EN 301 549WCAG 2.1 AADirective (EU) 2019/882
Your store’s accessibility, on the record.
Testamur is a Shopify app for shops selling to EU consumers under the European Accessibility Act. It checks your storefront’s code for accessibility barriers, maps each one to EN 301 549, drafts your accessibility statement and keeps a dated record of what it found and what you changed.
Every scan, every fix and every statement version is dated and kept, so you can show what you checked, when, and what you did next.
In development The Shopify App Store listing goes live after Shopify’s review.
Scan report · storefront
yourstore.example
| Clause | Requirement | Result |
|---|---|---|
| 9.1.1.1 WCAG 1.1.1 | Non-text content 23 product images without a text alternative | Barrier found |
| 9.4.1.2 WCAG 4.1.2 | Name, role, value Cart button without an accessible name | Barrier found |
| 9.1.4.3 WCAG 1.4.3 | Contrast (minimum) Text over the hero image: contrast could not be measured | Needs review |
| 9.2.4.7 WCAG 2.4.7 | Focus visible Needs a person with a keyboard | Manual check needed |
| 9.3.1.1 WCAG 3.1.1 | Language of page | No automated barrier |
Automated checks cover only part of WCAG. “No automated barrier” is not a pass, and every “Manual check needed” row needs a person.
§ 1 · How it works
Four steps, one record.
You install the app, Testamur reads your live storefront, and every result lands in a record that only grows. You do not need to read the directive to use it.
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Step 1
Scan the storefront code
Testamur opens your public storefront in a real browser: home page, collections, products, blog, cart, search and legal pages, up to 14 pages per full scan. It runs the open-source axe-core rules against the rendered code and notes whether each barrier comes from your theme or from a third-party app.
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Step 2
Keep the evidence
Each scan is saved as a dated snapshot that is never edited afterwards, and so is each statement version. A new scan adds a new entry. On paid plans, publishing a theme change starts a new scan, so the record shows what changed and when.
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Step 3
Draft the statement and the conformance report
From the record, Testamur drafts the accessibility information the EAA asks service providers to publish[source 1: Directive (EU) 2019/882], and an EN 301 549 conformance report, clause by clause, per Annex C[source 2: EN 301 549 at ETSI]. Clauses no automated test can judge say “Not evaluated”, and none says “Supported” until a person has tested it. You review the draft before anything is published.
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Step 4
Fix in the theme, then re-check
Each barrier comes with the element it was found on, the clause it maps to and guidance for fixing it in your theme code. Testamur never injects scripts and never changes your live theme without your approval: it prepares the fix, you approve it, and the next scan records whether the barrier is still detected.
Coming at launch An alt-text assistant that drafts image descriptions for you to review, and fix packs checked against your theme version, applied to a copy of your theme that you preview and publish yourself. Agencies can receive the same changes as a GitHub pull request.
Check your own Shopify store for free →
§ 2 · The obligation
What the EAA asks of an online shop
The European Accessibility Act covers e-commerce services offered to consumers in the EU, including by sellers based outside the EU[source 1: Directive (EU) 2019/882]. Microenterprises are exempt: fewer than 10 staff and an annual turnover or balance sheet of no more than €2 million.
Three duties, in plain words
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Make the shop usable
Product pages, search, account and checkout must be perceivable, operable, understandable and robust, and the law names identification, security and payment explicitly (Annex I)[source 1: Directive (EU) 2019/882].
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Say how you meet the requirements
Publish information on how your service meets them, in your terms and conditions or an equivalent document, in an accessible format (Art. 13 and Annex V). This is what people usually call the accessibility statement.
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Keep it that way, and be able to show it
Have procedures so the shop stays in conformity as it changes, and be able to show how you monitor that (Art. 13(3), Annex V point 3).
Key dates
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Directive (EU) 2019/882, the European Accessibility Act, is adopted. [source 1: Directive (EU) 2019/882]
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Deadline for member states to turn it into national law. [source 1: Directive (EU) 2019/882]
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National rules apply to e-commerce services offered to EU consumers. [source 1: Directive (EU) 2019/882]
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EN 301 549 v4.1.1 (based on WCAG 2.2) is published. It is not yet the legal reference; v3.2.1 (WCAG 2.1) is. [source 3: AccessibleEU on EN 301 549 v4.1.1]
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End of the transition for products already used to deliver a service. It does not postpone the rules for your website. [source 1: Directive (EU) 2019/882]
Enforcement in selected countries
| Country | National law | Authority | Maximum penalty | Recent activity |
|---|---|---|---|---|
| Germany | BFSG | MLBF (joint market surveillance office of the Länder) | Up to €100,000 per offence [source 4: BFSG § 37 fines] | The required service information must name the market surveillance authority.[source 5: BFSG Anlage 3] |
| France | Code de la consommation, Art. L.412-13 | DGCCRF | Not verified by us [source 7: Code de la consommation] | On 4 June 2026 a court in Caen ordered Carrefour, after a claim by two disability associations, to make its site and app accessible within six months or pay €500 a day.[source 8: Caen court order against Carrefour] |
| Netherlands | Implementatiewet toegankelijkheidsvoorschriften | ACM | Not verified by us [source 9: ACM webshop test] | In tests of large webshops published in March 2026, the ACM found that ordering with assistive technology was impossible at 61% of them.[source 9: ACM webshop test] |
| Sweden | Lag (2023:254) | PTS | Sanction fee of SEK 10,000 to SEK 10,000,000 [source 10: Swedish law 2023:254] | None found |
| Spain | Ley 11/2023 | Varies by sector | Up to €1,000,000 [source 11: Spain RDL 1/2013 Art. 83] | None found |
Austria, Belgium and Italy are on our list too; we show their figures once we have verified them. We have not found a published fine against an online shop under any national EAA law so far (checked 25 October 2026). Supervision and court orders have started. This is general information, not legal advice.
Check your own Shopify store for free →
§ 3 · Built to be trusted
A record you can stand behind.
Testamur is built for shops that want evidence they can show: what was tested, when, with what result, and what changed after each fix.
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Every scan dated and kept.
Your accessibility record grows with every check. Each scan and each statement version is saved as a dated snapshot that is never edited afterwards.
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No overlay, no script on your storefront.
Fixes go into your theme code, where the barriers are. Testamur prepares them; you approve and publish.
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Clear about what automation finds.
Every finding is mapped to EN 301 549, and every clause a machine cannot judge is marked for a manual check. That matters: the W3C notes that evaluation tools “can only assist” in determining accessibility[source 15: W3C on evaluation tools], and in a GOV.UK test of ten tools against 143 known barriers, the best single tool found 41%[source 16: GOV.UK tool test]. A Deque study found automated tests caught 57% of issues by volume[source 17: Deque automated testing study]. Your record says exactly which part was tested.
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Statements per country, reviewed by lawyers.
Accessibility statement templates are released country by country, each reviewed by a lawyer for that country first. You review the draft for your store before anything is published.
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Made in the EU, data stays in Frankfurt.
Built in Belgium. The website and request data are hosted in Frankfurt, Germany, and free checks run on our own computer in Belgium.
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Method and data public.
Read our study of EU Shopify stores: the method, the numbers and the data as CSV downloads.
Check your own Shopify store for free →
§ 4 · Why not an overlay
A toolbar on top does not fix the code underneath.
Accessibility overlays promise a fix with one line of script. Disability organisations, accessibility practitioners and a US regulator have said why that does not hold.
“Overlays do not make the website accessible or compliant with European accessibility legislation.”
“No overlay product on the market can cause a website to become fully compliant with any existing accessibility standard.”
$1 million
In April 2025 the US Federal Trade Commission finalised an order requiring overlay vendor accessiBe to pay $1 million. The FTC said the company misrepresented that its widget could make any website WCAG-compliant and formatted reviews and articles it was connected to so they looked independent[source 12: FTC final order against accessiBe].
Overlay widget and Testamur, side by side
| Question | Overlay widget | Testamur |
|---|---|---|
| Where it works | A script that loads on top of your pages and changes them in the visitor’s browser | Reads the code your theme and apps deliver; changes your live theme only with your approval |
| What it says about your store | Often “compliant” or “lawsuit protection” | What was found, where, and what was not tested |
| What stays behind | A toolbar icon | A dated record, a statement draft and fix guidance per barrier |
| Who fixes the code | Nobody: the original code stays as it was | You approve a prepared fix or your developer makes it; the next scan records whether the barrier is still detected |
Check your own Shopify store for free →
§ 5 · Pricing
Planned pricing
These are the prices we plan to launch with; they may change before launch. Billing runs through your Shopify invoice. Shopify bills in US dollars, so the euro amounts here are approximate. Paid plans are planned with a 14-day trial, and the first 100 merchants are planned to get a founding-customer price for 12 months: Essential €29, Pro €99 per month.
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Free
€0
See where your store stands.
- Storefront scan mapped to EN 301 549
- Top fixes and the full barrier report
- Preview of your accessibility statement draft
- EN 301 549 conformance report, viewable in the app
- One manual re-scan per week
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Essential
€49 per month, or €490 per year
Keep a statement live and the record running.
- Everything in Free
- Re-scan when your live theme changes
- Weekly scheduled scans
- Scan history: your dated record
- Hosted accessibility statement for one country
- Manual re-scans up to once an hour
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Pro
For stores selling in several countries
€149 per month, or €1,490 per year
The full record, for every country you sell to.
- Everything in Essential
- “What changed” comparison on every report
- Download the EN 301 549 conformance report
- Statements for every supported country
- Daily scheduled scans
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Audited
from €499 per month, on request
Adds the part a scan cannot do.
- Everything in Pro
- Periodic manual testing by a partner auditor, recorded in the same trail
Prices exclude VAT. A hosted statement for a country goes live only after a lawyer for that country has reviewed its template. Manual testing on the Audited plan is planned for after launch. Agencies managing several client stores can ask about a partner rate.
§ 6 · Questions
Questions merchants ask
Does the EAA apply to my shop?
If you sell to consumers in the EU online, probably yes, including when your business is based outside the EU. The main exception is for microenterprises that provide services: fewer than 10 staff and annual turnover or balance sheet of no more than €2 million[source 1: Directive (EU) 2019/882]. National laws set the details, so check with an adviser in your main market. Testamur does not give legal advice.
Will Testamur make my store compliant?
No tool can promise that, and we don’t. Testamur finds the barriers that automated tests can detect, maps them to EN 301 549, helps you fix them in your theme and documents the work. Part of the standard can only be checked by a person. What you get is an accurate picture and a dated record of progress.
How is this different from an accessibility widget?
A widget adds a script and a toolbar on top of your pages and leaves the underlying code as it is. Testamur adds no script to your storefront. It reads the code your customers receive, tells you what is wrong and where, prepares fixes you approve, and records what changes. See why not an overlay.
What does the scan not cover?
Anything that needs human judgement: whether alt text actually describes the image, whether a video has accurate captions, whether the page makes sense with a screen reader. In the scan report those clauses show as “Manual check needed”; in the EN 301 549 conformance report they stay “Not evaluated” until a person has tested them. The scan also does not cover Shopify’s checkout, which Shopify runs and themes cannot change, or PDFs and other documents you link to.
Does Testamur change my theme or slow my store down?
It never injects scripts and never changes your live theme without your approval. Today the app asks Shopify only for permission to read theme information, so it can tell when your theme changes. When fix preparation arrives at launch, fixes go into a copy of your theme that you preview and publish yourself, and Shopify asks you to approve that permission first. Scans load your public pages the way a visitor’s browser would; nothing from Testamur runs in your shoppers’ browsers.
Which countries and languages are covered?
We start with Germany and Austria, then the Netherlands and Flanders (Belgium). France follows in a second wave, planned for around February 2027. A country’s statement template goes live only after a lawyer for that country has reviewed it; until then, statement drafts are in English.
What data does Testamur keep?
Scan results for your public storefront pages, your statement versions and the dates of each. It does not need access to your customers, orders or products. If you uninstall, your store’s data is deleted as Shopify’s rules require.
When can I install it?
The app is in development and has not been submitted to the Shopify App Store yet. Join the waitlist to hear when it opens. There is no launch date to announce yet.
Free check
Check your own store first.
Ask for a free automated check of your Shopify store. You get the result by email after you confirm your address.
The report maps each finding to EN 301 549 and marks everything a machine cannot judge for a manual check.
§ 7 · Waitlist
Hear when Testamur opens.
One email when the app is listed on the Shopify App Store, and one if your country’s statement template is ready. Nothing else.
Want a first look at your own store? Free store check.
Annex · Sources
Sources
Every fact on this page links to one of these. Checked on 25 October 2026. Laws and their national versions change, so check the current text before relying on it.
- Directive (EU) 2019/882 on the accessibility requirements for products and services (European Accessibility Act): Art. 2–4, 13, 14, 31, 32, Annex I and Annex V EUR-Lex
- EN 301 549 Accessibility requirements for ICT products and services: V3.2.1 (2021) and V4.1.1 (2 September 2026) ETSI
- European accessibility standard EN 301 549 has been updated (7 September 2026) AccessibleEU, European Commission
- Barrierefreiheitsstärkungsgesetz (BFSG) § 37 Bußgeldvorschriften; see also § 14 and Anlage 3 Bundesministerium der Justiz, gesetze-im-internet.de
- BFSG Anlage 3: information on services, including the competent market surveillance authority gesetze-im-internet.de
- Website der Marktüberwachungsstelle der Länder (MLBF) online Bundesfachstelle Barrierefreiheit
- Code de la consommation, accessibility of products and services (Art. L.412-13 and following) Légifrance
- Pour le tribunal judiciaire de Caen, l’accessibilité des sites de e-commerce doit être totale (11 June 2026) Faire Face
- ACM: klant met beperking kan bij merendeel grote webwinkels niet terecht (24 March 2026) Autoriteit Consument & Markt
- Lag (2023:254) om vissa produkters och tjänsters tillgänglighet, § 39 Sveriges riksdag
- Real Decreto Legislativo 1/2013, Art. 83 (sanctions applied by Ley 11/2023, Art. 30) BOE
- FTC Approves Final Order Requiring accessiBe to Pay $1 Million (22 April 2025) U.S. Federal Trade Commission
- Accessibility overlays don’t guarantee compliance with European legislation (17 May 2023) European Disability Forum
- Overlay Fact Sheet overlayfactsheet.com (signed by accessibility practitioners)
- Selecting Web Accessibility Evaluation Tools W3C Web Accessibility Initiative
- What we found when we tested tools on the world’s least-accessible webpage (24 February 2017) GOV.UK Accessibility blog
- Automated testing study identifies 57 percent of digital accessibility issues (10 March 2021; vendor study) Deque Systems