Shopify accessibility checklist for the European Accessibility Act (WCAG 2.2)

The European Accessibility Act has covered e-commerce since 28 June 2025. Unless you're a microenterprise (fewer than 10 staff and no more than €2 million turnover or balance sheet), a store selling to EU consumers must be "perceivable, operable, understandable and robust". In practice the benchmark is WCAG 2.1 AA today, moving to WCAG 2.2 AA.

This is a developer's checklist, not legal advice. Each EU country wrote the act into its own law, so check yours. In Ireland, for example, it became S.I. No. 636 of 2023, and the Competition and Consumer Protection Commission publishes guidance for businesses.

Who the act covers

For an online store, the directive asks for four things:

• The website and any mobile app must be "perceivable, operable, understandable and robust" (Annex I, Section III).
• You pass on accessibility information about the products you sell when the manufacturer provides it (Annex I, Section IV).
• Identification, security and payment functions must be accessible too (same section). Shopify runs the checkout, but anything you add to it is yours.
• You publish information on how your service meets the requirements, in your terms and conditions or an equivalent document (Annex V). An accessibility statement page, linked from the footer and from your terms, is a practical way to do this.

Penalties are set by each member state, and Article 30 says they must be "effective, proportionate and dissuasive".

Where WCAG fits in

The act itself never mentions WCAG. It sets functional requirements and lets harmonised standards show that you meet them. For websites that standard is EN 301 549. Version 3.2.1, from 2021, is built on WCAG 2.1. Version 4.1.1, published by ETSI in September 2026, adopts WCAG 2.2 Level AA. A standard only gives you a "presumption of conformity" once the Commission cites it in the Official Journal of the EU. As of 5 November 2026 that hadn't happened, and Deque expected it around 30 November 2026.

WCAG 2.2 has been a W3C Recommendation since October 2023, and the current edition is dated 12 December 2024. W3C says a site that conforms to WCAG 2.2 also conforms to 2.1, so if you're fixing a store now, build to 2.2.

What WCAG 2.2 adds, in Shopify terms

Six of the new success criteria are at level A or AA:

WCAG 2.2 also drops 4.1.1 Parsing, which W3C now treats as obsolete. Shopify already asks Theme Store themes for touch targets of at least 24 by 24 CSS pixels, so a current Theme Store theme should start in decent shape on 2.5.8. That review doesn't cover your custom sections or the widgets your apps add.

The checklist, page by page

The WCAG success criterion for each item is in brackets, so you can look it up.

On every page

• A skip link to the main content that appears when it receives focus (2.4.1).
• A visible focus style on every link, button and field. Never outline: none without a replacement (2.4.7).
• The menu, mega menu, search, cart drawer and pop-ups work with Tab, Enter, Space and Escape, and focus returns to where it was when they close (2.1.1, 2.1.2, 2.4.3).
• Text contrast of at least 4.5:1, or 3:1 for large text, and 3:1 for icons, borders and form controls (1.4.3, 1.4.11).
• Pinch zoom left on, with no maximum-scale or user-scalable=no in the viewport tag (1.4.4).
• The page language set on the <html> element (3.1.1).
• Sticky bars and chat bubbles that never cover the focused element (2.4.11).
• Help and contact links in the same place on every page (3.2.6).

Collection pages

• Product images with useful alt text, or empty alt text where the product name is already in the card (1.1.1).
• Filters and sorting built as labelled form controls, with the new result count announced when it changes (1.3.1, 4.1.3).
• Price range filters that accept typed values as well as dragging (2.5.7).
• Sale and regular prices told apart in text, so a screen reader doesn't read out two prices with no context (1.3.1).
• Pagination and "load more" buttons that work from the keyboard and are big enough to tap (2.1.1, 2.5.8).

Product pages

• Gallery thumbnails and zoom usable from the keyboard, and alt text written for each product image (2.1.1, 1.1.1).
• Variant options grouped and labelled, with swatches named in text as well as shown in colour (1.3.1, 1.4.1).
• Price and availability changes announced when the shopper picks another variant (4.1.3).
• Quantity buttons and swatches of at least 24 by 24 CSS pixels (2.5.8).
• Captions on videos, and no sound that plays on its own (1.2.2, 1.4.2).
• Review widgets, size charts and other app content tested like the rest of the page, because shoppers can't tell where your theme ends and an app begins.

Cart, forms and pop-ups

• Every field with a visible label, error messages in text and the right autocomplete value (1.3.1, 3.3.1, 1.3.5).
• Cart changes, such as removing an item, announced to screen readers (4.1.3).
• Newsletter and discount pop-ups that move focus inside, close with Escape and hand focus back afterwards (2.1.2, 2.4.3).
• Custom forms that don't ask for the same information twice (3.3.7).
• Anything you add to checkout, such as a checkout UI extension, tested on its own.

Content

• Headings in order, with one h1 per page (1.3.1, 2.4.6).
• Link text that makes sense out of context, so no bare "click here" (2.4.4).
• An accessibility statement page linked from the footer (EAA Annex V).

How I test a store

My audits run axe-core through Playwright on four page types: home, a collection, a product page and the cart. This is the accessibility call in my audit pipeline:

await axe.run(document, {
  runOnly: {
    type: 'tag',
    values: ['wcag2a', 'wcag2aa', 'wcag21a', 'wcag21aa'],
  },
})

Those four tags cover WCAG 2.0 and 2.1 at levels A and AA. To include axe-core's WCAG 2.2 check, add 'wcag22aa' to the list. Right now that tag holds one rule, target-size, which axe-core leaves switched off by default (rule list) and runs when you ask for the tag.

Big violation counts usually come from a few root causes. On one store a single colour token produced 482 contrast flags, and fixing the token cleared every one of them. So I group the results by rule and map each to its WCAG success criterion, and the report lists the causes, each with its fix.

Automated scans cover only part of WCAG. In Deque's study of more than 13,000 pages, automated axe-core tests found 57% of all issues by volume, but those issues fell under only 16 of the 50 WCAG 2.1 AA success criteria. That is why the audit adds keyboard and focus checks by hand. The same goes for Lighthouse: its accessibility score is a weighted set of automated pass-or-fail checks, and the manual checks it lists don't count towards it, so a score of 100 still needs a manual check.

What Shopify covers and what you cover

Shopify's accessibility page says it tests its products for WCAG 2.2 Level AA and publishes conformance reports. The checkout's report is against WCAG 2.2 A and AA, and the report for the Dawn theme (version 2.4.0) is against WCAG 2.1 A and AA. The same page notes that merchants have complete control over their theme code. Your theme customisations, the apps on your storefront and your content are yours to get right.

An overlay widget doesn't move that responsibility. In April 2025 the US Federal Trade Commission ordered overlay vendor accessiBe to pay $1 million and barred it from claiming its automated product can make any website WCAG-compliant.

When you don't need a developer

A lot of this is content work you can do in the Shopify admin: alt text for product and theme images, colour choices in the theme editor, headings and link text in pages and blog posts, captions on videos and the accessibility statement page itself. If you're a microenterprise the act's service rules don't apply to you, although shoppers who use a keyboard or a screen reader still need to be able to buy.

When to hire an agency instead: if you need a formal conformance report, such as a VPAT, for a procurement process, or testing with disabled users, a specialist accessibility firm is the right buy. A developer audit like mine finds the problems in your theme and apps and tells you how to fix each one.

If you want your store scanned against WCAG 2.1 AA, with keyboard checks and the fixes ranked, my fixed-price Shopify store audit covers it.