The short answer
It can, if you sell to consumers in the EU. Since June 28, 2025, the European Accessibility Act covers e-commerce services offered to EU consumers, and it looks at who you sell to, not where you are based. Microenterprises (fewer than 10 staff and no more than €2 million turnover) are exempt. The technical benchmark is EN 301 549, which uses WCAG 2.1 AA today.
WCAG (the Web Content Accessibility Guidelines) is the W3C's technical standard for accessible websites. Fines are set by each EU country. Germany allows up to €100,000.
Does the EAA apply to stores outside the EU?
Very likely, if you actively sell to consumers in the EU. The Act covers e-commerce services offered to consumers in the EU, and nothing in that definition depends on where the seller is based. That is our reading, not a court ruling. In practice, EU regulators have limited reach over a store with no EU presence, but EU customers, marketplaces and partners can still ask you to meet it.
The European Accessibility Act (EAA) is Directive (EU) 2019/882. EU countries had to turn it into national law by June 28, 2022, and it has applied since June 28, 2025. Each country's law is what an authority actually enforces, so the details and the fines differ by country.
Enforcement is still early. A European Commission page noted in September 2026 that accessibility complaints remain rare. That gives stores time to fix things calmly, but it is not a reason to wait.
What counts as an e-commerce service
The Act lists e-commerce services among the services it covers (Article 2(2)(f)). It defines them as services provided at a distance, through websites and mobile apps, by electronic means, at the consumer's request, with a view to concluding a consumer contract (Article 3(30)).
For a Shopify store, that is the whole path a shopper takes to buy: the storefront, product pages, search and filters, the cart and the order process. Shopify runs checkout itself, so check Shopify's own accessibility reports for that part and focus on what you control.
The microenterprise exemption
A microenterprise has fewer than 10 staff and an annual turnover or balance sheet total of no more than €2 million (Article 3(23)). Microenterprises that provide services are exempt from the service accessibility requirements (Article 4(5)).
| Store | Staff | Turnover | Exempt |
|---|---|---|---|
| Store A | 4 | €900,000 | Yes |
| Store B | 8 | €3 million | No, turnover is over €2 million |
| Store C | 14 | €1.5 million | No, 10 or more staff |
Even if you are exempt, accessible pages still help you sell to more people, and your larger EU partners or marketplaces may ask for it in their contracts.
What the EAA asks of an online store
In plain words, a covered store needs to do four things.
- Make the service accessible. The accessibility requirements are in Annex I of the Act. For a website, meeting the harmonised standard EN 301 549 is the accepted way to show it.
- Publish service information. Annex V asks you to explain how your service meets the requirements. Most stores do this in an accessibility statement.
- Keep it up. You must show that your processes keep the service accessible over time, not just on the day you fixed it.
- Document any exception. If a requirement would be a disproportionate burden, you must assess and record it (Article 14).
There is a transition rule (Article 32): service contracts agreed before June 28, 2025 may continue until they expire, for up to 5 years, and products already used to provide a service may continue until June 28, 2030. This rarely helps a store's own website, so plan to meet the rules now.
EN 301 549 and WCAG 2.1 AA today, WCAG 2.2 next
EN 301 549 is the European standard for accessible technology. Its web section is WCAG. Version 3.2.1 uses WCAG 2.1 AA, and it is the version that currently gives a “presumption of conformity”. That means if your site meets it, authorities start from the view that you meet the Act.
Version 4.1.1 was published on September 2, 2026 and moves the web section to WCAG 2.2 AA. It gives that presumption only once it is cited in the Official Journal of the EU, which had not happened as of October 16, 2026.
Aim for WCAG 2.2 AA now
What this means for each part of a Shopify store
The Act looks at the whole service a shopper uses to buy. On Shopify, some of that is yours and some is Shopify's.
| Part of the store | Who controls it | What to do |
|---|---|---|
| Checkout | Shopify | Read Shopify's checkout accessibility report. Check your brand colours there. |
| Theme | You | Fix labels, focus, headings, contrast and pop-ups, or have a developer do it. |
| Product images and video | You | Write alt text for every image. Caption videos. |
| Apps | You choose them | Test review, chat, upsell and pop-up apps. Ask vendors for fixes. |
| Languages | You | Set the right page language for each market, which WCAG asks for (3.1.1 and 3.1.2). |
If you translate your store for EU markets, check each language version, not only English. Alt text, button labels and your accessibility statement need translating too.
The accessibility statement
Annex V asks service providers to make information available on how the service meets the accessibility requirements. It is usually placed in the terms and conditions or an equivalent page, and it must itself be accessible. It should cover:
- a general description of the service, in accessible formats
- how the service works, explained so people with disabilities can understand it
- which accessibility requirements you meet and how
In practice, an accessibility statement page does the job. Add what you know is not fixed yet, how customers can get help or order another way, and the date you last reviewed it. In German this page is usually called a Barrierefreiheitserklärung. Our statement generator drafts one you can edit.
Disproportionate burden: how to claim it
If meeting a requirement would be a disproportionate burden, or would fundamentally change your service, the Act lets you claim an exception (Article 14 and Annex VI). It is not a simple opt-out. You must:
- assess the burden against the criteria in Annex VI
- write the assessment down and keep it for 5 years
- renew it at least every 5 years
- tell the relevant authorities, unless you are a microenterprise
For most stores, the common fixes (alt text, labels, contrast, keyboard access) are small, so this exception is unlikely to cover them.
Fines and enforcement by country
Article 30 leaves penalties to each EU country. They must be “effective, proportionate and dissuasive” and come with orders to fix the problem. Market surveillance authorities in each country can also order a non-conforming service to be changed or stopped.
| Country | Law | Maximum fine |
|---|---|---|
| Germany | Barrierefreiheitsstärkungsgesetz (BFSG), § 37 | €100,000 for the main violations, €10,000 for others |
| Other EU countries | National laws putting the EAA into effect | Set by each country. Check the law where your customers are. |
We list only amounts we have checked against the law itself. Figures for other countries circulate online, but we have not confirmed them, so we leave them out.
Germany: the BFSG in short
Germany's law is the one merchants ask us about most. The Barrierefreiheitsstärkungsgesetz (BFSG) is Germany's law that puts the EAA into effect. Section 37 sets fines of up to €100,000 for the main violations and up to €10,000 for others.
Start with the EAA's microenterprise exemption for services and check whether it covers you. For German-language help, a German lawyer or your local chamber of commerce (IHK) is the right next step.
Does the European Accessibility Act apply to the UK?
Not as UK law. The UK is not in the EU, so the EAA does not apply to sales inside the UK. A UK store that sells to consumers in EU countries is in the same position as a US or Canadian store: those EU sales can be covered.
Sales inside the UK fall under UK law, which this page does not cover. Check it separately with a UK adviser.
Does Europe have something similar to ADA?
Yes. The European Accessibility Act is the closest match for online stores, though it works differently. The ADA is a broad civil rights law enforced mostly through private lawsuits. The EAA lists specific products and services, including e-commerce, and each EU country enforces it through its own authorities, with fines and orders.
| Point | ADA (United States) | EAA (European Union) |
|---|---|---|
| Technical standard | None in the law. Courts use WCAG 2.1 AA. | EN 301 549, which uses WCAG 2.1 AA today |
| Who enforces it | Mostly private lawsuits and demand letters | Authorities in each EU country |
| Statement required | No, but settlements often require one | Yes, in effect (Annex V service information) |
If you sell in both places, read our ADA guide too. The same WCAG 2.2 AA work counts for both.
What a store outside the EU should do
Six steps, in order. None of them needs an EU office.
- 1
Check whether you sell to EU consumers
Look at your Shopify Markets settings and last year's orders. If you ship to EU countries and accept orders from consumers there, assume the Act can apply. - 2
Check the microenterprise test
Fewer than 10 staff and €2 million or less in turnover or balance sheet total. You must meet both. - 3
Work toward WCAG 2.2 AA
Fix the buying path first: product pages, variant pickers, cart, pop-ups and contact forms. WCAG 2.2 AA covers the WCAG 2.1 AA in today's EN 301 549 and the newer version. - 4
Publish an accessibility statement
Describe how your store works for people with disabilities, which requirements you meet, what is still open and how to reach you. Add it as a page in Shopify and link it from your footer. - 5
Document anything you cannot fix yet
If a change would be a disproportionate burden, write down why, keep it for 5 years and review it at least every 5 years. - 6
Keep a dated record
Save scans, fixes and who approved them. It shows your process keeps the store accessible over time, which Annex V also asks for.
Check your store against the EAA
Answer a few questions and get a list of what applies to you.
Selling from Canada? Our guide to AODA compliance and Canadian accessibility laws covers the rules at home. The federal Canadian rules use the same EN 301 549 standard.
Questions store owners ask
When did the European Accessibility Act start?
It has applied since June 28, 2025. EU countries had to turn it into national law by June 28, 2022. Service contracts agreed before June 28, 2025 may run until they expire, for up to 5 years.
Does the EAA cover mobile apps?
Yes, for e-commerce. The Act defines e-commerce services as those provided through websites and mobile device-based services. If you have a shopping app for EU consumers, it counts too.
Is my small store exempt from the EAA?
If you have fewer than 10 staff and your annual turnover or balance sheet total is €2 million or less, yes, for the service rules. You must meet both conditions. A store with 8 staff and €3 million turnover is not a microenterprise.
Which WCAG version does the EAA use?
The EAA itself names no WCAG version. Its harmonised standard, EN 301 549 v3.2.1, uses WCAG 2.1 AA. Version 4.1.1, published September 2, 2026, moves to WCAG 2.2 AA once it is cited in the EU's Official Journal. Working toward WCAG 2.2 AA covers both.
Do I need an accessibility statement for the EAA?
In effect, yes. Annex V asks service providers to publish how the service meets the accessibility requirements, usually in the terms and conditions or a similar page. Most stores do this with an accessibility statement.
What are the fines under the European Accessibility Act?
Each EU country sets its own. Germany's law, the BFSG, allows fines of up to €100,000 for the main violations and up to €10,000 for others. Authorities can also order a service to be changed or stopped.
Does the EAA apply to B2B stores?
The e-commerce rules cover services offered to consumers, at the consumer's request, to conclude a consumer contract. A store that sells only to businesses is generally outside that part. If you sell to both, the consumer side counts. Ask a lawyer if your case is unclear.
Can Inclusely make my store EAA compliant?
No tool can promise that. Inclusely helps you find and fix barriers against WCAG 2.2 AA, drafts an accessibility statement you review, and keeps a dated record of the work.
This page explains the law in general terms. It is not legal advice. For advice about your business, speak with a lawyer.

