The European Accessibility Act is Directive (EU) 2019/882. It has applied since 28 June 2025 and covers, among other things, e-commerce services offered to consumers. An online store that sells to consumers in the EU falls into that category. Each member state has implemented the directive in national law.
For services, the Act provides an exemption for microenterprises. These are businesses with fewer than ten employees and an annual turnover or annual balance sheet total of no more than two million euros. The Act addresses offers to consumers, so a portal that sells to business customers only is assessed differently from a D2C store.
We are developers and not a law firm. We tell you what your store meets technically and what it does not. Whether and to what extent the law applies to you, including when your company is based outside the EU, is a question for your legal counsel. We supply the findings.
The Barrierefreiheitsstärkungsgesetz (BFSG) is the German implementation of the European Accessibility Act. It has applied since 28 June 2025 and contains the same exemption for microenterprises that offer services. For a store that sells to German consumers, the technical work is the same as for any other EU market: the purchase journey has to be usable with keyboard, screen reader and magnification.
Entering Germany usually involves more than accessibility. Language, currency and tax are set up in Shopify Markets, as described on our Shopify internationalisation page. Consent and cookie banners follow a different legal basis, which our page on privacy and consent covers. An audit only assesses whether the banner can be operated.
Trading partners and public buyers may ask about the state of accessibility. A documented audit gives you an answer you can stand behind. It names the tested pages, the criteria, the findings and the fixes, and it separates your own share from the platform and from third-party apps.
We audit against the Web Content Accessibility Guidelines (WCAG) 2.2 at level AA. The law itself does not list individual test criteria. In practice the route leads through the European standard EN 301 549, which refers to WCAG for web content, currently to WCAG 2.1 level AA. WCAG 2.2 carries the requirements of 2.1 forward and adds criteria that matter in a store anyway, such as focus visibility and the size of touch targets.
The audit combines manual testing and automated tests. Automated tests find only part of the problems. Whether a variant can be selected with the keyboard only shows when someone operates the page. An audit against WCAG is a technical finding. It is not a certificate of legal compliance, and we do not promise one.
No. An overlay places a script on top of a page whose markup stays unchanged. Missing labels, wrong semantics and components that cannot be operated with the keyboard remain. In some cases the script interferes with the assistive technology people already use.
Most findings sit in templates, components and forms and can only be fixed there. That is theme work, as described on our Shopify development page. Contrast and colour roles concern the design system, which our Shopify UX/UI design page covers.
Most barriers appear in custom components and in widgets from apps. Typical findings are colour swatches for variants without labels, error messages that are not connected to their field, light greys for prices and hints, and cart drawers and filters that do not hold the keyboard focus.
The more individual a component is, the more thoroughly it has to be tested by hand. For Gusti Leder we developed an engraving configurator with a live preview on the product image as a custom Shopify app. The Gusti Leder case study describes the migration and reports a 45% higher conversion rate. An accessibility audit was not part of that case study. We mention the project because configurators of this kind need their own pass with keyboard and screen reader in every audit.
The checkout is provided by Shopify and can be adjusted within defined limits. Your share is what you add: your own extensions, additional fields and the colours in the branding. We include these parts in the audit. Our Shopify checkout page shows what can be changed there.
We commit to findings you can follow: which criteria we tested, what we found, what has been fixed and what remains open. We do not guarantee conformity with the European Accessibility Act or the BFSG, and we do not provide a legal assessment. NICCOS has been a Shopify Plus Partner since April 2022, and the Shopify Partner Directory lists 19 reviews with a rating of 5.0.
The state you reach only lasts if accessibility becomes part of sign-off. Otherwise new sections, campaign pages and apps bring the same errors back. On request we take over the recurring check through Shopify support.
We test the purchase journey with keyboard and screen reader and add automated tests. The result is a list of findings per template with severity and affected criterion.
We correct markup, focus order, labels, error messages, contrast and the operation of components.
We record the state reached, known limitations and the test steps. That is the basis for your accessibility statement.
The European Accessibility Act is an EU directive that has applied since 28 June 2025. Germany implemented it as the BFSG.
For services, businesses with fewer than ten employees and no more than two million euros in annual turnover or balance sheet total are exempt.
The Act addresses sales to consumers. A pure B2B portal is assessed differently from a D2C store.
We supply the technical findings. Your legal counsel makes the legal assessment.
A script on top of the page does not change missing semantics in the markup and does not replace an audit.
Most findings sit in templates, components and forms and can only be fixed there.
Your own extensions, additional fields and colours in the branding belong in the audit.
Reviews, product finders, cookie banners and chat are part of your page, even if the code comes from others.
We delimit purchase journey, customer account, forms and the most important content pages.
We operate the store with the keyboard only, go through it with a screen reader and check focus and magnification.
Everything that blocks the purchase comes first: variant selection, cart, forms and error messages.
Fixes are built in a preview theme and re-tested one by one.
For apps and widgets we check settings, alternatives or a build of our own.
We record the state, set up a route for feedback and add accessibility to the sign-off of new features.
The choice of colour and size has no label, no focus style and no state a screen reader announces.
Errors appear in red next to the field but are not connected to it in code and are not announced.
Light greys for prices, hints and disabled states fall below the required contrast values.
Cart drawer, filters and modals let the keyboard focus run on behind them and do not close with Escape.
You are entering an EU market
You sell to consumers in the EU or plan to, and you need to know the technical state of the store.
Someone has reported a barrier
Users, an authority or a competitor have pointed out barriers. Then you need findings first.
The store contains custom builds
Configurator, filters, cart drawer and size guide are custom-built. That is where problems appear that no automated test finds.
The theme was bought
The vendor advertises accessibility. That does not prove it for your store with your content and apps.
The store is being rebuilt
A report on templates that will soon be replaced is outdated at launch. Accessibility then belongs in the requirements of the rebuild.
To Shopify developmentThe brand design is being revised
If colours, contrast and components are being decided anew anyway, the requirement belongs in the design.
To Shopify UX/UI designIt is about consent
Cookie banners, Consent Mode and data sharing follow a different legal basis. An audit only assesses whether they can be operated.
To privacy and consentAuditing, fixing and maintaining are three different tasks. A store rarely needs all three at once.
For stores that need to know the technical state against WCAG 2.2 AA before deciding on order and budget.
Ends with a report another team could work through as well.
For stores where the findings exist and the blocking points should be fixed.
Ends once the agreed findings are fixed and re-tested one by one.
For stores that publish new sections, campaign pages and apps on a regular basis.
Runs for as long as the store is developed further and keeps the state documented across releases.
Every figure appears in the case study, where you can verify it.
Groundies, MYCR7 and Gusti Leder are three of thirteen projects we have published with starting point, delivery and result.
We test the purchase journey with keyboard and screen reader. Afterwards you know which findings block the purchase and which can wait.
NICCOS
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