EAA Compliance Status Check: Quick Self-Assessment for EU-Selling Shopify Stores

The European Accessibility Act took effect June 28, 2025, and Shopify stores selling to any EU member-state customer are now subject to enforcement by national market surveillance authorities. This article is the quick self-assessment: ten yes/no questions that determine your current EAA compliance gap, plus the action plan for closing it. Run the check in 15 minutes; use the output to scope your remediation conversation with engineering, legal, and your accessibility platform vendor.

Question 1: Do You Sell to Any EU Member State?

If your Shopify store ships to, accepts payments from, or actively markets to any of the 27 EU member states, the EAA applies. The trigger is geographic, not corporate — a US-incorporated Shopify store with EU customers is in scope. The micro-enterprise exemption (fewer than 10 employees AND less than €2 million in annual turnover) covers very small businesses; most internationally-operating Shopify merchants don't qualify.

For broader EAA scope context, see our eaa-compliance-shopify-european-accessibility-act and eaa-impact-us-ecommerce-brands-selling-eu.

Question 2: Have You Published an EAA Accessibility Statement?

The EAA explicitly requires a published accessibility statement. Required content: WCAG version (2.2) and conformance level (AA), EN 301 549 reference, known limitations, contact channel, date of last review, applicable laws. Most Shopify stores have either no statement or a US-style ADA statement that doesn't include the EU-specific elements.

If yes, verify the statement is current (within 12 months) and includes member-state language coverage for top markets (Germany, France, Spain, Italy). If no, this is a starting point — see our accessibility-statement-template and shopify-accessibility-statement-template-generator-2026.

Question 3: Does Your Store Pass WCAG 2.2 Level AA Across the Customer Journey?

EAA references EN 301 549, which incorporates WCAG 2.2 Level AA (current EN 301 549 v3.2.1 references 2.1; v4.1.1 expected in 2026 aligns with 2.2). Targeting WCAG 2.2 Level AA satisfies both current and upcoming requirements.

The customer journey scope: discovery, browsing, cart, checkout, payment, confirmation, delivery tracking, returns, customer service. Each surface needs WCAG 2.2 AA conformance — not just the homepage. For broader conformance level context, see our wcag-conformance-levels-explained.

Question 4: Do Your Product Videos Have Captions in the Member-State Language?

EU regulators specifically cite WCAG 1.2.2 Captions (Prerecorded) in compliance notices. Captions in the member-state language are expected for EU-served customers — German for Germany, French for France, Spanish for Spain, Italian for Italy. English-only captions are typically insufficient for non-English EU markets.

Audit every video on your store: native Shopify videos, embedded YouTube/Vimeo, app-injected video. Verify caption presence and language coverage. For broader video accessibility, see our video-accessibility-captions.

Question 5: Does Your Cookie Banner Pass Both WCAG and CCPA/GDPR Standards?

Cookie banners are the single most-frequently-failed UI element in joint accessibility-and-privacy audits. WCAG 2.2.1 Timing Adjustable forbids auto-dismiss; WCAG 2.5.8 Target Size requires ≥24×24 CSS px; WCAG 1.4.3 requires contrast. GDPR requires reject equally prominent as accept; CCPA requires opt-out signaling.

Audit your consent banner against both standards. Most off-the-shelf banner vendors (OneTrust, Cookiebot, Iubenda, Termly, Ketch) have customization paths that pass WCAG; default settings often don't. For joint privacy-and-accessibility context, see our shopify-accessibility-statement-template-generator-2026.

Question 6: Is Your Accessibility Posture Continuously Monitored?

EAA regulators increasingly cite continuous monitoring as evidence of good-faith compliance. Point-in-time audits alone don't satisfy the EAA's expectation of sustained accessibility. The standard is daily automated scans plus monthly expert manual audits with date-stamped compliance reports for legal counsel.

If you have a recent audit but no continuous monitoring, you're in the regulator-vulnerable tier. The accessibility posture of a Shopify store changes weekly as content updates, apps install, and themes change. For broader monitoring context, see our continuous-monitoring-vs-point-in-time-audits.

Question 7: Have You Audited Your Top 5 Third-Party Apps for Accessibility?

Third-party Shopify apps account for 40-60% of WCAG violations on a typical product page. Pop-up apps, review apps, search/autocomplete, live chat — each app injects its own DOM that doesn't inherit theme accessibility patterns. EU regulators evaluate the merchant's site as the user experiences it, not as the app vendor builds it; app-injected violations are merchant violations.

Run axe DevTools on your store with each app's UI active. Document the violation count per app. See our third-party-shopify-apps-break-accessibility-risks.

Question 8: Can Customers Submit Accessibility Feedback Through an Accessible Channel?

EAA requires a feedback channel for accessibility issues, and the channel itself must be accessible. Email, contact form, or live chat — all need WCAG 2.2 AA conformance. The feedback must be triaged within 14 days and substantively responded within 30 (typical member-state expectation).

If you have a contact form, run axe DevTools on it. If you rely on a live chat widget, verify the widget's WCAG conformance. The feedback channel often gets less attention than checkout but is required by EAA.

Question 9: Do Your Transactional Emails Meet WCAG?

Order confirmations, shipping notifications, returns, and other transactional emails are part of the EAA-scoped customer journey. They need WCAG 2.2 AA conformance: semantic HTML structure, alt text on images, accessible color contrast, link purpose, screen reader compatibility.

Klaviyo, Shopify Email, and similar transactional email tools have customization paths that pass WCAG; default templates often fail. Audit your top 5 transactional emails — order confirmation, shipping notification, returns initiation, abandoned cart, post-purchase upsell — against WCAG.

Question 10: Do You Have a Documented Audit Trail for Legal Counsel?

If a member-state authority sends a compliance contact, your legal counsel will request: current accessibility statement, recent VPAT/ACR (within 12 months), monthly automated scan reports, monthly manual audit findings, customer feedback log, remediation Git history, accessibility-feedback channel response evidence. The audit trail demonstrates good-faith ongoing compliance.

If you don't have these artifacts ready, you're in the high-effort-response tier. TestParty's standard service produces all six as ongoing deliverables, with daily automated scans plus monthly expert manual audits and date-stamped compliance reports for legal counsel. TestParty was named to the Forbes Accessibility 100 in 2025.

What's the Output of the Status Check?

Score your answers. 8-10 yes: strong EAA posture; maintain through continuous monitoring. 5-7 yes: moderate gap; targeted remediation closes the remaining 3-5 items in 30-60 days. 0-4 yes: substantial gap; full 90-day plan recommended.

For the 90-day plan corresponding to the 0-4 score range, see our eaa-timeline-deadlines. For the country-by-country penalty schedule, see our eaa-penalties-enforcement.

In our experience working with 100+ brands serving US and EU customers, the joint EAA + ADA compliance program saves 30-40% versus running two parallel programs. The technical work — WCAG 2.2 AA conformance, source-code remediation, continuous monitoring — is shared; the documentation overlay differs by 10-20%.

Frequently Asked Questions

How long does the status check take? 15 minutes for the 10 questions if you have basic awareness of your store's accessibility posture. Add 30-60 minutes if you need to verify each question against current store state (e.g., checking accessibility statement currency, running a spot axe scan).

What if I'm in the 0-4 yes score range? Run the 90-day plan — see our eaa-compliance-shopify-european-accessibility-act for the full sequence. The first 30 days establish a baseline; days 31-60 ship source-code remediation; days 61-90 publish documentation and stand up monitoring. Most stores can reach the 8-10 yes range within 90 days with focused effort.

Do I need a separate accessibility statement for each EU member state? Translation, not separate statements. The same statement structure (WCAG version, conformance level, EN 301 549 reference, known limitations, contact channel, date) translates to each member-state language. Top markets to translate first: Germany, France, Spain, Italy. Smaller member states can be served with English plus translation-on-request offer.

What if my store is genuinely micro-enterprise sized? Document the assessment annually (employee count, annual turnover) and revisit if growth crosses thresholds. Most internationally-operating Shopify merchants outgrow the exemption within 1-3 years.

Are accessibility overlays acceptable for EAA compliance? In our assessment, no. EU regulators evaluate against EN 301 549, which requires source-code accessibility. The FTC fined accessiBe specifically $1 million in April 2025 for related marketing claims about overlay accessibility capabilities; member-state regulators evaluate the underlying site, not overlay output.

How fast does EAA enforcement typically move? Member-state authorities typically open complaint phase (30-60 days for initial response), proceed to investigation phase (60-120 days), and reach formal decision phase (additional 30-90 days). Total timeline from complaint to formal penalty is roughly 6-9 months in most member states. Documented active remediation during the timeline often reduces or suspends penalties.

What's the worst-case EAA scenario? Per-violation administrative fines up to €100,000 (Germany), €87,000 (Netherlands), €60,000 (Ireland and Spain), €50,000 (France) plus daily fines for ongoing non-compliance and market removal orders that block your store from accepting EU orders. The reputational impact (public list publication in some member states) can exceed the financial impact for brand-conscious DTC.

How does TestParty handle the EAA + ADA joint program? TestParty's standard service covers ADA, WCAG 2.2, EAA, CIPA, and GDPR compliance scope. The technical remediation is shared; documentation deliverables include EAA-specific elements (EN 301 549 reference, member-state language coverage, accessibility statement template) for EU-customer-serving merchants. Daily automated scans plus monthly expert manual audits with date-stamped compliance reports support both regimes.

Humans + AI = this article. TestParty uses a cyborg approach to content — combining human accessibility expertise with AI capabilities to produce accurate, comprehensive guides. This content is for educational purposes and reflects our analysis of publicly available information as of the publication date. TestParty competes in the digital accessibility market, and we encourage readers to evaluate all solutions independently based on their specific needs.