The European Accessibility Act (in force June 28, 2025): What Shopify Merchants Selling into the EU Should Know

What the EAA is, and the date that matters

The European Accessibility Act (EAA) is an EU directive that sets accessibility requirements for a defined set of products and services sold to consumers in the European Union. It became enforceable on June 28, 2025. From that date, in-scope e-commerce services are expected to meet the Act's accessibility requirements and to publish an accessibility statement (European Commission, EAA).

If you run a Shopify store, the part that tends to matter most is straightforward to say and harder to apply: e-commerce is named as one of the covered services, and “accessible” is measured against established technical standards rather than a vendor's marketing language. This post walks through scope, the microenterprise exemption, and the documents that help you respond when someone asks how your store measures up. It is informational, not legal advice — the specifics of how the EAA applies to any one business are a question for your own lawyer.

Does it apply to your Shopify store?

The EAA is written around “economic operators” that offer covered products and services to consumers in the EU. For an online store, the trigger is generally about the market you sell into, not the country you happen to be based in. A merchant outside the EU that markets and sells to EU consumers can still fall within scope, while the precise treatment of any given store depends on facts the law cares about and you may not have weighed yet.

That is why we keep this section deliberately high-level. Whether your store is in scope, and to what extent, depends on what you sell, who you sell it to, and how EU member states have transposed the directive into their own national law. Those are details to confirm with counsel rather than infer from a blog post. What we can say plainly: “we're a small shop, surely this doesn't apply to us” is an assumption, not an answer, and it is worth checking properly.

The microenterprise service exemption

The EAA includes an exemption on the services side for microenterprises. A microenterprise is commonly described as a business that is, broadly, under 10 staff and under EUR 2 million in annual turnover. A microenterprise providing a covered service may fall outside parts of the services obligations under the Act.

Treat that as a starting point for a conversation with your lawyer, not a blanket pass. A few reasons to be careful:

• It is a service-side exemption with conditions. It is not a general “small business is exempt from everything” rule.
• The thresholds above are the figures usually cited, but the staff-count and turnover definitions, and how they are counted, are legal details. We are hedging them as “broadly” on purpose.
• Member states transposed the directive into national law, so the exact contours of the exemption can vary by country.

Whether the microenterprise exemption actually covers your situation is a legal determination. Paperfort cannot make that call for you, and neither should a checklist. If you think you might qualify, that is precisely the kind of question to put to your counsel before relying on it.

How EN 301 549 and WCAG fit in

The EAA does not invent its own pixel-by-pixel rulebook. It leans on EN 301 549, the EU's harmonized standard for accessibility requirements for information and communication technology (ICT) products and services. EN 301 549 in turn incorporates success criteria from the Web Content Accessibility Guidelines (WCAG, W3C).

For a store owner, the practical takeaway is that the web-accessibility work maps onto a familiar target. A WCAG 2.2 Level AA baseline for your storefront lines up with the kind of technical expectations EN 301 549 reflects. It is the same conformance target that procurement teams and accessibility documents already use, which means effort spent there is not wasted if an EU question arrives.

One honest caveat belongs right here. Automated scanning, including the axe-core scan Paperfort runs, detects roughly 30 to 50 percent of WCAG issues (Deque). It is genuinely useful for catching a large, well-defined class of problems quickly, and it is not a substitute for the human judgment that the remaining criteria require. We say this plainly so you know what a scan does and does not cover.

What documentation helps

You cannot hand someone “compliance.” What you can do is keep a paper trail that shows the work, dated and specific. Three documents do most of the heavy lifting here:

• An accessibility statement on your own domain. A public, plain-language page describing your accessibility approach and a real feedback channel. The EAA's expectation that in-scope e-commerce services publish an accessibility statement is one of the more concrete requirements (European Commission, EAA).
• A WCAG 2.2 AA audit report. A dated record of what an evaluation against WCAG 2.2 Level AA found on your storefront, including the issues to fix and where automated testing reaches its limit.
• A VPAT 2.5. The Voluntary Product Accessibility Template, revision 2.5, published by the Information Technology Industry Council (ITI). VPAT 2.5 ships in several editions, including an EU edition keyed to EN 301 549, which is the version aligned with the European standard the EAA references.

Together these give you something to show: a statement a customer can read, a report your developer can act on, and a conformance document framed against the European standard. They are documentation, not legal certification, and they do not by themselves make a store compliant or settle the scope and exemption questions above.

A practical checklist

A reasonable sequence for a Shopify merchant who sells, or wants to sell, into the EU:

• Confirm in-scope status with counsel. Ask your lawyer whether the EAA applies to your store, and whether the microenterprise service exemption is realistically available to you. Do this before you rely on any of it.
• Run a WCAG 2.2 AA scan of your storefront. Get a baseline of what automated testing can catch, and a list of what it flags for human review.
• Publish an accessibility statement on your own domain. Plain language, a genuine feedback channel, and a date.
• Keep dated records. Save the audit report and the VPAT so you have a timestamped trail of what you tested and when. If a question arrives, dated documentation you can hand to your counsel is worth more than a scramble.

A note on what this is not. Nothing here is legal advice, and no document, scan, or statement “prevents lawsuits” or makes a store “ADA compliant” on its own. The legal questions about scope and exemptions belong to your lawyer. What Paperfort handles is the documentation layer: an automated axe-core WCAG 2.2 AA scan that produces an audit report, a hosted accessibility statement, and a VPAT 2.5. Automated coverage sits at roughly 30 to 50 percent of WCAG issues, so we tell you where the scan stops and a qualified professional should look further.

Where Paperfort fits

If you want the three documents above generated from one automated scan, that is what Paperfort produces: a $249 one-time bundle, or monthly plans at $29, $79, and $149. You get an audit report, a hosted accessibility statement on your own domain, and a completed VPAT 2.5 (the EU edition maps to EN 301 549). It is documentation to keep on file and hand to your developer or your counsel — not legal advice, not a compliance guarantee.

If that is useful, you can start with the audit whenever the timing is right.