Is your Shopify webshop EAA-proof? Requirements, WCAG and fines in 2026
This article is for informational purposes only and does not constitute legal advice. Consult a specialist or the ACM for advice specific to your situation.
TL;DR — the key points at a glance
- Since 28 June 2025, the European Accessibility Act (EAA) applies to Dutch webshops
- Shopify does NOT handle compliance for you — your theme, apps and content are your responsibility
- The ACM can impose fines of up to €900,000 or 1% of annual turnover (maximum per infringement)
- Fewer than 10 employees and under €2 million turnover? You are exempt as a micro-enterprise
- Conventional automated scan tools find only 30–40% of all WCAG issues, the Toegankelijk360 AI Scan finds 60–70% — manual audit and verification remains essential
- Overlay widgets (AccessiBe, UserWay) are not a valid solution and are actively challenged
- A professional WCAG audit costs €1,500–€5,000 — far cheaper than an enforcement process
Who is this article for?
This article is specifically written for:
- Shopify store owners in the Netherlands and the EU who want to know what the EAA means for them
- E-commerce managers at brands running on Shopify
- Digital agencies building Shopify stores for clients
- SaaS and tech companies with a webshop or online ordering environment
Do you have a small store with fewer than 10 employees and turnover under €2 million? Read the section on the micro-enterprise exemption at minimum. As soon as you grow, the obligation kicks in immediately.
Want the full Shopify WCAG implementation plan?
The legal context is one thing. The step towards EAA compliance is another. Request our step-by-step Shopify WCAG implementation plan now.
Your Shopify store is probably not compliant — and you are far from alone
You've invested in a sharp store. Great product photos, a smooth checkout, strong reviews. But while you were optimising all of that, you were probably unknowingly locking out a market of millions. And since 28 June 2025, that isn't just a missed opportunity — it's a legal infringement.
Since 28 June 2025, the European Accessibility Act (EAA) applies. Your store must be accessible to people with a visual, motor, cognitive or auditory disability — people who navigate with a screen reader, who can't use a mouse, or who struggle with fast animations and auto-playing videos.
The hard reality: the ACM concluded that the majority of major Dutch webshops are still not accessible. Shopify stores face extra risk — not because of the platform itself, but because of the way you as a merchant customise themes, install apps and add content. All outside Shopify's own control and responsibility.
There is a clear path to compliance. But that path requires more than installing a plugin or running a free scanner. In this guide we explain everything: what the EAA entails, how the ACM enforces, what financial risks you face, and how to build an accessible Shopify store that holds up legally.
Must my Shopify store be accessible?
Short answer: Yes. Since 28 June 2025, the European Accessibility Act requires virtually all webshops selling to consumers to meet WCAG 2.1 AA. Only micro-enterprises with fewer than 10 employees and under €2 million turnover are exempt.
The EAA is not a vague guideline. It is hard law, transposed in the Netherlands via the Implementatiewet toegankelijkheidsvoorschriften producten en diensten (Staatsblad 2024, 87). Every webshop serving consumers in the EU falls in scope — including all Shopify stores.
The law applies if you:
- sell products or services online to consumers
- are active on the Dutch or European market
- do not qualify as a micro-enterprise (see below)
| Criterion | Exempt (micro-enterprise) | Not exempt |
|---|---|---|
| Staff | < 10 employees | ≥ 10 employees |
| Turnover / balance sheet | ≤ €2 million | > €2 million |
| Consequence for store | Full exemption for services | Full compliance required |
Note: both criteria must apply. If you exceed either threshold, the exemption lapses immediately. Plan your compliance proactively if you are near those limits.
Which services fall under the EAA?
Short answer: Every webshop where a consumer can place an order online falls under the EAA. This includes webshops for clothing, electronics, groceries, books, and all platforms with an order flow.
Article 3(30) of the directive defines e-commerce services as services provided remotely, via websites or apps, electronically and on individual request, for the purpose of concluding a consumer contract. The ACM confirms that booking sites and all online platforms with an order flow also fall under this definition.
This includes for example:
- webshops for clothing, electronics, books and groceries
- ticket sales and reservation sites
- subscriptions and digital services with an online checkout
- marketplaces and platforms with an ordering or booking flow
The technical standard: WCAG 2.1 AA via EN 301 549
Short answer: The technical standard for EAA compliance is WCAG 2.1 Level AA, integrated in the European standard EN 301 549 v3.2.1. If you demonstrably meet WCAG 2.1 AA, you legally enjoy the presumption of conformity.
A new version of EN 301 549 (v4.1.1) incorporating WCAG 2.2 is expected in 2026. If you want to be future-proof, it pays to use WCAG 2.2 as your benchmark now.
Is Shopify EAA-compliant?
Short answer: Shopify's platform itself (admin, hosted checkout, Dawn theme) has been audited against WCAG 2.2 AA. But as soon as you customise a theme, install apps or add content, you are responsible for the accessibility of your store. Shopify states this explicitly in their own Accessibility Statement.
Shopify itself — the admin platform, the hosted checkout and the standard Dawn theme — has been audited against WCAG 2.2 AA. In their official Accessibility Statement (updated 7 July 2025), Shopify explicitly states they are working on EAA compliance.
But then follows the crucial sentence every Shopify store owner must know:
"While merchants have complete control over their theme codes, we offer developer training resources on how to build accessible components."
Shopify explicitly places the responsibility for your store with you. As soon as you choose a theme, customise it, install apps or add content, you are responsible for the accessibility of the end result.
Why Shopify stores are particularly vulnerable to EAA enforcement
There are three structural reasons why Shopify stores are above-average susceptible to accessibility issues.
1. The theme pitfall
Many merchants assume that a Shopify theme is automatically accessible. Free themes like Dawn, Sense, and Refresh are a solid starting point, but not fully WCAG-proof. In practice we commonly see issues such as:
- menus that cannot be properly operated with a keyboard
- insufficient colour contrast on discount labels or buttons
- search fields and pop-ups that work poorly with screen readers
Premium themes are typically designed for visual appeal and conversion. Accessibility is rarely a priority. Complex components like mega menus, quick views, and variant selectors therefore cause the most problems.
2. The app pitfall
The average Shopify store uses 10 to 30 apps, such as:
- pop-ups
- review widgets
- cookie banners
- chat tools
- filters and search features
Each app adds its own code to your store. This code is almost never tested for accessibility. Pop-ups that trap keyboard users, chat widgets without labels, review blocks that a screen reader cannot read.
3. Dynamic content and the checkout
Shopify's standard checkout has been tested for accessibility. But as soon as you add upsells, loyalty widgets, or custom blocks via Checkout Extensibility, you as the store owner become responsible. Shopify does not review that.
The same applies to interactive features like mini carts and pages that automatically refresh: for screen readers these kinds of changes are often invisible because they are not announced.
Research by AccessibilityChecker.org (2025) found that only 11% of all cart and checkout pages meet minimum WCAG requirements — exactly the moment when you can lose a customer.
Enforcement in the Netherlands: the ACM and what they can do
Unlike in the US — where accessibility enforcement runs primarily through civil lawsuits — in the Netherlands we have an administrative law model with sector-specific supervisors.
For e-commerce services, the Autoriteit Consument & Markt (ACM) is the designated supervisor. The ACM acts both on its own initiative and based on complaints via ConsuWijzer.
Expected enforcement sequence:
- Warning with remediation deadline
- Administrative order with periodic penalty if no action is taken
- Administrative fine for continued non-compliance
| Sector | Supervisor |
|---|---|
| Webshops (e-commerce services) | Autoriteit Consument & Markt (ACM) |
| Banking and financial e-commerce | Autoriteit Financiële Markten (AFM) |
| E-readers, computers, payment terminals | Rijksinspectie Digitale Infrastructuur (RDI) |
| E-books and audiovisual media services | Commissariaat voor de Media |
| Passenger transport | Inspectie Leefomgeving en Transport (ILT) |
Consumers with disabilities can additionally file separate complaints with the College voor de Rechten van de Mens under the Equal Treatment Act.
Enforcement has already started elsewhere in Europe. In November 2025, French disability organisations sent formal legal notices to Auchan, Carrefour, E.Leclerc and Picard. Norway imposed daily fines of NOK 50,000 on an inaccessible health portal. The ACM has started a formal enforcement programme; the first fining decisions are expected during 2026.
What does non-compliance cost? More than you think
Short answer: The ACM can impose fines of up to €900,000 or 1% of annual turnover — whichever is higher. Per infringement, meaning multiple WCAG violations can stack. Enforcement follows a graduated approach: first a warning, then a penalty order, then a fine.
Under the Dutch Wet handhaving consumentenbescherming, the ACM can impose fines of up to €900,000 or 1% of annual turnover — whichever is higher. These are maximum amounts; the actual amount depends on the seriousness and duration of the infringement. Multiple WCAG violations can also stack.
Beyond direct fines, there are other cost items:
| Cost item | Indicative amount (NL) |
|---|---|
| Legal defence costs | €5,000 – €25,000 |
| Emergency remediation after complaint | €3,000 – €15,000 |
| Lost revenue from inaccessible checkout | Structural loss |
| Reputational damage | Not quantifiable |
Compare that with preventive costs:
| Service | Indicative amount |
|---|---|
| Accessibility quickscan | €750 – €1,250 |
| Full WCAG 2.2 AA audit | €1,500 – €5,000 |
| Remediation (average) | €2,000 – €8,000 |
The calculation is simple: proactive investment costs a fraction of what an enforcement process costs.
The commercial side: millions of customers dropping off right now
According to the European Commission, 87 million people with a disability live in the EU. In the Netherlands that amounts to over 4 million people with a functional disability that affects their digital use. Nearly 21% of the Dutch population is 65+ — a group growing exponentially that is disproportionately affected by inaccessible interfaces. Thuiswinkel.org estimates that webshops collectively miss out on approximately €4.2 billion per year due to inaccessibility.
An accessible store is therefore not just a compliance matter. It is an untapped market.
Why overlay widgets are not a solution for Shopify EAA compliance
Short answer: Accessibility overlays (AccessiBe, UserWay, EqualWeb) are not a valid EAA compliance solution. They mask problems in the source code instead of fixing them, and are explicitly rejected by European disability organisations and supervisory authorities.
AccessiBe, UserWay, EqualWeb and AudioEye sell "one line of code" that would make your store compliant. That doesn't work — and it can cost you dearly.
In April 2025, the FTC fined AccessiBe $1 million for misleading claims about WCAG compliance. Research data shows that sites with an accessibility widget were involved in 22.6% of all US accessibility lawsuits in 2025 — plaintiffs use the presence of an overlay as a signal that the underlying code is faulty. The European Disability Forum states explicitly: "Overlays do not make a website accessible and are not a valid basis for EAA compliance."
Invest that annual €500–€2,000 in a thorough audit and concrete remediation instead.
How Toegankelijk360 helps with Shopify EAA compliance
Toegankelijk360 is a Dutch agency specialised in WCAG audits, EAA compliance and digital accessibility for Shopify stores and other e-commerce platforms.
Why Toegankelijk360?
- Shopify specialist — daily experience with Liquid, Online Store 2.0, apps and checkout flows
- Audit and remediation — from finding to working solution, no standalone reports
- AI-assisted scanning — combined with in-depth manual review for advanced analysis
- Screen reader tests with real tools — NVDA, VoiceOver, JAWS; not just automated scanners
- EAA guidance from A to Z — from baseline to accessibility statement and ACM notification obligation
We are not a generalist that treats accessibility as an afterthought. We work daily with Shopify Liquid, Online Store 2.0 and the most common apps and checkout flows. We test with real screen readers (NVDA, VoiceOver, JAWS) and work alongside developers to structurally solve issues — not patch them.
Our audits combine AI-assisted scanning with in-depth manual review. That means we can analyse large catalogues and complex storefronts more efficiently, without sacrificing the precision that only a human expert can provide.
Receiving an ACM notice? Getting complaints via ConsuWijzer? Or want to proactively demonstrate that your store complies? We guide you through the entire process — from baseline to demonstrable compliance.
Request a no-obligation quickscan →
Frequently asked questions about Shopify and the EAA
- Does the EAA also apply to my small Shopify store?
- Yes, unless you qualify as a micro-enterprise: fewer than 10 employees and a maximum of €2 million annual turnover or balance sheet total. If you exceed either of those limits, the exemption lapses immediately.
- Is Shopify EAA-compliant?
- Shopify's platform, admin and standard Dawn theme are audited against WCAG 2.2 AA. But your theme customisations, apps and content fall outside that audit — and you are responsible for those.
- Does Shopify's standard theme automatically make my store EAA-conformant?
- No. Shopify has audited some themes, but that only covers part of the requirements. Every customisation — colours, content, apps — can break accessibility. Shopify states this explicitly.
- What happens if I receive a complaint via the ACM?
- The ACM uses a graduated approach: first a warning, then an administrative order with periodic penalty, and for continued non-compliance a fine up to €900,000 or 1% of annual turnover (maximum amounts; the actual amount depends on the seriousness of the infringement).
- Do I need to comply with WCAG 2.2, or does WCAG 2.1 AA suffice?
- Legally binding is currently WCAG 2.1 AA via EN 301 549 v3.2.1. WCAG 2.2 is expected in the European standard in 2026. We advise using WCAG 2.2 as your benchmark already.
- What does a professional WCAG audit cost in the Netherlands?
- A quickscan starts from €750–€1,250. A full WCAG 2.1 AA audit for a mid-sized Shopify store typically costs €2,000–€5,000. Remediation hours come on top of that.
- Does accessibility also help my SEO?
- Yes. WCAG requirements directly overlap with SEO best practices: semantic HTML, heading hierarchy, alt text, clear link text. Accessible sites rank significantly better and generate more organic traffic.
- Is an accessibility overlay a quick fix for EAA compliance?
- No. Overlays mask problems and are rejected by enforcement authorities and disability organisations as a valid compliance route. The FTC fined AccessiBe $1 million in 2025 for misleading claims.
- What must be in my accessibility statement?
- A description of your service, your target level (WCAG 2.1 AA / EN 301 549), current conformance status, known limitations with target date, at least two feedback channels, and an escalation route to the ACM. Publish on a dedicated page linked from your footer.
In closing: Shopify EAA compliance is an investment, not a cost
The EAA calls for a different perspective on your Shopify store. Not just as a legal obligation, but as a strategic choice.
An accessible store serves 87 million extra EU consumers, ranks better in Google, has less cart abandonment, and protects your business against fines and reputational damage. While most competitors have done nothing yet, you can distinguish yourself now.
The stores best positioned for the coming years are not just compliant — they have built accessibility into their development process. Every theme update checked, every new app tested, every quarter monitored. Not as a one-off project, but as a structural part of how they build and grow.
Don't wait for the first complaint via ConsuWijzer. Every month that passes is another month of legal risk — and another month of lost revenue from customers dropping off at your inaccessible checkout.
Plan a no-obligation introductory meeting with Toegankelijk360 today →
Want the full technical implementation plan?
The legal context is one thing. The technical roadmap is another. Contact Toegankelijk360 to receive our step-by-step Shopify WCAG implementation guide.