European Accessibility Act for Shopify merchants selling into the EU

This article is for U.S. Shopify merchants who ship to the European Union and for the agencies that manage their stores. It summarizes what Directive (EU) 2019/882, known as the European Accessibility Act or EAA, says about online stores, in plain terms and with the article numbers so your attorney can check them. It is not legal advice. The directive is applied through the national law of each member state, and the details differ by country.

Who is covered

The directive applies to e-commerce services, defined as services provided at a distance through websites and mobile apps, at the request of a consumer, with a view to concluding a consumer contract (Articles 2 and 3). The European Commission's overview of the act lists e-commerce among the covered services. A Shopify store that sells to consumers is an e-commerce service.

The company's location does not matter. 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" (Article 3). A store in Florida with EU shipping, EU currencies and EU customers is offering a service to consumers in the Union.

Who is exempt

Microenterprises providing services are exempt from the accessibility requirements and the related obligations (Article 4). A microenterprise employs fewer than ten people and has an annual turnover or an annual balance sheet total not exceeding two million euros (Article 3). Both conditions must hold. Many small Shopify merchants fall inside this exemption; many growing ones do not, and the exemption ends when the business crosses either threshold.

There is also a transition: services provided under contracts concluded before June 28, 2025 do not have to comply until June 28, 2030 (Article 32). For a store that sells one order at a time, that transition is of little use, because each new purchase is a new consumer contract.

What the store has to do

• Design and provide the service in accordance with the accessibility requirements (Article 13). For a website, that means the content and the checkout must be perceivable, operable, understandable and robust, the same four principles WCAG is built on.
• Explain how the service meets the requirements in the general terms and conditions or an equivalent document, and keep that information available for as long as the service is offered (Article 13). This is the part most ADA-remediated stores have not done.
• Correct a non-compliant service and inform the competent national authorities when the service does not comply (Article 13).

The technical yardstick used across the EU is the European standard EN 301 549, whose web content requirements are aligned with WCAG at level AA. A store remediated toward WCAG 2.2 AA is doing what that standard asks of web content.

How enforcement differs from the ADA

Under the ADA, the pressure on Shopify stores comes from private plaintiffs and their law firms, through demand letters and lawsuits. Under the EAA, each member state designates authorities that check compliance and act on complaints, and each member state sets its own penalties, which the directive requires to be "effective, proportionate and dissuasive" (Article 30). Consumers and organizations can complain to those authorities and take action under national rules. There is no industry of demand letters around the EAA today, and the risk is a regulator's order and a fine rather than a settlement. AccessibilityChecker's Shopify guide notes that penalties in Germany can reach 100,000 euros and that France adds separate annual penalties for a missing accessibility statement.

If the store was already remediated after a demand letter

Most of the work carries over. The theme fixes, the screen reader and keyboard testing and the remediation record are the same evidence a national authority would ask for. Three things are usually still missing:

1. The information duty

   A description of how the store meets the accessibility requirements, in the terms and conditions or a linked accessibility statement, written for the EU audience and kept current. The accessibility statement from the ADA work is the starting point.

2. The EU-facing parts of the store

   Translated storefronts, EU payment methods, VAT displays, cookie consent and shipping calculators are often added by apps after the remediation and need the same testing.

3. A maintenance routine

   The EAA applies for as long as the service is offered, so the store has to stay accessible through theme updates, new apps and new products. The maintenance plan from the remediation record covers this.

The remediation itself, the code behind the most common fixes and the record your attorney receives are described on the service page, in the 10 WCAG failures in almost every Shopify lawsuit and in how to document remediation for plaintiff's counsel.

Frequently asked questions

Selling into the EU?

Send your store URL and the countries you ship to at gersen@gersenmedina.com. Gersen replies with the scope for an audit that covers both the ADA exposure and the EAA requirements.