For two years, every article about the European Accessibility Act used the same phrase: "when it comes into force." That sentence no longer works. The deadline passed. The countdown is over. If you run a Shopify or WooCommerce store that sells into the EU, the question sitting in your inbox right now isn't "how much time do we have," it's "what is actually broken, and in what order do we fix it."
That's the useful question. So let's answer it, not with a legal briefing, but with a working list - the same one we'd hand a merchant if they called us this afternoon and said "just tell me what to do first."
The Stat: The European Accessibility Act (Directive (EU) 2019/882) entered into application on 28 June 2025, requiring covered products and services, including e-commerce, sold within the EU to meet defined accessibility requirements. (Source: Directive (EU) 2019/882)
Here's a quick visual of the eight items before we walk through each one.
Why this list, in this order
We didn't pick these eight items at random. We ranked them by a simple rule: which failures are (a) most common on real storefronts, and (b) most directly named in the standards the EAA leans on. That combination tells you where an auditor, a complaint, or a frustrated customer is most likely to find you first.
WCAG SC 1.4.3 Contrast (Minimum), 3.3.2 Labels or Instructions, and 2.1.1 Keyboard remain the most commonly failed criteria on retail storefronts generally, according to category data from the WebAIM Million report. That's not a niche finding, it's the pattern across the web at large, and ecommerce sites are not the exception. So items one through four on our list target exactly those failure modes as they show up on a typical Shopify or WooCommerce build.
1. Contrast on price and CTA text
Low-contrast price tags and "Add to Cart" buttons are the single most common failure we see. Merchandising teams love a soft gray price label or a pastel button because it looks calm in a mockup. On a phone screen in daylight, it's unreadable. Run your theme's price, discount badge, and primary button text through a contrast checker against their actual background, not the swatch in your design file.
2. Labeled form fields at checkout
Placeholder text that disappears the moment someone starts typing is not a label. If your checkout form relies on placeholder-only fields for email, address, or card details, a screen reader user (and plenty of sighted users with cognitive or attention differences) loses track of what each field wants the second they start filling it in. Every field needs a persistent, programmatically associated label.
3. Keyboard-operable cart and filters
Can someone complete a purchase using only a keyboard, tab through your product filters, and open the cart drawer without a mouse? Many Shopify filter apps and WooCommerce plugin widgets trap keyboard focus or require a hover state that a keyboard user can never trigger. Test it yourself: unplug the mouse for ten minutes and try to buy something from your own store.
4. Alt text on all product imagery
Every product photo, every lifestyle shot, every size-chart image needs a real, descriptive alt attribute, not "image1.jpg" and not a repeated brand name across forty thumbnails. This is tedious at catalog scale, which is exactly why it gets skipped, and exactly why it's on this list.
The second wave: newer, sharper requirements
The next four items map to more specific, more recently formalized requirements, the kind that a store built even a year or two ago is unlikely to have addressed by accident.
5. No CAPTCHA-only authentication
WCAG 2.2's Accessible Authentication (Minimum) criterion (SC 3.3.8, Level AA) specifically prohibits requiring a cognitive-function test, such as a puzzle CAPTCHA, without an alternative or assistance mechanism. If your checkout, account creation, or newsletter signup gates on a "select all the traffic lights" puzzle with no other path through, that's a direct conflict, and it's directly relevant to EU checkout and signup flows under an EAA-aligned standard.
6. Skip link past header and nav
A visually hidden "skip to main content" link, positioned first in the DOM and visible on keyboard focus, saves a keyboard or screen reader user from tabbing through your entire mega-menu on every single page. It's a five-minute build and one of the highest-leverage fixes on this whole list.
7. Announced status messages
When someone adds an item to their cart, applies a discount code, or hits a validation error, does anything get announced to assistive technology, or does the change happen silently in a corner of the screen? Status updates need to live in a region marked so screen readers pick them up automatically, without the user having to go hunting for what changed.
8. Accessible cookie consent banner
The EU-mandated cookie banner is often the first thing a keyboard or screen reader user hits on your site, and it's frequently the least accessible element on the page: unlabeled buttons, no focus trap management, or a banner that can't be dismissed without a mouse. Fix this one and you also fix the first impression.
Put it in a table
| Priority | Fix | Standard it maps to |
|---|---|---|
| 1 | Contrast on price/CTA text | WCAG 1.4.3 |
| 2 | Labeled checkout form fields | WCAG 3.3.2 |
| 3 | Keyboard-operable cart/filters | WCAG 2.1.1 |
| 4 | Alt text on product imagery | WCAG 1.1.1 |
| 5 | No CAPTCHA-only authentication | WCAG 2.2 SC 3.3.8 |
| 6 | Skip link past header/nav | WCAG 2.4.1 |
| 7 | Announced status messages | WCAG 4.1.3 |
| 8 | Accessible cookie consent banner | WCAG 2.1.1 / 4.1.2 |
Or as a working checklist you can hand to a developer this week:
- Contrast on price/CTA text
- Labeled form fields at checkout
- Keyboard-operable cart and filters
- Alt text on all product imagery
- No CAPTCHA-only authentication
- Skip link past header/nav
- Announced status messages (added to cart, etc.)
- Accessible cookie consent banner
Where to go deeper
This list is deliberately the short version, the eight things to triage this week rather than the full spec. If you want the complete, section-by-section walkthrough of exactly how these requirements map onto a Shopify theme or a WooCommerce plugin stack, we've covered it in our deeper, section-by-section EU platform guide, with more detail on theme-level fixes and plugin compatibility.
The EAA being "live" doesn't mean every store needs to panic. It means the checklist stops being optional homework and starts being this week's task list. Work through these eight in order, and you'll have closed the gaps that matter most, in the order they're most likely to matter.
If you'd rather have someone else run the checklist against your actual storefront, line by line, we'd be glad to help. You can get an EAA-focused audit for your store and know exactly where you stand, instead of guessing.