The online shop accessibility checklist for the EAA in 2026

EAA Comply · Updated July 2026 · 10 min read

Automated scanning with axe-core reliably catches around 57% of real-world accessibility defects by volume — mostly the categories below. This checklist is ordered by how often each issue actually shows up in real product-page and checkout audits, not by an abstract standards list, so you can fix the highest-impact items first.

Homepage and site-wide

• Color contrast. Body text needs at least 4.5:1 contrast against its background, large text at least 3:1. Contrast, along with labels and structure, makes up the majority of real defects an automated scan finds — check your brand's accent colors on buttons and links specifically.
• Every image has meaningful alt text (or alt="" for purely decorative images) — not the filename, not "image123.jpg".
• One visible focus indicator that's clearly visible when tabbing through links and buttons — don't remove the browser's default outline without replacing it with something equally visible.
• Logical heading structure (one H1 per page, no skipped levels) so screen-reader users can navigate by heading.
• Skip-to-content link as the first focusable element, so keyboard users don't have to tab through the entire navigation on every page.

Product pages

• Product images have descriptive alt text — "blue cotton t-shirt, crew neck, front view" rather than "product-04217.jpg". Zoom and gallery controls must also be operable by keyboard.
• Size, color and variant selectors are usable without a mouse — this is one of the most common failures we see in Online shop audits, especially on swatches implemented as styled <div> elements instead of real form controls.
• Price, stock status and reviews are readable by screen readers, not conveyed only through icons or color (e.g. a red dot alone for "out of stock").
• "Add to basket" confirmation is announced to assistive technology (via an aria-live region), not shown only as a silent visual toast.

Checkout — the highest-stakes pages on your site

• Every form field has a real, programmatically associated label — placeholder text alone is not a label, and disappears the moment the user starts typing.
• The entire checkout can be completed using only a keyboard — no dead ends, no focus traps in address or payment modals. This is exactly the manual test our Online shop audit adds on top of the automated scan.
• Error messages are specific and linked to their field ("Postcode must be 4 digits," announced and associated with the postcode field) rather than a generic "Please check the form" banner at the top.
• Payment method icons have text alternatives, and any CAPTCHA has a non-visual alternative.
• Order confirmation is clearly announced, not just a visual redirect a screen-reader user might miss.

Documentation and ongoing process

• A published, honest accessibility statement — see our accessibility statement for the structure regulators expect, or read the full guide below.
• A way for users to report accessibility problems and a process to actually act on what comes in.
• Re-testing after every redesign or new template, not just once at launch — this is what monthly monitoring is for.

What this checklist can't do

A checklist, like an automated scanner, catches the well-known, high-frequency issues. It won't replace an actual scan of your specific code, and it definitely won't replace testing your specific checkout with a keyboard and, ideally, a screen reader. Treat it as a starting map, not a finish line — and remember that neither this list nor a scan report is a legal certification; see our legal notice for what EAA Comply is and isn't.

Where this fits in your broader compliance work

The checklist is a starting point. Read the full European Accessibility Act guide for online shops for who it applies to and what to do first, and see why a checklist alone — like an overlay alone — isn't the same thing as reducing your actual legal exposure in our overlay risk breakdown.

• Sources:
• Deque / axe-core project, discussion of real-world issue coverage percentages
• Siteimprove, "The European Accessibility Act for Ecommerce"
• Accessible.org, "EAA: Ecommerce Services Requirements"