Brexit removed you from the single market. It did not remove you from EU consumer law.
When a UK-based Shopify store sells a product or a digital service to a consumer in Berlin, Paris or Amsterdam, that transaction is an e-commerce service under Article 2.2(f) of Directive (EU) 2019/882. The Directive applies by market destination, not by company registration. The same principle that already requires UK sellers to comply with EU GDPR, CE marking, GPSR, WEEE and packaging regulations when selling into the EU now applies to web accessibility. This is not a new legal concept for UK exporters — it is the next regulation on the same list.
The UK's own Equality Act 2010 already requires reasonable adjustments for disabled users, but it does not demand a structured Accessibility Statement or a WCAG criterion-by-criterion report. The EAA does. If a German market surveillance authority inspects your Shopify store and finds no Accessibility Statement published under Art. 13.2, the enforcement procedure starts against you as the service provider, not against Shopify Inc.
What the EAA requires from your Shopify store — the four documents
Under Article 13.2 of Directive (EU) 2019/882, every provider of a covered service must produce and maintain structured accessibility documentation. For an e-commerce service, this means:
Accessibility Statement
Under Art. 13.2. Must be public, accessible, up-to-date, and include a feedback mechanism for users to report barriers.
WCAG 2.1 AA Assessment
17 official criteria grouped by the 4 principles (Perceivable, Operable, Understandable, Robust). This is the technical standard of harmonised standard EN 301 549.
Remediation plan
Issues found must be documented with priority (HIGH/MEDIUM) and guidance to fix them. The law requires remediation, not just identification.
Feedback mechanism
A public channel (email, form) for any user to report accessibility barriers. Art. 13 requires this as part of the Statement.
What you receive in your 6-10 page PDF
EAA-Report generates a structured Accessibility Report under EN 301 549 V3.2.1 and Art. 13.2 of Directive (EU) 2019/882. Here is what it contains:
WCAG 2.1 AA Assessment
17 official criteria evaluated with per-principle scoring and numbered WCAG reference.
Personalised Accessibility Statement
Under Art. 13.2. With your company data, website URL, country of service, contact email. Ready to publish on your store.
HTML footer block
Copy-paste code with Accessibility Statement link, feedback mechanism and competent authority data for each EU country you sell into.
Legal risk analysis
Verified fine ranges from national transposition laws: Spain (up to €1M), Germany (up to €100K), France (up to €250K), Netherlands (up to €900K or 10% of turnover).
Prioritised remediation plan
Each issue with HIGH/MEDIUM priority and W3C guidance for your developer.
Disproportionate burden template
Documentation under Annex VI of Directive 2019/882, in case you need to claim partial exemption.
Generated in your browser. No data leaves your device.
What it costs to have the accessibility documentation the EU requires
Three mistakes UK Shopify sellers make when approaching EU accessibility
"I comply with the Equality Act 2010, so I'm covered"
The Equality Act requires reasonable adjustments for disabled users, but it does not require a structured Accessibility Statement, a WCAG criterion-by-criterion report, or a published feedback mechanism. The EAA does. Complying with UK law does not satisfy EU obligations when you sell to EU consumers.
"My Shopify theme is accessibility-ready"
The base theme may follow good practices, but every app you install (chat widgets, review popups, cookie banners, product filters) can break accessibility. The EAA evaluates your store as published, not the theme in its default state. Your theme is not your Accessibility Statement.
"Nobody has complained yet, so I'll deal with it when they do"
EU market surveillance is proactive, not complaint-driven. France has already admitted lawsuits against 4 supermarket chains. The Netherlands (ACM) has launched sectoral audits. Sweden (PTS) has active e-commerce inspections. The enforcement model is modelled on CE marking, not on ADA lawsuits. By the time a complaint arrives, the fine range is already set.
Enforcement is live — and it reaches UK sellers
The EAA has been enforceable since 28 June 2025. Market surveillance authorities across the EU have started inspections. As a UK seller providing e-commerce services to EU consumers, you are subject to the enforcement regime of every Member State where you sell.
BFSG. Up to €100,000 per individual infringement. BFIT-Bund as surveillance authority.
Ordonnance 2023-859. Tribunal Judiciaire de Paris admitted EAA lawsuits against 4 supermarket chains in November 2025.
Implementatiewet. Up to €900,000 or 1-10% of annual turnover. ACM actively auditing banking and telecom since spring 2026.
Law 11/2023 + subsidiary regime RDL 1/2013. Minor up to €30K, serious up to €90K, very serious up to €1M. Repeat offences: operating ban up to 2 years.
What EAA-Report guarantees and what it doesn't
EAA-Report generates a document structured under Art. 13.2 of Directive (EU) 2019/882 based on the information you enter. The truthfulness, accuracy and completeness of that information is your responsibility as service provider.
We guarantee that the document structure follows Art. 13.2 of Directive (EU) 2019/882 and that the legal references cited are correct as of the latest verification date. We do not guarantee that a specific document will be accepted by a market surveillance authority in a specific case, nor by a commercial buyer in a procurement process.
EAA-Report is not legal advice. For specific situations, consult a lawyer or specialised regulatory consultancy.
Frequently asked questions — UK Shopify sellers
Does the EAA apply to UK companies selling to EU consumers?
I already comply with the UK Equality Act 2010. Is that enough?
Do I need a separate report for each EU country I sell to?
Can an EU authority actually enforce against a UK company?
Is my data safe with EAA-Report?
Is EAA-Report legal advice?
⚠️ Important notice: EAA-Report is a self-assessment documentation tool, not legal advice and not a third-party audit. The document is generated from your input data. You are responsible for the accuracy of the data you provide. EAA-Report does not replace a qualified professional assessment.
Official legal sources
- Directive (EU) 2019/882 — European Accessibility Act — full text