Does your online shop meet the European Accessibility Act? How to check it in ten minutes
The European Accessibility Act has applied to online shops since 28 June 2025. If you sell to consumers in the EU, your shop is probably covered, even if you are based outside the EU.
The technical bar is WCAG 2.1 Level AA. The law points to the harmonised standard EN 301 549, and that standard includes WCAG 2.1 AA in full.
There is one real exemption: micro-enterprises that provide services, meaning fewer than 10 staff and annual turnover or balance sheet of €2 million or less.
Most shops fail on the same handful of problems, and most of them take minutes to fix in a Shopify or WooCommerce theme.
Who the law covers
The European Accessibility Act (Directive (EU) 2019/882) covers e-commerce services offered to consumers in the EU. Each member state has written it into national law: in Germany it is the Barrierefreiheitsstärkungsgesetz (BFSG), in France it sits in the law on accessibility of products and services, and so on. The obligations are close to identical across the EU.
What decides whether you are covered is who you sell to, not where your company is registered. A UK or US shop that ships to customers in Germany or France is offering an e-commerce service in the EU.
The exemption is narrow. It applies to micro-enterprises providing services: fewer than 10 people and annual turnover or balance sheet total of no more than €2 million. Both conditions must hold. A five-person shop turning over €3 million is not exempt, and neither is a 12-person shop turning over €1 million.
What it actually asks of a shop
In practice, the law asks that someone using a screen reader, a keyboard, voice control or zoom can find a product, understand it, and complete a purchase. Measured technically, that means meeting WCAG 2.1 Level AA, plus a few service-specific duties:
- the product pages, basket and checkout are usable without a mouse and readable by assistive technology;
- images that carry information have a text alternative;
- every form field (search, newsletter, address, payment) has a proper label;
- text has enough contrast and the page can be zoomed;
- you publish information about how your service meets the requirements, usually an accessibility statement (free generator).
The ten-minute check
Start with an automated check of your home page and one product page. It will not tell you everything (see below), but it finds the failures that are easiest to prove, which are also the ones a regulator's or a claimant's own scan will find first.
Run the free check on your shop. It takes about thirty seconds, needs no account, and lists each failure with the WCAG criterion it breaks.
Across a million home pages, the WebAIM Million study finds the same six problems year after year. Here is where each one usually lives in a shop theme:
| Failure | Share of home pages | Where it usually is in a shop |
|---|---|---|
| Low contrast text | 83.9% | Light grey prices, "sale" badges, placeholder text, footer links |
| Missing alternative text | 53.1% | Product images, collection banners, logos used as links |
| Missing form labels | 51.0% | The newsletter box in the footer, the search field, "sort by" selects |
| Empty links | 46.3% | Cart, account and social icons with no text |
| Empty buttons | 30.6% | Icon buttons: close, menu, quantity plus and minus |
| Missing document language | 13.5% | The lang attribute on the page's html element |
Our own run over 1,352 German home pages, each loaded in a real browser so that elements a site hides on screen were not counted, found the same pattern: 95.8% had at least one confirmed failure, and the most common was a link with no accessible name, on 39.2% of pages. (Updated 11 October 2026: the first run, in September, read the raw HTML and so also counted elements the sites hide on screen; it reported 96.6% and 40.5%. The method change is explained in the study.)
Fixing them in Shopify
- Product images: Products → choose a product → click an image → "Add alt text". This fixes it at the source for every theme.
- Icon links (cart, account): in the theme's header section, add visually hidden text or an
aria-labelto the link, and mark the iconaria-hidden="true". - Newsletter field: give the input a
labelelement. A placeholder is not a label: it disappears as soon as someone types.
Fixing them in WooCommerce
- Product images: Media Library → the image → "Alternative Text".
- Mini-cart and account icons, sort select, search field: usually in the theme's header and archive templates. Add a label to each control.
- Variation swatches: swatches built from
divelements with click handlers cannot be reached by keyboard. They need to be buttons or radio inputs.
What no automated check can tell you
Automated testing finds roughly a third of accessibility barriers. It cannot judge whether alt text is accurate, whether the focus order makes sense, or whether a keyboard user can actually finish a purchase. Two manual tests cover a lot of what is left:
- The keyboard test. Put the mouse away. Using only Tab, Shift+Tab, Enter and the arrow keys, add a product to the basket and reach the payment step. If you get stuck, lose track of where you are, or a pop-up traps you, so will your customers.
- The zoom test. Zoom the browser to 200%. Nothing should overlap or disappear, and the checkout button should still be reachable.
A clean automated result is a good start, not conformance. Anyone who tells you otherwise is selling something.
What happens if a shop does not comply
Enforcement is by national market-surveillance authorities, with fines set in national law. Reported maximums range from around €60,000 in Ireland to around €900,000 in Sweden; Germany allows up to €100,000 per violation, and France €5,000 to €250,000 plus periodic penalties. In Germany there is a second, faster route: since August 2025, shops have been receiving private warning letters (Abmahnungen) over accessibility failures. Our German guide covers what to do if you receive one.
An accessibility widget will not make a shop compliant. Overlays add a toolbar on top of the page but leave the underlying markup as it was, which is what the law and every automated scan look at. In 2025 the US Federal Trade Commission fined the best-known overlay vendor $1 million for claiming otherwise.
Where to go from here
- Free check of any page, with no account, showing every confirmed failure with its WCAG criterion.
- Chrome extension, which checks the page as your browser rendered it, including logged-in pages such as the checkout.
- WordPress plugin, which runs the same checks from wp-admin.
- The Fix Pack ($99, one-off), which shows every occurrence with its line and markup and the code to fix it on your platform.
Sources
- Directive (EU) 2019/882 (European Accessibility Act), in particular Article 2, Article 4(5) and Annex I
- EN 301 549, the harmonised standard for ICT accessibility, which incorporates WCAG 2.1 Level AA
- WebAIM Million, 2026 edition: webaim.org/projects/million
- Penalty ranges: Level Access, "Penalties for EAA non-compliance" (vendor summary of national laws)
- Federal Trade Commission settlement with accessiBe, 2025
- Limen, study of 1,352 German home pages (September 2026, re-measured in a browser on 11 October 2026)
This article is not legal advice. It describes the law in general terms as of 4 October 2026. Whether your business is covered, and what you must do, depends on your circumstances; a lawyer in your jurisdiction can tell you.