EAA for US and UK Shopify brands in the EU

General information, not legal advice. Laws differ by country; for your situation, ask a lawyer.

By Sieghart Michielsen · Published October 25, 2026

If your Shopify brand is based in the US or the UK and ships to customers in Germany, France or the Netherlands, the European Accessibility Act (Directive (EU) 2019/882, the EAA) is likely relevant to you. It has applied to online stores selling to EU consumers since 28 June 2025, and it is written around the service, not the seller's address.

This guide explains when the EAA reaches a store outside the EU, how it differs from US and UK rules, and gives a 30/60/90-day plan. Where the answer depends on legal interpretation, we flag it.

In short

The EAA covers e-commerce services provided to consumers in the EU (Art. 2(2)(f)). A "service provider" is anyone who provides such a service on the Union market or offers it to consumers in the EU (Art. 3(4)). There is no EU-establishment test.
The directive was implemented by 27 national laws. Which of them apply to you depends on where your consumers are, which is partly a legal question.
The technical reference is EN 301 549, which for web content means WCAG 2.1 AA. US brands already working to WCAG have a head start.
Beyond the code, you must publish accessibility information (Annex V) and keep the service accessible as it changes (Art. 13).
Microenterprises (fewer than 10 persons and up to €2 million turnover or balance sheet) are exempt, wherever they are based.

When the EAA applies to a store outside the EU

What the directive says

Article 2(2)(f) of the European Accessibility Act lists "e-commerce services" among the services it covers, and Art. 3(30) defines them as services "provided at a distance, through websites and mobile device-based services by electronic means and at the individual request of a consumer with a view to concluding a consumer contract". A Shopify storefront where shoppers browse, add to cart and check out fits that description.

The key definition for non-EU brands is Art. 3(4): a service provider is "any natural or legal person who provides a service on the Union market or makes offers to provide such a service to consumers in the Union". The national laws repeat this. Germany's BFSG, for example, defines a service provider as anyone who provides or offers a service to consumers on the Union market (§ 2 Nr. 4 BFSG). Neither text asks where the provider is based.

What is clear, and what is a legal question

A company does not escape the EAA by being incorporated in Delaware or London. What the directive does not spell out is the line between offering a service to EU consumers and merely being reachable from the EU. A store with a German-language storefront, euro prices and shipping to Berlin is in a different position from a US-only store an EU visitor happens to open. Where the line falls, and how an authority would enforce against a provider without an EU presence, are questions for counsel. If you have set up EU markets in Shopify, plan as if the EAA applies.

Which country's rules?

The EAA is a directive, so what binds you are the national laws that implement it. Article 13(4) requires a provider to inform "the competent national authorities of the Member States in which the service is provided" when the service falls short, which points to the countries whose consumers you serve. A brand selling across the EU can therefore face several national laws at once. The core duties are the same; authorities, language, microenterprise rules and sanctions differ. Treat the applicable law as an open question for counsel.

Authorities for e-commerce accessibility in selected EU countries (as of 25 October 2026)
Country	National law	Authority
Germany	BFSG	MLBF (Magdeburg); must be named in your accessibility information
France	Code de la consommation L. 412-13	DGCCRF
Netherlands	Civil Code art. 6:230fb	ACM
Belgium	Code of Economic Law, Book VIII	FPS Economy, Economic Inspection
Ireland	S.I. 636/2023	CCPC
Italy	D.lgs. 82/2022	AgID
Spain	Ley 11/2023	Regional authorities, coordinated nationally
Austria	BaFG	Sozialministeriumservice
Sweden	Lag 2023:254	PTS

How the EAA differs from US and UK rules

The Americans with Disabilities Act

In the US, website accessibility for private retailers is mostly discussed under Title III of the Americans with Disabilities Act, a civil-rights law. The Department of Justice's 2024 web rule names WCAG 2.1 level AA as the technical standard, but it covers state and local governments under Title II, not private businesses. For an online store, the US question is usually whether disabled customers are being excluded.

The EAA works differently:

It is enforced like product regulation. National market surveillance authorities check services, can order corrections and can impose sanctions under national law.
It has a publication duty. You must publish information on how your service meets the requirements (Art. 13(2), Annex V), in writing and orally, in an accessible way, for as long as the service runs.
It has a process duty. You need procedures that keep the service accessible when your store, the requirements or the standards change (Art. 13(3)), and you must take corrective action and inform the authorities "immediately" if it falls short (Art. 13(4)).

The UK

The UK is not an EU member state, and the EAA is not part of the law of Great Britain. It matters to a UK brand only for the part of its business that serves consumers in the EU. At home, the Equality Act 2010 prohibits discrimination by service providers in England, Wales and Scotland and includes a duty to make reasonable adjustments for disabled people, but no technical standard or published statement. (Northern Ireland has its own rules, not covered here.)

The standard: your WCAG work counts

The technical reference for web content in the EU is the European standard EN 301 549. Version 3.2.1 incorporates WCAG 2.1 level AA. Version 4.1.1, which incorporates WCAG 2.2, was published by ETSI on 2 September 2026; according to AccessibleEU it is not yet the legal reference. A brand that already tests against WCAG 2.1 AA for the US market has done much of the groundwork. Usually missing is the EU layer: published information per market, the named authority, and a record of how the store is kept accessible.

What EU storefronts typically show

The barriers on stores selling into the EU are mostly the familiar ones. In our study of 5,463 EU Shopify home pages (HTTP Archive crawl of 1 September 2026, mobile, home pages on EU country domains only, automated checks only), 94.2% failed at least one automated WCAG 2.1 A/AA check. 74.6% had text with insufficient colour contrast, 54.3% had links without an accessible name, 36.0% had images without alt text and 17.0% blocked zooming. Our guide to the most common Shopify accessibility fixes shows where each one lives in the theme.

And the audience is large: according to Eurostat, 23.9% of people aged 16 or over in the EU reported some or severe long-standing limitations in their usual activities due to health problems in 2024.

A 30/60/90-day plan for a brand with EU storefronts

This plan assumes a Shopify Plus or Advanced brand that uses Shopify's international selling tools. Shopify lets you create markets for specific countries or regions, give each market its own URL through a country domain or a subfolder such as example.com/en-ca (international domains), and choose the languages each market uses, with translations through the Translate & Adapt app or a compatible third-party app.

Days 1–30: scope and baseline

Map your EU exposure. List each market, its countries, domain or subfolder, languages, and whether you ship there and price in local currency.
Check the microenterprise test for the whole group (see the microenterprise exemption). Most Plus brands will not qualify.
Run a baseline. An automated scan of the home page, a collection, a product page, cart, search and your policy pages in each market. You can start with a free check.
Test by hand. Complete one order using only the keyboard, and one with a screen reader. Automated tools find only part of the barriers: in a GOV.UK test, ten tools together found 71% of 143 barriers, the best single tool 41%.
Brief counsel on the open questions: targeting, applicable law, statement language, notification duty.

Days 31–60: fix and publish

Fix theme-level issues first. Contrast, unnamed links and buttons, alt text and zoom are usually in the theme or its settings, so one fix covers every market.
Review apps. Review widgets, pop-ups, cookie banners and chat tools often add barriers; report them or replace the app.
Check payment and identification. Annex I of the EAA names identification, security and payment functions for e-commerce. Check what you can configure in checkout and record what you cannot.
Publish accessibility information per market following Annex V, in the market's language, naming the authority where the national law asks for it. Our guide to the accessibility statement for Shopify has an outline.

Days 61–90: keep it current

Set a cadence. Rescan after every theme update, new app or major campaign, and at least monthly.
Keep a dated record of scans, fixes and statement versions. Article 13(5) lets an authority ask for the information needed to show your service meets the requirements.
Set up a feedback route in each language and a process for handling reports, including when to inform an authority.
Plan for WCAG 2.2, which EN 301 549 V4.1.1 brings in.

Languages of the statement

The national laws we reviewed mostly do not set an explicit language rule for this information. The practical approach is to publish it in the language of each storefront, plus English if you offer an English EU storefront. Belgium usually means Dutch and French. Whether general consumer-language rules (for example in France) apply to the statement is an open point for counsel.

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. The app is designed to draft country-specific accessibility information for each EU market, suggest code-level fixes and keep a dated record of what you checked, fixed and published. It shows only what automated checks can detect and does not replace a manual audit or legal advice.

Sources

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 free

Frequently asked questions

Does the European Accessibility Act apply to US companies?

It can. The directive defines a service provider as anyone who provides a service on the Union market or makes offers to provide such a service to consumers in the EU. It does not require an EU establishment. A US store that sells to EU consumers can fall within that definition; exactly when a store counts as offering its service in the EU is a legal question.

Does the EAA apply to UK businesses selling to the EU?

The EAA is not part of the law of Great Britain, so it does not apply to sales to UK customers. A UK store that offers its service to consumers in EU countries is in the same position as a US store: the national laws of those countries can apply to that part of its business.

We already work to WCAG for the US market. Is that enough for the EU?

It is a strong start. The European standard for web content, EN 301 549 V3.2.1, incorporates WCAG 2.1 level AA. The EU adds duties that a technical standard does not cover: published accessibility information under Annex V, a process to keep the service accessible, and corrective action when problems are found.

Which EU country's rules apply to my store?

The directive points to the member states in which the service is provided, which suggests the countries whose consumers you serve. In practice that can mean several national laws at once. How a non-EU provider should handle overlapping national rules has not been settled; ask counsel in your main EU markets.

Do small non-EU brands get the microenterprise exemption?

The definition looks at the enterprise, not its location: fewer than 10 persons, and turnover or balance sheet total of no more than 2 million euros. Figures of linked and partner enterprises can count. Belgium only exempts microenterprises until 28 June 2030.

About the author

Sieghart Michielsen. Sieghart Michielsen builds Testamur, a Shopify app that checks EU storefronts for accessibility barriers and keeps a dated record of scans, fixes and accessibility statements. He writes these guides from the legal texts, the authorities’ own pages and public data. He is not a lawyer.