The European Accessibility Act — Directive (EU) 2019/882 — has applied to services since 28 June 2025, and an online shop’s purchase flow is a covered service, which is why a Shopify merchant selling into Germany now has real duties under the BFSG, the German law that implements the directive.
The rest of this post is the working detail: who is covered, what EN 301 549 does as the presumed conformity standard, which obligations have paperwork attached, and what a merchant can honestly do about it without pretending a scan equals compliance.
Who is covered, in practice
The Act regulates the accessibility of products and services sold to consumers — and a shop’s purchase flow, from browsing to checkout, is a service. The practical test for a Shopify merchant is simple: if consumers buy from you in an EU member state, assume you are in scope for that member state’s implementation of the directive.
In Germany that implementation is the Barrierefreiheitsstärkungsgesetz (BFSG), and it is the reason German merchants see the strictest version of these requirements: a named obligation to publish an accessibility statement, and administrative fines for serious gaps.
| Instrument | What it is | Date |
|---|---|---|
| Directive (EU) 2019/882 (EAA) | The European Accessibility Act itself | In force for services since 28 June 2025 |
| BFSG | German implementation of the EAA | Applies alongside the directive |
| EN 301 549 | European ICT accessibility standard, presumed conformity | Tracks WCAG 2.1 AA |
| WCAG 2.1 AA | The web success criteria EN 301 549 builds on | The technical target for your store |
EN 301 549 is the standard you are measured against
EN 301 549 is the harmonised European standard for accessible ICT, and it is the presumed-conformity standard: meeting it is the normal way to demonstrate you meet the legal requirement. Its web chapters track WCAG 2.1 AA, so the concrete engineering task on a Shopify store is unglamorous and specific — make the purchase flow conform to WCAG 2.1 AA, and keep evidence that you did.
That is why “we ran a scan” and “we conform” are different sentences. The scan generates findings; conformance is a judgement about all the success criteria, including the ones no tool can test.
The obligations with paperwork attached
Two duties produce artifacts rather than opinions:
- An accessibility statement. In Germany, BFSG §14 requires the service provider to publish a statement with defined content — who the provider is, which standard it targets, the known gaps, and how to reach them. A statement copied into a theme page in 2025 and never touched goes stale; the useful version is dated and refreshed with each new test.
- A dated record of what was tested. A report that marks every WCAG 2.1 AA criterion pass, fail or not tested, names the tool and version, and separates what was fixed from what remains manual. This is the document a lawyer asks for when something is questioned.
Enforcement runs through national authorities, and BFSG §37 sets fines up to €100,000 for the serious categories and €10,000 otherwise. No tool promises immunity from a warning letter or a fine — what a tool can produce is the record.
Detection and fixing, not a legal guarantee
No scanner, app or consultancy can certify that your store conforms to the law. A tool reports test findings and generates document templates; the statement’s content remains yours, reviewable by a lawyer before you publish it. Treat any vendor who sells you “compliance” as a red flag.
What a merchant actually does
- Scan your purchase-flow page set against WCAG 2.1 AA and read every finding with its criterion and selector.
- Fix what can be fixed safely in the page — and preview each fix before shoppers see it.
- Triage the remainder: alternative text, focus order and content wording are human work.
- Publish an accessibility statement with defined content at a stable URL on your own domain.
- Re-test on a schedule, so the statement’s date and summary stay true.
Capyo: Accessibility WCAG EAA does steps 1 to 4: an axe-core scan of your page set, nine code-level fixes delivered through a theme app extension with preview and one-click revert, image-by-image approval of AI-generated alt text, a dated Prüfbericht PDF, and the statement published at its own URL through an app proxy. To feel the output before installing anything, the free WCAG Check Shop tool scans your homepage.
When did the European Accessibility Act start applying?
Directive (EU) 2019/882 has applied to services since 28 June 2025. In Germany the BFSG implements it, and an online shop purchase flow is treated as a covered service.
Does the European Accessibility Act apply to my Shopify store?
If you sell to consumers in an EU member state, assume yes for that member state implementation. The German BFSG is the strictest version and the one most Shopify merchants encounter first, because it attaches a statement obligation and defined fines.
What is EN 301 549?
The harmonised European standard for accessible ICT and the presumed-conformity standard for the directive. Its web chapters track WCAG 2.1 AA, so making your purchase flow conform to WCAG 2.1 AA is the practical engineering target.
Do I have to publish an accessibility statement?
BFSG §14 requires the service provider to publish a statement with defined content. Its content is yours and should be reviewed by a lawyer; the valuable version carries a date and a result summary that refresh when you re-test.
What are the fines for non-compliance?
BFSG §37 sets fines up to €100,000 for the serious categories and €10,000 otherwise. Enforcement is national and depends on the member state; no tool can promise that a warning letter or a fine will not arrive.
Free tool
WCAG Check Shop
Free check: see which WCAG 2.1 AA findings your homepage has in seconds.
Open the free toolCapyo is an independent app, not affiliated with or sponsored by Shopify. "Shopify" is a trademark of Shopify Inc. The app reports axe-core findings against WCAG 2.1 AA / EN 301 549 and generates document templates; it is not legal advice and it does not promise any legal outcome. The accessibility statement the app generates is a template to be reviewed by a lawyer, and the shop operator is responsible for its content and accuracy.