The European Accessibility Act for Shopify stores: who is covered and what the shop must meet

The European Accessibility Act, Directive (EU) 2019/882, applies to e-commerce services provided to consumers after 28 June 2025. For a Shopify store that means the storefront, product pages, account, login, checkout and payment, in every EU country it sells to, wherever the company sits. It is a directive, so each country enforces it through its own law and its own fines. This page explains who is covered, the exemption for the smallest businesses, what “accessible” means in practice, the statement the law asks you to publish, and the national rules in the main markets. Complimus has no accessibility feature; this is the rule explained, not a product page.

1. Who is covered

“E-commerce services” are services provided at a distance, through websites and mobile apps, by electronic means and at the individual request of a consumer, with a view to concluding a consumer contract (Article 3(30)). A consumer is a natural person acting outside a trade or profession (Article 3(22)), so the Act covers B2C selling and not a shop that sells only to businesses. The provider is anyone who provides or offers such a service to consumers in the EU (Article 3(4)): the test is the market and the shopper, not the company's address.

Some content is out of scope (Article 2(4)): office files and media published before 28 June 2025, online maps, third-party content the shop neither funds nor controls, and archived content not updated since that date. Digital products sold through the shop are not listed products, so only the selling flow is covered; e-books with dedicated software are a separate scoped service.

2. The microenterprise exemption and disproportionate burden

A microenterprise employs fewer than 10 persons and has an annual turnover or an annual balance sheet total not exceeding EUR 2 million (Article 3(23)). Microenterprises providing services are exempt from the service requirements (Article 4(5)); the Irish CCPC reads it as the headcount test plus one of the financial tests. Larger businesses may invoke a disproportionate burden or a fundamental alteration of the service (Article 14), but only after an assessment against Annex VI, kept for five years and renewed when the service changes, and never where they received outside funding for accessibility. Outside the exemption, the authority of each country where the service is provided must be notified.

3. What accessible means for a storefront

Annex I asks for information that is perceivable through more than one sense, understandable, offered in text formats usable for alternatives, with readable fonts, sufficient contrast and adjustable spacing, and for websites and apps that are perceivable, operable, understandable and robust. For e-commerce it adds that identification, security and payment functions, electronic signatures and payment services meet the same four principles, and that the shop passes on the accessibility information the seller provides about the products it sells.

A service that complies with a harmonised standard cited in the Official Journal is presumed to meet the requirements the standard covers (Article 15). The standard prepared for it is EN 301 549. Version V3.2.1 builds on WCAG 2.1 and is cited under the Web Accessibility Directive for public bodies; version V4.1.1, published on 2 September 2026, moves the web baseline to WCAG 2.2 Level AA and adds a mapping to the Accessibility Act. Neither version had been cited in the Official Journal under this directive on 3 November 2026, so the Article 15 presumption is not yet available and EN 301 549 with WCAG 2.1 AA is the benchmark authorities work from, not a safe harbour. In practice a store checks the WCAG criteria: text contrast of at least 4.5 to 1, every control reachable by keyboard with visible focus, alternatives for images, labelled form fields and clear error messages.

4. The statement you must publish

A private provider of e-commerce services prepares the information in Annex V explaining how the service meets the accessibility requirements, publishes it in written and oral form in a way accessible to persons with disabilities, and keeps it for as long as the service runs (Article 13(2)). Where the service falls short, the provider corrects it and informs the authorities of the countries where the service is provided (Article 13(4)).

5. National laws and penalties

Amounts above come from the national texts (Germany and Austria) or the national authority (Ireland), read on 3 November 2026. Where a country's fine is not listed, its law sets one and we have not confirmed the figure from a primary source.

6. Transition rules

Article 32 lets a provider keep using products it lawfully used for similar services before 28 June 2025 until 28 June 2030, and lets service contracts agreed before that date run unchanged until they expire, at most five years. The storefront itself gets no deferral: a shop serving consumers after 28 June 2025 must meet the requirements now.

7. First steps for a Shopify store

• Check the thresholds: fewer than 10 staff and an annual turnover or balance sheet total of at most EUR 2 million means the service requirements do not apply; with 10 or more staff, or above EUR 2 million on both measures, they do.
• Tab through the menu, product options, cart and checkout with the keyboard alone. Every control needs visible focus (WCAG 2.1.1 and 2.4.7).
• Write alt text for product and banner images, and mark decorative ones as decorative (WCAG 1.1.1).
• Check text and button contrast against 4.5 to 1, including sale badges and footer links (WCAG 1.4.3).
• Give every form field a visible label and a clear error message, in checkout, account and newsletter forms (WCAG 3.3.1 and 3.3.2).
• Publish the Article 13(2) statement on how the shop meets the requirements, and keep it current.

For the four EU shopping rules an app can carry, see the EU compliance apps overview.

Frequently asked questions