Guide · European Accessibility Act
EAA checklist for Shopify stores: 30 points to work through
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General information, not legal advice. Laws differ by country; for your situation, ask a lawyer.
The European Accessibility Act (Directive (EU) 2019/882, the EAA) has applied to online stores selling to EU consumers since 28 June 2025. It does not come with an official checklist. It sets functional requirements, points to a technical standard and asks you to publish information about your store's accessibility. This guide turns that into 30 concrete points for a Shopify store, grouped in the order we suggest you work through them.
A word on what a checklist can and cannot do. It helps you organise the work and not forget a whole area, such as apps or the checkout. It cannot tell you that your store meets the law: many points need a person to judge them, and automated tools find only part of the barriers.
In short
- Start by checking whether the EAA applies to you at all: microenterprises providing services are exempt.
- Most technical work sits in the theme: contrast, names for icon links and buttons, zoom, focus and headings.
- Check content, forms, the checkout and every app, not just the home page.
- Publish your accessibility information (Annex V) and keep a dated record of what you tested and fixed.
- Finish with a manual test: keyboard only, then a screen reader, from the home page to the order confirmation.
How to prioritise
In our study of 5,463 EU Shopify home pages (public HTTP Archive crawl of
1 September 2026, mobile view, home pages only, automated checks only), 94.2% failed at least one automated check that
maps to WCAG 2.1 level A or AA. The most common findings were low colour contrast (74.6%), links without an
accessible name (54.3%), images without an alt attribute (36.0%) and blocked zoom (17.0%). Fix those
first: they are frequent, they affect many shoppers, and most are one change in the theme.
The reference for "accessible enough" is the European standard EN 301 549, which includes the WCAG 2.1 level A and AA success criteria for web content. Version V4.1.1 (based on WCAG 2.2) was published in September 2026 and is expected to replace it as the reference once it is cited in the EU Official Journal. Planning with WCAG 2.2 in mind costs little extra.
1. Scope: does the EAA apply to you?
| Point | What to check | Reference |
|---|---|---|
| 1. Consumers in the EU | Do you sell to consumers (not only businesses) in at least one EU country? | EAA Art. 2(2)(f), Art. 3(30) |
| 2. Microenterprise test | Fewer than 10 persons and turnover or balance sheet total of no more than €2 million? Then the service requirements do not apply. Belgium exempts only until 28 June 2030 | EAA Art. 3(23), Art. 4(5) |
| 3. Countries you sell to | List them: each country's law adds details, such as the authority to name or the language | National transposition |
| 4. Dated self-assessment | Write down the result, your figures and the date, whichever way it goes | Good practice |
Our guide to the EAA microenterprise exemption explains how to count staff and turnover, and how groups of companies are counted.
2. Theme and design
| Point | Where in Shopify | How to check | WCAG |
|---|---|---|---|
| 5. Text contrast | Theme settings › Colors, colour schemes per section | 4.5:1 for normal text, 3:1 for large text; check sale labels and text over images | 1.4.3 |
| 6. Zoom allowed | layout/theme.liquid, viewport meta tag | No maximum-scale=1 or user-scalable=no; pinch-zoom works on a phone | 1.4.4 |
| 7. Icon links and buttons named | Header (search, account, cart), social icons, slider arrows, close buttons | Each has a text label or aria-label | 2.4.4, 4.1.2 |
| 8. Visible focus | Theme CSS | Tab through the page: you can always see where you are | 2.4.7 |
| 9. Headings in order | Section headings in the theme editor | One h1, no skipped levels used for styling | 1.3.1 |
| 10. Moving content can be paused | Slideshows, marquee and announcement bars | No autoplay, or a visible pause control | 2.2.2 |
| 11. Reflow at 320 px | Whole store | No horizontal scrolling at 400% zoom on desktop | 1.4.10 |
The guide to the 7 most common Shopify accessibility fixes shows where each of these lives in Dawn and similar themes. Shopify's own theme accessibility page lists further theme settings to review.
3. Content: images, video and text
| Point | Where in Shopify | How to check | WCAG |
|---|---|---|---|
| 12. Product image alt text | Products › media item › Add alt text, or CSV | Each meaningful image describes what matters for buying | 1.1.1 |
| 13. Banner and section images | Theme editor › section › image › Edit | Text inside images is repeated in alt text or on the page | 1.1.1, 1.4.5 |
| 14. Decorative images | Theme sections, files | Empty alt so screen readers skip them | 1.1.1 |
| 15. Video | Product media, sections | Captions; no sound that starts on its own | 1.2.2, 1.4.2 |
| 16. Link text | Pages, blog posts, menus | No bare "click here"; the link says where it goes | 2.4.4 |
| 17. Page language | Languages settings, translations | Each language version declares its language | 3.1.1 |
Alt text is the biggest content task on most stores. Our guide to Shopify alt text and bulk editing covers where Shopify stores it and how to fill in hundreds of images at once.
4. Forms, cart and checkout
Annex I of the directive adds requirements specific to e-commerce, including that identification, security and payment functions are perceivable, operable, understandable and robust. Shopify builds the checkout. Its own accessibility conformance report for the checkout (March 2026) lists some criteria as only partially supported, so test what your customers actually get.
| Point | Where in Shopify | How to check | WCAG |
|---|---|---|---|
| 18. Visible field labels | Newsletter, contact form, search | Every field has a label, not only a placeholder | 1.3.1, 3.3.2 |
| 19. Understandable errors | Forms, cart | The message names the field and the fix, and a screen reader announces it | 3.3.1, 3.3.3 |
| 20. Variant pickers and quantity | Product page | Size and colour choices work with the keyboard and announce their state | 2.1.1, 4.1.2 |
| 21. Cart drawer | Theme cart drawer or page | Focus moves into the drawer, Escape closes it, focus returns | 2.1.2, 2.4.3 |
| 22. Checkout branding | Settings › Checkout, checkout editor | Your colours and fonts keep the contrast ratios | 1.4.3, 1.4.11 |
| 23. Payment methods and extensions | Payment providers, checkout extensions | A test order with a screen reader, for each payment method you offer | 4.1.2 |
5. Apps and third parties
Pop-ups, review widgets, chat buttons and cookie banners bring their own markup. In our study, pages with 40 or more detected third-party technologies failed 4.1 automated checks on average, pages with fewer than 20 failed 2.7. That is a correlation, not proof of cause, but it is a good reason to test every app you add.
| Point | What to check | WCAG |
|---|---|---|
| 24. Cookie banner | Reachable and closable with the keyboard; focus is not trapped behind it | 2.1.1, 2.4.3 |
| 25. Pop-ups and chat | Close button has a name; the pop-up does not steal focus repeatedly | 4.1.2, 3.2.1 |
| 26. Reviews, wishlists, recommendations | Star ratings have a text equivalent; buttons are named | 1.1.1, 4.1.2 |
6. The accessibility statement
Article 13 of the directive asks service providers to publish the information listed in Annex V, in their general terms and conditions or an equivalent document: a description of the service, the explanations needed to understand how it works, and a description of how it meets the accessibility requirements. National laws add details: Germany, for example, requires naming the market surveillance authority.
| Point | What to check | Reference |
|---|---|---|
| 27. Content per Annex V and national law | Service description, how it works, how it meets the requirements, known barriers, contact for feedback, authority where required | EAA Art. 13, Annex V |
| 28. Findable and accessible | Linked from the footer or the terms; the page itself meets the same standard | EAA Art. 13(2) |
Our guide to the accessibility statement for Shopify has an outline you can adapt and the wording to avoid. Have a lawyer check the final text for your countries.
7. Records and manual testing
| Point | What to do |
|---|---|
| 29. Manual test of the buying journey | Keyboard only, then a screen reader (VoiceOver on iPhone, NVDA on Windows): home page, search, product, cart, checkout, order confirmation |
| 30. Dated record | What you tested, with which tools, what you found and fixed, and when. Repeat after theme changes, new apps and at least yearly |
The manual test matters because tools miss a lot. When GOV.UK tested automated tools against a page with 143 deliberate barriers in 2017, all ten tools together found 71% of them and the best single tool 41%. A dated record, in turn, keeps your accessibility information honest: it shows what was checked and what is still open. The W3C's WCAG quick reference explains each success criterion named in the tables above.
How Testamur helps
Testamur is a Shopify app in development, built as an accessibility record rather than an overlay. The free check is available now and covers the automated part of this list on your home page and, where your robots.txt allows, collection, product and legal pages. The app is designed to keep dated scans, suggest code-level fixes and draft country-specific accessibility information, so that you can document what you checked, fixed and published. It shows only what automated checks can detect, and it does not replace the manual test or legal advice. You can run the free check on your own store.
Sources
- Directive (EU) 2019/882 (European Accessibility Act): Art. 3, 4(5), 13; Annexes I and V
- W3C: How to Meet WCAG (quick reference)
- Shopify Help Center: theme accessibility
- Shopify: Checkout accessibility conformance report
- GOV.UK Accessibility blog: what we found when we tested tools (2017)
- Testamur: EU Shopify accessibility study 2026 (HTTP Archive, crawl of 1 September 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
Is there an official EAA checklist for online stores?
No. The directive sets functional requirements (Annex I) and an information duty (Article 13 and Annex V). The European standard EN 301 549, which includes WCAG 2.1 level A and AA for web content, is the usual technical reference. A checklist like this one helps you organise the work; it does not replace testing against the standard.
Does passing every point mean my store meets the EAA?
No checklist can tell you that. Many points need human judgement, for example whether alt text is meaningful or whether an error message is understandable. Use the list to find and fix barriers, test with real assistive technology, and describe the result honestly in your accessibility information.
Do I have to check the Shopify checkout myself?
Shopify builds the checkout, but you choose colours, logos, texts, payment methods and checkout extensions. The EAA names payment and identification functions explicitly. Place a test order with the keyboard only and with a screen reader, and note what you can change and what you cannot.
How often should I go through the checklist?
After every theme change, new app or larger content update, and otherwise at least once a year. Keep the date of each round and what you fixed. That record makes your accessibility information easier to keep accurate.