What the European Accessibility Act actually requires of a Shopify store

Most of what is written about the EAA is written by companies selling accessibility software, and it all reaches the same conclusion. Here is the version that starts by telling you the law may not apply to you at all.

This is not legal advice. We build accessibility tooling, not law practices. Everything below is sourced and linked so you can check it, and if the answer matters to your business you should ask a lawyer rather than a blog post — including this one.

First: you may be exempt

The EAA exempts microenterprises from its service obligations. A microenterprise is a business with fewer than 10 employees and an annual turnover or balance sheet total of no more than €2 million.

E-commerce is a service under the Act. So if your Shopify store is run by fewer than ten people and turns over less than €2 million, the EAA's service requirements do not apply to you.

That describes a very large proportion of Shopify merchants. It is also the single most important fact in this article, and you will notice it is rarely the first thing an accessibility vendor tells you.

Two things to be careful about. The exemption covers services, not products — if you manufacture a covered product, the product obligations still apply. And the thresholds are about your business, not your store: ten employees means ten employees, however few of them touch the website.

If you are not exempt, does it apply to you?

The EAA applies to businesses serving EU consumers, regardless of where the business is based. A shop in Ohio that ships to Ireland is in scope. A shop in Ireland that only sells domestically is in scope. A shop that blocks EU traffic entirely is not — which is a strategy some merchants have chosen, and it is worth understanding as an option rather than discovering as an accident.

The Act took effect on 28 June 2025.

What the standard actually is

The EAA itself does not contain a list of things your website must do. It points to a harmonised standard, EN 301 549, which for web content incorporates WCAG 2.1 Level AA.

So the operative benchmark today is WCAG 2.1 AA. A new version of the European standard, EN 301 549 v4.1.1, is expected during 2026 and is likely to incorporate WCAG 2.2 once published in the Official Journal — but until that happens, 2.1 AA is what the current harmonised standard points at.

This matters practically. WCAG 2.2 is a superset of 2.1: it adds nine success criteria and removes one. Testing against 2.2 therefore covers 2.1 and then some, which is why Remedy reports against 2.2 and maps every finding to its EN 301 549 clause. You are not choosing between them.

What that means for a Shopify store in practice

WCAG 2.1 AA is roughly fifty success criteria. On a typical Shopify storefront, a handful of them account for almost all of the failures:

  • Text contrast (1.4.3). The single most common failure on almost every store we have scanned. Brand colours chosen for a logo rarely clear 4.5:1 as body text.
  • Images without text alternatives (1.1.1). Every product photo without alt text is a product a blind shopper cannot identify.
  • Controls without accessible names (4.1.2). Icon-only buttons — cart, search, the mobile menu — that a screen reader announces as "button" and nothing else.
  • Link purpose (2.4.4). Five links all reading "Read more" tell a screen-reader user, who often navigates by listing links, five identical things.
  • Target size (2.5.8, added in 2.2). Quantity steppers and colour swatches smaller than 24×24 pixels, which anyone with a tremor cannot hit reliably.

What automated testing can and cannot tell you

An automated scan — ours or anyone's — detects a portion of WCAG failures. It is very good at the measurable ones: contrast ratios are arithmetic, a missing alt attribute is either there or not, a target is either 24 pixels or it is not.

It cannot judge whether your alt text is accurate, whether your heading structure is logical, whether an error message is understandable, or whether someone can complete a purchase using only a keyboard in a sensible order. Those require a person, and anyone who tells you a scan is sufficient is describing a product, not the standard.

This is why no software can tell you that your store meets EN 301 549, and why any tool that says it can is making a claim it cannot support. In 2025 the US Federal Trade Commission fined an accessibility-overlay vendor $1 million over that kind of claim.

A reasonable order of work

  1. Establish whether you are in scope at all. Employee count, turnover, and whether you sell to EU consumers. If you are a microenterprise, the service obligations do not apply and the rest of this is a quality decision rather than a legal one.
  2. Run a scan and read the results. You need to know the size of the problem before you can judge anything else. This costs nothing.
  3. Fix the mechanical failures. Contrast, alt text, target sizes. These are the bulk of the count and the least judgement-dependent.
  4. Get a person to test what a scanner cannot. Keyboard-only checkout, screen reader through a purchase, form errors. A few hours of a professional auditor's time answers questions no tool can.
  5. Keep a dated record. Whatever your position turns out to be, being able to show what you found and what you did about it, with dates, is materially different from having nothing.

Where Remedy fits

Remedy does steps 2, 3 and 5. It scans your storefront with axe-core, maps every finding to its WCAG 2.2 criterion and EN 301 549 clause, corrects contrast, target sizes and missing image descriptions — verifying each correction by re-testing before it is applied — and keeps a dated record you can export as a PDF.

It does not do step 1, and it does not do step 4. It will not tell you whether the EAA applies to you, and it will not tell you that your store meets any standard. What it gives you is numbers against named criteria, which is the part a machine can be trusted with.

How Remedy works

Sources

Related

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