
Yes, the European Accessibility Act (EAA) applies to Shopify stores selling to EU customers (even if the Shopify store is headquartered or based in the United States or another country). The directive specifically includes e-commerce services within its scope.
What the Directive Says About E-commerce
The EAA explicitly defines e-commerce services in Article 1(30) as:
“‘e-commerce services’ means services provided at a distance, through websites and mobile device-based services by electronic means and at the individual request of a consumer with a view to concluding a consumer contract”
The directive states that e-commerce services are included in Article 2(2)(f):
“This Directive applies to the following services provided to consumers after 28 June 2025: … (f) e-commerce services.” (Article 2(2))
Recital 43 clarifies:
“The e-commerce services accessibility obligations of this Directive should apply to the online sale of any product or service”
This definition clearly encompasses Shopify stores, which are ecommerce websites that electronically enable consumers to purchase products.
Scope of Application
The directive makes it clear that e-commerce accessibility requirements apply broadly:
“Some activities that take place via websites and mobile applications of public sector bodies, such as passenger transport services or e-commerce services, which fall within the scope of this Directive, should in addition comply with the applicable accessibility requirements of this Directive in order to ensure that the online sale of products and services is accessible for persons with disabilities… (Recital 46)
The Four Principles
The Directive adopts the four principles of web accessibility taken from the Web Content Accessibility Guidelines (WCAG):
“The four principles of accessibility of websites and mobile applications, as used in Directive (EU) 2016/2102, are: perceivability, meaning that information and user interface components must be presentable to users in ways they can perceive; operability, meaning that user interface components and navigation must be operable; understandability, meaning that information and the operation of the user interface must be understandable; and robustness, meaning that content must be robust enough to be interpreted reliably by a wide variety of user agents, including assistive technologies. Those principles are also relevant for this Directive.” (Recital 47)
This effectively means that conformance with WCAG 2.1 AA or WCAG 2.2 AA will very, very likely meet the technical accessibility requirements contained in Annex I.
Microenterprise Exception
The directive does provide limited exceptions:
“This Directive contains exemptions for microenterprises providing services” (Recital 35)
However, this exception only applies to microenterprises (typically fewer than 10 employees and annual turnover under €2 million) providing services. Product sales may still be covered.
Disproportionate Burden
The directive does allow for a “disproportionate burden” defense, but sets a high bar. According to Annex VI, businesses must assess:
“Ratio of the net costs of compliance with accessibility requirements to the overall costs (operating and capital expenditures) of manufacturing, distributing or importing the product or providing the service for the economic operators”
This assessment must be documented and considers factors like business size and resources.
Conclusion
The EAA unequivocally applies to Shopify stores selling to EU customers. The directive’s definition of e-commerce services, combined with its explicit statements about online sales, makes it clear that all online stores—including those on Shopify—must comply with accessibility requirements by June 28, 2025.
The only potential exceptions are for microenterprises, and even then, the exception is limited. Store owners should now ensure their sites meet the four principles of accessibility: perceivable, operable, understandable, and robust.
If you need help making with EAA compliance for your Shopify store, we’d love to help. Send us a message below and we’ll be right back with you.