify: editing menus).
- Reference it from your terms: under Settings > Policies, open the terms of service and add a link to the page. Shopify's store policies help notes that you have to turn off the automated policy to edit its text.
Whether a linked page is enough, or whether the text must sit in the terms themselves, is one of the points counsel should confirm for each country. The page itself must be accessible: real headings, plain text, no PDF-only version. For the oral format, offering to read the information out on the phone or through your support channel is one approach; counsel should confirm it for your countries.
An outline you can adapt
This outline follows Annex V and the country extras above. Replace every bracket with facts about your own store, translate it into the language of the shoppers you target and adapt it per country.
# Accessibility information
Provider: [legal name], [address], [company register / VAT no.]
Service: online shop at [store URL]
Date: [date] · Next review: [date]
## 1. Our service
[What the shop sells and how buying works: browsing, search, product pages,
cart, checkout, payment, delivery, returns, customer service.]
## 2. Requirements and standard
This shop is subject to [national law transposing the European
Accessibility Act]. Our technical reference is EN 301 549 V3.2.1,
which includes WCAG 2.1 level AA for web content.
## 3. How the shop meets the requirements
[Concrete features: text alternatives for product images, keyboard
access to menus and checkout, zoom allowed, colour contrast checked,
labelled form fields, accessible payment steps.]
## 4. Known barriers
[What does not yet meet the requirements, where, and what you plan.
Name barriers in third-party apps or widgets and their provider.]
## 5. How we check and monitor
[Method and dates: automated checks (which pages, how often), manual
tests (keyboard, screen reader), who did them. Automated checks find
only part of the barriers.]
## 6. Feedback and contact
Tell us about a barrier: [e-mail], [phone], [contact form URL].
We reply within [n] working days. On request we provide this
information in another format, including orally by phone.
## 7. Authority and complaints
[Name, address and website of the market surveillance authority
for your country, and the complaint route it offers.]
## 8. About this information
Prepared on [date] by [who] using [method]. Last reviewed [date]. Notes on the sections:
- Section 3 is the core of Annex V (c). List features you have checked, not features you hope the theme has. Our guide to the most common Shopify accessibility fixes covers the usual gaps; in our study of EU Shopify home pages, 94.2% failed at least one automated check.
- Section 4 should include third-party apps: review widgets, chat, cookie banners and pop-ups are part of what shoppers use.
- Section 5 answers Annex V point 3 in the countries that keep it. Give dates and say what kind of tests you ran.
- Section 7 is required in Germany and useful everywhere. Use the authority's own website for its name and complaint route.
Wording to avoid
The statement is a factual description, not marketing copy. Avoid absolute claims you cannot back up: that the store meets every requirement, that it works for everyone, or that a tool, widget or third party has signed it off. An overlay or toolbar script does not change what your theme and content deliver. Prefer precise sentences such as "We tested the home page, collection pages, product pages and checkout with automated tools and a keyboard on [date]. We found the following barriers…".
Watch the title, too: "déclaration" in France, "dichiarazione" in Italy and "Erklärung" in Germany are the names of separate (mainly public-sector) regimes.
Keep versions dated
The information has to stay available as long as you offer the service, and it should change when the store changes: a new theme, a new app, fixed barriers. Put the date and next review date on the page, keep each earlier version with its date, and keep the evidence behind it (check results, fixes, who tested what). When an authority or a shopper asks, you can show what you knew and did at each point.
How Testamur helps
You can run a free automated check of your store today. The Testamur Shopify app, now in development, drafts country-specific accessibility information from your scans and your own inputs and keeps a dated record of what you checked, fixed and published. Its templates are drafts pending counsel review per country, it is not an overlay, and it does not replace legal advice.
Sources
- Directive (EU) 2019/882 (European Accessibility Act), Art. 13 and Annex V, EUR-Lex
- MLBF, German market surveillance authority for accessibility
- ACM (Netherlands): accessibility of e-commerce services
- Shopify Help Center: creating and editing pages
- Shopify Help Center: editing menus
- Shopify Help Center: store policies
- Testamur study: accessibility of 5,463 EU Shopify home pages (2026)
Check your store free
See which barriers an automated check finds on your own Shopify store: the home page and, where your robots.txt allows, collection, product and legal pages, mapped to WCAG and EN 301 549. Free, result by email. Automated checks find part of the barriers, not all of them.
Check your store freeFrequently asked questions
Does my Shopify store need an accessibility statement?
If you sell to consumers in the EU and your business is not a microenterprise, the European Accessibility Act requires you to publish information on how your online shop meets the accessibility requirements (Art. 13(2) and Annex V). Most people call it an accessibility statement; national laws use different names.
Where should I publish it in Shopify?
A common approach is a dedicated page (Online Store > Pages), linked from the footer menu and referenced from your terms of service. The law speaks of the general terms and conditions or an equivalent document, so ask counsel whether a linked page is enough in your country.
Can I say my store meets all the requirements?
Only if a thorough evaluation supports it, which is rare for a live web shop with apps. A statement that names known barriers and what you are doing about them is more honest and more useful to shoppers than a blanket claim.
Do I need a separate statement for each country?
The core content comes from the same Annex V, but national laws add items and use different names. Germany requires the market surveillance authority to be named, and the language should match the shoppers you target. Many stores keep one structure and adapt it per country and language.
Is a template enough?
A template gives structure. The content has to describe your actual store, the checks you did and the barriers you found. Nothing in this guide is legal advice; have the final text reviewed for each country you sell to.