Shopify and the European Accessibility Act

What Shopify requires, and what it does not

Shopify publishes accessibility best practices for themes and enforces a hard gate on the Theme Store: a theme needs a minimum average Lighthouse accessibility score of 90across the home, collection and product pages, on both desktop and mobile, to be listed.

That gate is worth reading precisely, because it is the most misread fact about Shopify and the EAA. Lighthouse runs a subset of automated checks; 90 is a score on that subset, not a conformance claim. Shopify's theme store requirements do not mandate conformance to WCAG level A, AA or AAA. The EAA, by contrast, routes through EN 301 549, whose currently cited version is based on WCAG 2.1 level AA — see EAA vs WCAG for how that chain works. A theme can clear Shopify's bar and still fail criteria the law cares about, because the criteria that need a human to test are exactly the ones an automated score cannot reach.

The requirements Shopify does set for themes

These are worth knowing because they tell you what you can reasonably expect a Theme Store theme to already do — and therefore what is worth reporting to the theme developer rather than fixing yourself. From Shopify's own theme accessibility documentation:

• Keyboard operation. Tab and Shift + Tabnavigate the theme; the focus indicator is visible and consistent; keyboard focus order matches DOM order. Positive tabindex values and autofocus are ruled out.
• Colour contrast. Text below 24 px regular or 18.5 px bold needs 4.5:1 against its background; at or above those sizes, 3.0:1. Icons and input borders need 3.0:1.
• Structure. Valid HTML, headings used in sequence with a singleh1 naming the page topic, navigation wrapped in nav, thelang attribute set on html, and a skip link that becomes visible on focus.
• Images and forms. Every img carries an altattribute, decorative images an empty one; every form field has a label associated byfor; required inputs carry the required attribute.
• Two things a theme must never do: rely on mouse hover to reveal something, or use colour alone to carry information.

Source: Shopify — accessibility best practices for themesand Shopify Theme Store requirements.

Where Shopify stores actually fail

The pattern is consistent: the theme skeleton is usually sound, and the failures cluster in the three places Shopify's own requirements do not reach.

1. Your product data

Alt text is a field on the image in your admin, not a theme setting. Shopify does not require it at upload, so a catalog imported in bulk — from a supplier feed, a migration, or a CSV — routinely lands with that field empty across thousands of images. A theme that correctly outputs alt attributes will faithfully output thousands of empty ones. This is the most common critical finding on a Shopify storefront, and no theme change fixes it.

2. Third-party apps

Sliders, countdown timers, upsell popups, review widgets, cookie banners and announcement bars inject their own markup into pages that passed review without them. Shopify publishes accessibility best practices for apps too, but an app's storefront output is not gated the way a Theme Store listing is. Popups are the recurring offender: a modal that cannot be closed with the keyboard traps a keyboard user on the page, which ends the session rather than degrading it.

3. Your own customisations

Colour palettes chosen in the theme editor are the quiet one. A theme ships contrast-safe defaults; a brand palette applied through theme settings can drop body text or button labels below 4.5:1 across the whole store at once, with nothing in the editor warning you. Sale badges and stock indicators drawn only in red or green fail the colour-alone rule the same way.

The checkout is the exception — mostly

Shopify's hosted checkout is Shopify's own surface and the part of the journey you control least, which here is good news: it is maintained by a team with accessibility requirements, and it is the same checkout across millions of stores. The caveats are Checkout Extensibility apps and, on Shopify Plus, checkout customisations — both let third-party markup into the one flow where a failure means the customer cannot complete a purchase at all. If you have customised checkout in any way, walk the full journey with a keyboard only.

What to do, in order

1. Scan the home page and one product page. Between them you surface most theme-wide issues, because those sections repeat across the store.
2. Audit alt text as data, not design. Export your products, count how many image alt fields are empty, and fix it at the source.
3. Walk the buying journey with the keyboard only. Home, collection, product, add to cart, cart, checkout. No mouse. Every step you cannot complete is a barrier for someone who never had the option.
4. Disable apps one at a time when a finding matches nothing in your theme. It is usually the most recently installed one.
5. Publish an accessibility statement. It is an obligation in its own right, separate from the state of the site — thestatement generator fills in the enforcement authority and complaint route for your country.

What a scan cannot tell you

Automated testing typically catches an estimated 20–50% of real accessibility issues. On a Shopify store the gap is specific: whether your alt text describes the product or just repeats the filename, whether a size selector makes sense when announced aloud, whether focus order through a mega-menu is logical, and whether a cart error tells the customer what to do next. Those need a person. A clean scan is a floor, not a certificate.