Skip to content
Shopware & E-Commerce

European Accessibility Act for Shopware stores: checklist, exemptions and what 6.7 already does

In May 2025 someone wrote in the Shopware forum: "Stores have a transition period until 2030." The sentence has stuck around, and it's wrong. The 2030 deadline in the German transposition of the European Accessibility Act protects old contracts and products that were already in use – not the online store as a service. The store has had to be accessible since June 28, 2025 if it sells to consumers and isn't run by a microenterprise.

This article sorts out what the European Accessibility Act (Directive (EU) 2019/882) demands of a Shopware store, using Germany's Barrierefreiheitsstärkungsgesetz (BFSG) as the worked example: who is affected, which standard applies, what Shopware 6.7 ships out of the box and what theme, content and plugins leave to you. Plus a checklist of 16 WCAG criteria, the state of enforcement and the question of what overlay widgets really deliver. Everything as of November 7, 2026.

The short version

  • Affected is every store where consumers conclude contracts online (BFSG Section 1(3) no. 5, Section 2 no. 26). Exempt are microenterprises as service providers: fewer than ten employees and at most €2 million turnover or balance sheet total (Section 3(3)). Pure B2B stores aren't covered by the wording.
  • No grace period: Section 38 protects old contracts and old products until June 27, 2030, not the website. Fines in Germany up to €100,000 (Section 37), plus unfair-competition warning letters since August 2025.
  • Shopware 6.7 has baked in the accessibility rework from 6.6 – skip link, focus handling, keyboard navigation, list markup, 16 px base font. Shopware commits to WCAG 2.1 AA, not "EAA-ready": theme colors, content, alt text and third-party plugins remain your job.
  • Overlays don't satisfy the obligation – the German federal accessibility office, the federal and state monitoring bodies and the Overlay Fact Sheet all agree.

As always: we're software engineers, not lawyers. Sections and quotes come from the statute and the official bodies, the framing is our practical summary – not legal advice. Every EU member state transposed the EAA into its own law; the thresholds and the June 28, 2025 date come from the directive and are the same everywhere, the fines and authorities are national.

Does the EAA apply to my store?

The German act covers "services in electronic commerce" provided to consumers after June 28, 2025 (Section 1(3) no. 5 BFSG). Section 2 no. 26 defines them as digital services provided "at the individual request of a consumer with a view to concluding a consumer contract". A store where consumers can order is exactly that – and the EAA's Article 2 uses the same definition.

Does the EAA apply to my store?
SituationObligation?Basis
B2C store, ten or more employees or over €2 million turnoverYes, since June 28, 2025Section 1(3) no. 5, Section 14 BFSG; EAA Art. 2
B2C store of a microenterprise (fewer than ten employees and at most €2 million turnover or balance sheet total)No, voluntarySection 2 no. 17, Section 3(3) BFSG; EAA Art. 4(5)
Store sells products that aren't themselves covered by the EAA (clothing, furniture …)Yes – it's about the store as a service, not the goodsGerman federal accessibility office, e-commerce FAQ
Pure B2B store, business customers only, technically enforcedBy the wording no, because no consumer is involvedSection 2 no. 16 BFSG – there is no explicit statement from the authorities
Mixed B2B and B2C storeYesas B2C
Embedded third-party content you neither fund nor controlExempt – but payment and login functions are explicitly coveredSection 1(4) no. 4 BFSG, Section 19 BFSGV

Two details that often get missed: the microenterprise threshold is fewer than ten people – ten employees are no longer a microenterprise. And according to the federal accessibility office the obligation covers the whole website, not just the purchase path.

The 2030 grace period doesn't apply to your store

Section 38(1) BFSG lets service providers keep using products they lawfully used before June 28, 2025 until June 27, 2030, and continue service contracts concluded before the cut-off unchanged. Self-service terminals may run for up to 15 years (Section 38(2)). That mirrors Article 32 of the directive.

A store's website is neither a product nor an old contract. The law firm Taylor Wessing puts it plainly: the deadline is "no general grace period" for web stores. Anyone selling to consumers since June 2025 has been obliged since then – fully: unlike the rules for public bodies, the BFSG has no mechanism to declare and justify non-conformity.

What you actually have to deliver

The requirements sit in the regulation under the act (BFSGV). It names neither WCAG nor EN 301 549 explicitly but requires in Section 12 no. 3 that websites and apps are "perceivable, operable, understandable and robust in a consistent and adequate way" – the four WCAG principles. Section 19 BFSGV adds for e-commerce: identification, authentication, security and payment functions must meet the same requirements, and you must pass on accessibility information about the products you sell, as far as the manufacturer provides it.

The link to a standard comes through Section 4 BFSG (and EAA Art. 15): whoever meets a harmonised standard listed in the EU Official Journal may presume conformity. So far that's EN 301 549 V3.2.1, built on WCAG 2.1 A and AA. Its successor V4.1.1 with WCAG 2.2 was published on September 2, 2026; its citation in the Official Journal was announced for autumn 2026. In practice: plan for WCAG 2.2 now – the six new criteria (among them focus not obscured, target size, accessible authentication) hit stores directly.

Then there's the information under Annex 3 – colloquially the accessibility statement, even though the German act doesn't use the term. Section 14(1) no. 2 requires you to produce it and make it "accessible to the general public in an accessible form". Mandatory content: a general description of the service, explanations of how it is performed, a description of how the requirements are met, and the name of the competent market surveillance authority. The federal accessibility office recommends a link "Accessibility" in the header or footer; terms and conditions alone are allowed but the worse choice. In Germany the authority is the Market Surveillance Body of the Länder for the Accessibility of Products and Services (MLBF) in Magdeburg – its contact details are on its website and change occasionally, check them before publishing.

What Shopware 6.7 ships out of the box

Shopware has systematically reworked Storefront accessibility since 2024 – in 6.6 behind the feature flag ACCESSIBILITY_TWEAKS, because many changes break templates, in 6.7 built in and no longer switchable. The company commits to WCAG 2.1 AA and BITV 2.0 and says in the same breath that open points remain. There is no "EAA-ready" promise, and that's honest: an update alone doesn't make a store accessible.

What Shopware 6.7 ships out of the box
VersionWhat was added
6.6.1 to 6.6.4unique page titles, buttons instead of links in the offcanvas cart, headings on the login page, alt text for cart images, sliders announce state changes to screen readers
6.6.5skip link "Skip to main content" (visible on focus only), labelled quantity field
6.6.6focus handling after modals and reloads, zoom modal by keyboard, zoom to 200 % without breakage, pagination as links, language per passage
6.6.7keyboard navigation in account orders, text editor produces paragraphs instead of div
6.6.x overallvisible focus styles, flyout navigation by keyboard, filter panel as a group, icon buttons with text, 16 px base font and rem typography, better form errors
6.7.0 (June 17, 2025)flag removed, everything standard: duplicate link around the product image gone, lists as ul/li, language and currency switch as button, modals via button instead of a, icons aria-hidden, offcanvas with aria-labelledby, mobile keyboard navigation
6.7.2 to 6.7.4more accessible basic captcha, aria-label for slider and CMS image links, navbar focus; backports into older 6.7 minors (August 2026)

According to GitHub issues labelled area/accessibility, eleven points were still open on November 7, 2026 and 273 closed. The open ones include modals and offcanvas panels that don't move focus into the dialog, truncated totals in the cart at 200 % zoom and a skip link for the filters. If you're on Shopware 5, Shopware's documentation says there is no accessibility support at all; if you stay on 6.6, you have to set the flag and recompile the theme.

The checklist: 16 WCAG criteria for your store

The table shows, per criterion, the typical failure from the studies, what the Shopware core delivers in 6.7 and what stays with you. "Yes" means Shopware has documented a targeted implementation – a custom theme can break it again any time.

WCAG criteria in the store: Shopware 6.7 default and your task (as of November 7, 2026)
WCAG criterionShopware 6.7 coredefault StorefrontTypical failure in storesper studiesYour tasktheme, content, plugins
1.1.1 Non-text content (A)partlylisting falls back to product name, gallery empty in 6.7.0product images without alt text – on 53.1 % of all home pagesmaintain alt text per medium and language or generate it with AI; decorative images alt=""
1.3.1 Info and relationships (A)yeslists as ul/li, headings, landmarkslists made of div, tables without th, heading jumpsdon’t copy old structure in theme overrides; keep heading order in shopping experiences
1.4.3 Contrast (AA)partlycore contrasts fixed, theme colors decidelight gray helper text, prices on images – the most common failure of all, 83.9 %check primary, link and button colors in the theme manager for 4.5:1; no text on images
1.4.4 Resize text (AA)yes16 px base, rem typography14 px base font, fixed pixelsdon’t pin the old $font-size-base in your theme
1.4.10 Reflow (AA)partlyup to 200 % without breakage; checkout summary box openhorizontal scroll at 320 px, truncated amountsremove fixed widths in the theme, test checkout at 320 px
2.1.1 Keyboard (A)yesnavigation, filters, sliders, zoom by keyboardonly 20 of 65 top German stores keyboard-operable (Aktion Mensch 2025)mega-menu plugins, configurators and custom JS components are the weak spot
2.2.1 Timing adjustable (A)partlysliders pausable; session notice not verifiedsession timeout in checkout, countdown banners, autoplayautoplay off, avoid countdown elements, check session length
2.4.1 Bypass blocks (A)yesskip link since 6.6.5only 17.1 % of websites have a skip linkdon’t override the skip link block in the theme
2.4.4 Link purpose (A)partlyaria-label for image links, duplicate product link removed“More”, “click here”, image links without text – 46.3 % with empty linksCMS buttons with meaningful text, icon links with aria-label
2.4.7 Focus visible (AA)yesfocus styles and focusHandler“outline: none” in the theme – most stores without visible focusnever remove outline without a replacement; check focus color against the primary color
2.4.11 Focus not obscured (AA, WCAG 2.2)not verifiedsticky header or cookie banner covers the focused elementset scroll-padding-top, test sticky elements
2.5.8 Target size (AA, WCAG 2.2)not verifiedquantity plus/minus and color swatches under 24 pxminimum sizes and spacing in the theme
3.3.1 / 3.3.3 Error identification and suggestion (A/AA)yeserror texts with aria-describedby, not color onlyerrors only marked red, payment errors without assignmentcheck payment iframes of your providers separately (Section 19 BFSGV)
3.3.2 Labels or instructions (A)yeslabels instead of placeholders in registration and addresses51 % of websites with missing form labelscheck floating-label plugins and shopping experience forms
3.3.8 Accessible authentication (AA, WCAG 2.2)partlybasic captcha more accessible; image captcha remains a riskimage captcha without alternative in checkoutcaptcha off, or honeypot or Friendly Captcha instead of picture puzzles
4.1.2 Name, role, value (A)partlyicon buttons with text, offcanvas named; modal focus open30.6 % of websites with empty buttons, custom dropdowns without semanticsinstall current 6.7.x; don’t rebuild Bootstrap components

Legend:yespartlynot verified

Shopware data from the dev docs “Accessibility in the Storefront”, release notes 6.6.x/6.7.0.0, changelog and GitHub issues (label area/accessibility) as of November 7, 2026. Study figures: WebAIM Million 2026 (home pages of the top one million websites, February 2026), Aktion Mensch/Google test of German stores (June 2025). “Not verified” = no Shopware statement found.

Two numbers from the WebAIM 2026 study store owners should know: the Shopping category averages 71 errors per home page, 26.6 percent above the average of all websites. And German domains do markedly better with 46.3 errors than the average of 56.1 – so the law has an effect, but the market is far from conformance. In France the Tribunal judiciaire de Caen ruled against Carrefour in interim proceedings on June 4, 2026: 71.21 percent conformance wasn't enough; the court cited missing alt text, contrast and poorly labelled links among other things.

of top home pages with contrast errors – the most common WCAG failure (WebAIM 2026)
83.9 %
of home pages with missing alt text (WebAIM 2026)
53.1 %
top German stores operable by keyboard (Aktion Mensch and Google, June 2025)
20 of 65

Overlays and toolbars: what they can and can't do

The Shopware Store lists several extensions that put an accessibility toolbar into the store – toggle contrast, enlarge text, highlight links. They're cheap to free and quick to install. The experts agree on their limits:

  • Germany's federal accessibility office writes verbatim that an online store "cannot fulfil its digital accessibility obligations under the BFSG with an overlay tool".
  • The federal and state monitoring bodies (BFIT-Bund) state in their joint assessment of March 2025: overlays "cannot render a website with barriers fully accessible" and can create new barriers. They may complement, must themselves be accessible and switchable off.
  • The international Overlay Fact Sheet, signed by co-authors of WCAG and experts from Google, Microsoft, Apple and Shopify, considers automatic alt text, form repair and keyboard access via overlay "not reliable".
Overlays and toolbars: what they can and can't do
ExtensionVendorPrice (net)Assessment
Accessibility tools ("Barrierefrei Hilfswerkzeuge")designverignfree, premium from €4.17/monthtoolbar for user settings; 1,274 installs, 5.0 stars
Accessibility Toolbar & WidgetTC-Innovations (ThemeWare)free or €4.99/monthtoolbar, advertises being accessible itself and fully local
Accessibility for your shopgb mediafreetoolbar: invert, monochrome, scaling
All in One AccessibilitySkynet Technologies€25/monthclassic overlay, on the Overlay Fact Sheet's list; cleared only up to 6.7.4
Web Accessibilityweedesign€9.90/month"automatic ARIA repair", alt text from file names – produces exactly the questionable alt text WebAIM counts

A toolbar can be a convenience feature. As proof of conformance it doesn't work – and an "automatic repair" via JavaScript replaces neither an alt attribute nor a label in the source.

Alt text: the most visible building block

Of the 16 criteria, 1.1.1 is the one stores fail most often and most visibly – and the quickest to fix. Shopware stores alt text on the medium, translatable per language. If the field is empty, the listing shows the product name and the 6.7.0 gallery shows nothing. Neither is a description of the image.

For hundreds or thousands of product images, automation is practically the only option. Our plugin Alt-Text Optimizer Pro generates the texts through your own OpenAI key, per shop language, with product name and description as context and in configurable length – the backlog in the background, new images overnight. How it stacks up against AutoAlt, alttext.ai, Addify, Biloba and Shopware's built-ins is in our comparison of alt text generators. The basics of alt text in Shopware we wrote up in July.

Enforcement: authority, fines, warning letters

In Germany the competent authority since September 26, 2025 is the Market Surveillance Body of the Länder for the Accessibility of Products and Services (MLBF), a public institution of all 16 states based in Magdeburg. It adopted its market surveillance strategies on January 29, 2026 and runs online forms: "Report a barrier" and the application under Section 32 BFSG, with which any consumer can force proceedings if they can't use a service because of a violation – also represented by a recognised association.

According to Taylor Wessing's summary, the strategy relies first on reactive surveillance – applications, tips, self-reports – supplemented by proactive sampling by risk profile: reach, company size, complexity, automated pre-checks of websites. The procedure is graduated (Section 29): request to correct, renewed request under threat of prohibition, then an order to cease the offer. Fines under Section 37(2) reach up to €100,000 – a ceiling, no minimums. Published fines or prohibitions against stores didn't exist as of November 7, 2026; for the "first fines in early 2026" some vendors write about, we found no evidence.

Faster than the authority were private enforcers: since August 2025 a law firm has been sending blanket warning letters on behalf of a website service provider – "homepage not accessible" with a screenshot, €10,000 in dispute, settlement offer around €600. The law firms Heuking and WBS.LEGAL advise checking the sender's standing and the specific violation claimed – whether EAA duties even count as market conduct rules under German unfair competition law hasn't been decided by any German court yet.

Roadmap: from suspicion to a list in one week

  1. Clarify whether you’re covered

    Compare employees and turnover against the microenterprise threshold (fewer than ten and at most €2 million), check your B2C share. Record the result with your legal counsel.

  2. Check version and theme

    Update to current Shopware 6.7.x. Search the theme for outline: none, copied core blocks and old $font-size-base – the three most common regressions.

  3. Measure automatically

    Run axe or Lighthouse on home, category, product, cart, checkout and login – contrast, alt text, labels, empty buttons and links are found reliably by tooling.

  4. Test keyboard and zoom

    Operate the same six pages with Tab, Enter, Escape and arrow keys only, then at 200 % zoom and 320 px width. Focus must always be visible, nothing may be cut off.

  5. Alt text and content

    Count images without alt text and add them by AI or by hand, review shopping experiences for headings and link texts, check captcha and autoplay sliders.

  6. Publish the accessibility information

    Description of the service, how the requirements are met, contact and the competent authority – as a link “Accessibility” in the footer, reviewed by a lawyer.

If that turns up theme problems that can't be solved in a week, our article on Shopware themes weighs adapting, buying and rebuilding. And if you don't want to carry the audit and the fixes yourself, that's a project we support as a Shopware agency.

Frequently asked questions

Does the European Accessibility Act apply to every online store?

To every store where consumers conclude contracts online – regardless of what is sold. Exempt are microenterprises as service providers: fewer than ten employees and at most €2 million annual turnover or balance sheet total. Pure B2B stores aren’t covered by the wording because no consumer is involved; there is no explicit statement from the authorities on that.

Is there a transition period for online stores until 2030?

No. The 2030 deadline (Section 38 BFSG, Art. 32 EAA) protects only products that were in use before June 28, 2025 and service contracts concluded before that date. A store’s website is neither. It has had to be accessible since June 28, 2025.

Is Shopware 6.7 EAA-compliant?

Shopware commits to WCAG 2.1 AA and BITV 2.0 for the default Storefront and has built the accessibility rework into 6.7. There is no “EAA-ready” promise: theme colors, custom templates, content, alt text and third-party plugins all play a part, and some core points are still open. The core is a good basis, not proof of conformance.

Which WCAG version applies under the EAA?

The presumption of conformity runs through EN 301 549 as listed in the EU Official Journal. So far that is version 3.2.1 based on WCAG 2.1 A and AA. Version 4.1.1 with WCAG 2.2 was published on September 2, 2026; its citation in the Official Journal was announced for autumn 2026. If you implement today, base it on WCAG 2.2.

Is an accessibility overlay enough for the store?

No. Germany’s federal accessibility office states explicitly that an online store cannot fulfil its obligations with an overlay tool; the federal and state monitoring bodies and the Overlay Fact Sheet reach the same conclusion. A toolbar can offer convenience but replaces neither alt text nor labels nor keyboard operability in the source.

What are the penalties for violations?

In Germany the MLBF can demand corrections in a graduated procedure, threaten prohibition and finally order the offer to be stopped; fines under Section 37 BFSG reach up to €100,000. Any consumer can force proceedings via an application under Section 32. In parallel, unfair-competition warning letters have been circulating since August 2025 – no German court ruling exists yet. Other member states have their own authorities and fine ranges.

Sources

Retrieved November 7, 2026:

Bottom line

For Shopware stores the European Accessibility Act isn't a future topic and isn't a matter of one plugin. It has applied for a year and a half, it has no grace period for websites, and it demands full conformance instead of a statement about gaps. Shopware 6.7 takes a lot off your plate with the core – focus, keyboard, semantics, skip link. What remains is yours: theme colors, custom templates, forms in shopping experiences, captcha and above all the alt text.

Take the six pages from the roadmap and go through them once using only the keyboard. Where you lose focus or hit an image without a description is your first task – and everything still open after that we're happy to talk about in a free initial call.