If you sell to EU consumers from a Shopify store, the European Accessibility Act applies to you. Being on Shopify doesn't change that, and it doesn't hand you compliance either.
This guide covers why Shopify stores are in scope, the accessibility problems that are specific to how Shopify works, and what to actually do about it.
Why Shopify stores are in scope
The EAA has been enforceable since 28 June 2025. It covers ecommerce as a service, and it applies based on who you sell to, not where you're based or what platform you're on. A UK-registered store selling to customers in Germany, France or Ireland is in scope. There is no platform exemption, no clause that says "unless you're hosted on Shopify."
For the general breakdown of who's in scope and why, see our guide on whether the EAA applies to your business.
The technical standard behind it is EN 301 549, which for web content aligns with WCAG. Shopify itself works to WCAG 2.2 Level AA as its guiding principle and publishes accessibility conformance reports (VPATs) for its Admin, its Checkout, and its Dawn theme.
Those reports cover Shopify's products. Not your store.
This is the part most merchants get wrong. Shopify's own accessibility statement is explicit that merchants have complete control over their theme code. Everything you choose, customise, install or write sits on your side of the line: your theme and its settings, your product images and alt text, your colour choices, your copy, your navigation, and every third-party app you install. Shopify being accessible is not the same as your store being accessible, and it isn't a defence if someone complains.
Pitfall 1: theme-level issues you inherit without knowing
Every theme in the Shopify Theme Store has to clear an accessibility bar to get listed: a minimum average Lighthouse accessibility score of 90 across the home, product, collection and cart pages, plus some manual review by Shopify's team.
That's a real bar, and it means a Theme Store theme is a better starting point than a random custom build. But two things follow from it that merchants rarely think through.
First, Lighthouse is an automated tool, and automated tools only catch a fraction of real accessibility issues, the commonly cited range is around 30 to 40% of known barriers. A theme scoring 90+ has cleared the automated checks. It has not been proven to work for someone navigating by keyboard or listening with a screen reader. Those are different tests, and the second one is where the serious failures live.
Second, the score applies to the theme as shipped, not to your version of it. The moment you change colours in the theme editor, you can break contrast requirements. Rearrange sections and you can break heading order. Add a custom section, edit the Liquid, or drop in a snippet a freelancer wrote two years ago, and none of it was covered by Shopify's review. Whatever the theme scored on the demo store is not what your live store scores.
Common things we find at theme level:
- Focus indicators removed or invisible against a custom background colour.
- Mega menus and mobile menus that can't be operated by keyboard.
- Product image galleries and variant selectors that a screen reader can't make sense of.
- Announcement bars that read out in the wrong order.
Pitfall 2: third-party apps injecting inaccessible code
This is the biggest and least understood risk on Shopify, because the whole appeal of the platform is how easy apps are to install.
Every app you add injects its own HTML, CSS and JavaScript into your storefront, code you didn't write, can't easily inspect, and often can't modify. Shopify publishes accessibility conformance reports for its own products; it does not publish one for the thousands of third-party apps in its App Store. The accessibility bar that applies to Theme Store themes doesn't extend to apps.
In practice, one app can undo a clean theme. The usual culprits are the ones that put something over the top of your page or interrupt the shopper:
- Email capture popups and spin-to-win wheels that trap keyboard focus so a user can't tab out or press Escape to close.
- Cookie consent banners that can't be dismissed by keyboard.
- Review widgets and star ratings with no text a screen reader can announce.
- Live chat bubbles that grab focus or sit unreachable at the very end of the tab order.
- Product filters that update results without telling assistive technology anything changed.
A special note on accessibility overlay apps
If your instinct is to solve this by installing an accessibility widget from the App Store, be careful. These are the products that promise one line of code makes you compliant. In April 2025 the FTC issued a final order requiring accessiBe to pay $1 million and barred it from claiming its automated products can make any website WCAG-compliant. Overlays don't change your underlying code, so the barriers stay exactly where they were, and their presence has increasingly been cited in complaints as a barrier rather than a fix. An overlay is not a compliance strategy and it is not a legal shield.
Pitfall 3: checkout customisation
Shopify's hosted checkout is genuinely one of the better-tested parts of the platform, Shopify publishes a VPAT for Checkout against WCAG 2.2 A/AA. You inherit that baseline, which is a real advantage over a custom-built checkout.
Where it goes wrong is customisation.
Shopify's core checkout steps, Information, Shipping and Payment, moved off checkout.liquid for every store back on 13 August 2024. That's long settled and doesn't affect most merchants today. What's still live is a narrower, later deadline: non-Plus stores have until 26 August 2026 to move their Thank You and Order Status pages off checkout.liquid, Additional Scripts and script tags, mainly affecting tracking pixels, custom post-purchase scripts and any content merchants added to those two pages. Plus stores already passed this same deadline in August 2025. After 26 August 2026, Shopify auto-upgrades unmigrated stores and removes the legacy customisations automatically.
For accessibility, this shift is mostly good news, you can no longer accidentally break Shopify's tested checkout markup by hand-editing it. But two risks remain.
The extensions and apps you add into checkout are still your responsibility. A trust badge block, an upsell offer, a loyalty points prompt, a custom delivery-instructions field, each is third-party code rendering inside the checkout, and none of it is covered by Shopify's checkout conformance report. Your payment step can be perfectly accessible and the upsell block sitting above it can be unreachable by keyboard.
And any migration that changes what renders on your checkout pages needs re-testing afterwards. If you're moving before a deadline, test the result, don't assume the new version behaves like the old one did.
Checkout is also where accessibility failures cost the most. Earlier this year we manually audited a UK independent skincare retailer's store and found a PayPal payment option that could not be reached by keyboard at all. Card worked fine; PayPal was skipped entirely in the tab order. It looked completely normal on screen, and it hadn't shown up in the automated scan we'd run first. A keyboard-only customer wanting to pay by PayPal simply could not complete the purchase.
What a Shopify store owner should actually do
- Establish where you stand, automatically. Run an automated scan across your homepage, a collection page, a product page and your cart. This is fast, free, and catches the surface-level issues worth fixing immediately, missing alt text, contrast failures, unlabelled links. Treat the result as a starting point, not a verdict. A clean automated report does not mean a compliant store.
- Test the purchase journey by keyboard. Unplug your mouse. Starting at your homepage, use Tab, Shift+Tab, Enter, Space and Escape only, and try to complete a real purchase: browse a collection, open a product, choose a variant, add to cart, remove an item, go to checkout, and select each payment method. Note anything you can't reach, anything that traps you, and anything where you can't see where you are on the page. Most merchants find something within ten minutes.
- Test with a screen reader. NVDA is free on Windows, and VoiceOver is built into macOS. You won't be expert at it, and that's fine, you're checking for obvious failures. Does your navigation make sense? Are your product images described usefully? When you remove an item from the cart, does anything get announced, or does it happen in silence?
- Audit your installed apps deliberately. List every app that renders something on your storefront. For each one, ask whether you can reach and dismiss it by keyboard. Uninstall anything you're not actually using, every app is added risk and added code. If an app is essential but inaccessible, contact the developer; some will fix it, and their answer tells you a lot about whether to keep them.
- Fix the code, not the symptoms. Contrast and alt text are usually merchant-fixable in the admin and theme editor. Focus management, keyboard traps and status announcements normally need theme code changes. Either way, the fix goes into your source code, that's what makes the barrier actually go away.
- Retest after every change. Theme updates, new apps, seasonal design changes, checkout migrations, a new product range, each can reintroduce issues you already fixed. Ecommerce sites change constantly, which is exactly why accessibility isn't a one-off project. Fix it, document it, then check it stays fixed.
- Publish an accessibility statement. State the standard you're working to, what you've done, what's still outstanding, and how someone can report a problem. Under the EAA this is part of what's expected of you, and an honest statement showing real work is far stronger than silence or an overstated claim.
If you want a fast starting point, our free scanner checks any URL and emails you the results.
It's automated, so it'll find the surface issues and miss the ones described above. That's the honest limit of any scanner, including ours.
Want a full manual audit of your Shopify checkout instead? Get in touch.