The European Accessibility Act (EAA) became enforceable for ecommerce services on June 28, 2025. Unlike previous accessibility guidelines, the EAA is a legal obligation backed by national enforcement bodies across all 27 EU member states — not a voluntary best-practice standard. This checklist covers the 12 most critical WCAG 2.1 AA requirements that online stores must meet, with platform-specific implementation guidance.
Why WCAG 2.1 AA is the baseline
The EAA references EN 301 549, the European standard for ICT accessibility, which in turn maps to WCAG 2.1 level AA as its core requirement for web content. Meeting WCAG 2.1 AA is the minimum legal threshold — WCAG 2.2 compliance (which adds 9 new criteria) is becoming the expected standard but is not yet legally mandated in the EAA framework.
Checklist: 12 critical WCAG 2.1 AA requirements for ecommerce
1. Image alternative text (WCAG 1.1.1)
Every product image, banner, and icon must have descriptive alt text. Empty alt text (alt="") is only acceptable for purely decorative images. For product photos, alt text should describe the product, not just say "product image". For informational icons, describe the function.
Shopify: Edit each product image in the product editor → "Edit alt text". WooCommerce: Media Library → click each image → "Alternative Text" field.
2. Keyboard navigation (WCAG 2.1.1)
Every interactive element — buttons, links, menus, forms, and modals — must be reachable and operable using only a keyboard (Tab, Shift+Tab, Enter, Space, arrow keys). Test by unplugging your mouse and navigating your entire checkout flow.
Common failures: dropdown navigation menus that only work on hover, custom carousels without keyboard controls, modal dialogs that trap keyboard focus.
3. Visible focus indicator (WCAG 2.4.7)
When using keyboard navigation, the currently focused element must have a visible outline. Many themes remove the default browser focus ring with outline: none in CSS to satisfy designers — this is an accessibility violation. Replace with a custom focus ring: :focus-visible { outline: 2px solid #005FCC; outline-offset: 2px; }
4. Colour contrast — text (WCAG 1.4.3)
Normal text (below 18pt / 14pt bold) requires a minimum contrast ratio of 4.5:1 against its background. Large text requires 3:1. Product price text, navigation labels, and button text are commonly failing elements. Use EuroGPSR or the WebAIM Contrast Checker to test your specific colour combinations.
5. Form labels (WCAG 1.3.1, 3.3.2)
Every form field must have a programmatically associated label. Placeholder text alone is not an acceptable substitute — it disappears when the user starts typing. Checkout form fields (first name, email, address) are the most commonly failing elements in ecommerce accessibility audits.
6. Button and link names (WCAG 4.1.2)
Every button and link must have an accessible name — either visible text, an aria-label, or an aria-labelledby reference. "Add to Cart" buttons with only an icon and no text fail this requirement. Navigation icons without labels fail this requirement.
7. Page language declaration (WCAG 3.1.1)
The HTML element must declare the page language: <html lang="en"> (or the appropriate language code). Screen readers use this to select the correct pronunciation engine. Most modern platforms handle this correctly, but multi-language stores sometimes generate pages without a language declaration on translated versions.
8. Heading hierarchy (WCAG 1.3.1)
Page headings must follow a logical hierarchy: one H1 per page, H2 for main sections, H3 for subsections. Skipping heading levels (jumping from H1 to H3) disrupts screen reader navigation. Product pages commonly fail when theme designers use H3 or H4 for the product title to match visual size, bypassing H2.
9. Viewport scaling (WCAG 1.4.4)
Users must be able to resize text up to 200% without loss of content or functionality. Pages with <meta name="viewport" content="user-scalable=no"> or maximum-scale=1 fail this requirement. Remove these restrictions from your viewport meta tag.
10. Skip navigation link (WCAG 2.4.1)
Pages with repeated navigation must provide a "Skip to main content" link as the first focusable element. This allows keyboard and screen reader users to bypass your navigation menu on every page. It can be visually hidden but must become visible on keyboard focus.
11. Error identification and description (WCAG 3.3.1, 3.3.3)
Form errors must be identified in text (not just by colour change) and provide a specific description of how to fix the error. "Invalid email" is not sufficient — "Please enter a valid email address in the format name@example.com" is.
12. Status messages (WCAG 4.1.3)
Dynamic updates that don't receive focus — such as "Item added to cart" notifications or stock status changes — must be announced to screen readers via ARIA live regions. Without this, screen reader users have no way of knowing these updates occurred.
How to audit your store
Manual auditing with a keyboard and screen reader is essential, but automated scanning catches a large proportion of WCAG 2.1 AA violations. EuroGPSR's free scan checks your store for 12 accessibility signals aligned with EAA requirements and gives you platform-specific remediation steps. Scan any URL — no account required.
EAA enforcement and penalties
Each EU member state sets its own penalty regime. Germany has indicated fines up to €50,000 for serious EAA violations. France has incorporated EAA obligations into its Digital Accessibility Law, with fines up to €25,000. The UK has equivalent requirements under the Equality Act 2010 accessibility provisions.
Enforcement is expected to ramp up through 2026 as national market surveillance authorities establish their EAA inspection protocols.