Overview
The European Accessibility Act (EAA) is an EU law requiring many consumer-facing products and services, including ecommerce, to be accessible to people with disabilities. Enforcement began June 28, 2025, across all 27 member states. It applies based on who buys from you, not where your business is registered, so a US-based Shopify store selling to European customers can be in scope even with zero physical presence in the EU.
Who must comply
If you sell products or services to consumers in any EU country, the EAA generally applies to you. Location does not exempt you. Market access does. Marketplaces, online shops, banking, transport ticketing, e-books, and consumer electronics interfaces are all named directly in the Act.
There is one real exemption: micro-enterprises with fewer than 10 employees and annual turnover under 2 million euros are exempt from the services obligations. If you are above that size and sell into the EU, the exemption does not apply, regardless of how small your EU sales volume is relative to your US business.
What it actually requires
The EAA points to a European standard, EN 301 549, which for websites effectively means WCAG 2.1 AA, the same standard referenced in ADA compliance requirements for US businesses. In practice this means the same things: keyboard-navigable navigation and filters, labeled checkout forms, sufficient color contrast, and screen reader compatibility.
One requirement the EAA adds that ADA Title III does not explicitly demand: a published accessibility statement describing how your service meets the requirements, plus a way for users to report accessibility issues. What that statement should contain is covered in does your store need an accessibility statement page.
Penalties
Enforcement is handled at the national level, so fines vary significantly by country, from roughly 60,000 euros in Ireland to around 900,000 euros in Sweden. The first EAA lawsuits were filed in France in November 2025, and multiple other member states have signaled active enforcement plans through 2026.
How this differs from ADA exposure
ADA Title III litigation in the US is driven by private lawsuits from individual plaintiffs and their firms. EAA enforcement is driven by national regulatory authorities doing market surveillance, a different mechanism with different timing and different penalty structures. A US store can face both simultaneously if it sells into both markets, and a WCAG 2.1 AA audit substantially covers both at once, since the technical standard overlaps.
Example
A US home goods brand selling internationally through Shopify assumed EU accessibility rules did not apply since the company had no EU office or staff. After a customer complaint in Germany triggered a regulatory inquiry, the brand discovered its 40-person size put it well outside the micro-enterprise exemption. An existing WCAG 2.1 AA audit from a US-focused engagement covered most of the technical gap, but the store still had to add a published accessibility statement to close the compliance picture.
Common mistake
Assuming the EAA is a EU-only concern because the business is US-based. The Act is triggered by where your customers are, not where your company is incorporated. Any store shipping internationally should check its EU sales volume against the micro-enterprise threshold before assuming it is exempt.