EAA and eCommerce Accessibility 2026: Obligations, Risks and Overlays

What changes for e-commerce?

Directive (EU) 2019/882, implemented in Italy through Legislative Decree 82/2022, introduces accessibility requirements for certain products and services, including e-commerce services when they fall within its scope. It is not correct to turn this into a universal statement such as “all e-commerce businesses are subject to the same penalties”.

Before discussing compliance, at least the following should be checked:

• who provides the service and the size of the business;
• whether the service actually falls within the scope of the legislation;
• which requirements apply to the specific case;
• any exemptions or disproportionate-burden assessments provided by law.

Are microenterprises exempt?

The European Directive states that microenterprises providing services are exempt from the accessibility requirements for services and related obligations. This does not mean accessibility is irrelevant for a microenterprise: it remains an important quality of a digital product and other obligations may apply, but the EAA should not be presented as if it affected every small merchant in the same way.

What penalties exist under the Italian framework?

Legislative Decree 82/2022 provides a system of supervision and sanctions for violations that fall within its scope. The amount and applicable rules depend on the specific violation and operator. For that reason I avoid commercial formulas such as “a guaranteed fine equal to 5% of turnover” or automatic calculations for each barrier: the applicable rule and specific case must be checked first.

For a legal assessment of an individual merchant, a qualified legal professional should be involved. Technical work on the store instead focuses on identifying and correcting the barriers actually present.

Does an accessibility overlay make Shopify compliant?

No automated tool on its own can demonstrate complete compliance of a website. An overlay may change parts of the interface or add features, but it does not replace source-code remediation when a problem concerns semantic structure, focus order, labels, modals, keyboard interaction, error messages or custom components.

The technical point is simple: if a barrier is in the theme or component, the more robust solution is to correct that barrier at the source and then verify behavior with automated and manual testing.

What I check on a Shopify store

• Semantic structure: headings, landmarks, lists, tables and components with coherent markup.
• Keyboard: menus, filters, modals, cart drawers and controls should work without a mouse when required by the component.
• Focus: visible state and correct management when dynamic elements open or close.
• Images: useful alternative text when an image communicates information, without keyword stuffing.
• Forms: understandable labels, instructions and errors.
• Contrast and readability: checks on text, buttons and interactive states.
• Third-party components: review of apps and widgets that introduce their own interfaces.

Automated or manual testing?

Both. Automated tools are useful for quickly identifying some classes of issues, but they cannot independently assess experience quality, focus logic or the understandability of a journey. A serious audit therefore combines automated checks with manual tests on important flows.

Do you need an accessibility “certification”?

I do not use the word “certification” for a normal technical intervention on a theme. I can analyze the store, document issues, apply fixes and verify results, but that does not mean guaranteeing immunity from complaints or sanctions. Legal compliance depends on the entire service and the applicable legislation, not only on theme code.

How I approach accessibility on Shopify

I’m Francesco Guiducci, a freelance Shopify expert and Shopify app developer. When I work on accessibility I separate three levels: what I can correct in the theme, what depends on an app or external component, and what requires a legal assessment of the merchant.

If the issue is technical, I work on Liquid, HTML, CSS, JavaScript or the application component. If a feature requires dedicated logic, I can also assess development or adaptation of a Shopify app, without presenting an automatic widget as a universal solution.

Article updated September 3, 2026. For applicability to a specific case, check the current text of Legislative Decree 82/2022 and Directive (EU) 2019/882 with an appropriate professional.