If you run an online store for US customers, you have probably heard that an inaccessible website is a legal risk, and you may not have heard anyone say what the law actually asks of a private business. This guide separates what the US Department of Justice says from what it leaves open, explains why most teams build to WCAG, and gives you tools you can use this week: a test plan, a statement outline, a contract clause list and questions for a lawyer.
If you also sell to consumers in the EU, a different law applies. Read European Accessibility Act for online stores for that. This article stays with the US and does not repeat the EU checklist.
What the ADA says about websites
The Americans with Disabilities Act has separate parts for state and local governments (Title II) and for businesses open to the public (Title III). According to DOJ web guidance dated 18 March 2022, Title III covers businesses such as retailers. DOJ's position is that the ADA's requirements apply to the goods and services these businesses offer on the web. A notice on that page says it does not reflect the April 2024 rule for state and local governments, covered below.
The same page makes a point that matters for owners. DOJ says it has no regulation setting out detailed web standards, and that businesses have flexibility in how they comply with the ADA's general requirements. It relies on the general nondiscrimination and effective communication provisions. In DOJ's view, a missing technical standard is not the same as no duty.
What the guidance does not say
- It does not name a technical standard that a private business must follow. It describes WCAG and the federal Section 508 standards as helpful guidance, not as a legal requirement.
- It does not have the force of law. DOJ says the page is informal and has no legally binding effect, and that it may be rescinded or modified.
- It does not tell you what a court will decide about your store. That is a question for a US lawyer.
Government rules are different
For state and local governments, DOJ did set a standard. A rule published in the Federal Register on 24 April 2024 requires web content and mobile apps to meet WCAG 2.1 Level AA. A DOJ fact sheet says compliance dates, as extended by an interim final rule of April 2026, are 26 April 2027 for governments with a population of 50,000 or more, and 26 April 2028 for smaller ones and for special district governments. These dates have already moved once and can change again.
This rule does not set a standard for a private store. It matters to you in one case. The fact sheet says private companies are affected when they provide web content or mobile apps on behalf of a state or local government. If you sell to a school, city or state body, ask whether your contract passes these requirements to you.
WCAG: the standard to build and test against
The Web Content Accessibility Guidelines are an international technical standard from the W3C. W3C's overview page, updated 17 September 2026, lists WCAG 2.0 (December 2008), 2.1 (June 2018) and 2.2 (October 2023, updated December 2024). It calls 2.2 the latest version and encourages its use, and it says newer versions do not retire older ones. Content that meets 2.2 also meets 2.1 and 2.0, with one exception: a check called Parsing is obsolete in 2.2.
The guidelines have three levels: A, AA and AAA. Level AA includes all the A and AA requirements, and many organizations aim for it. W3C notes that it does not verify anyone's conformance claim, so the claim is yours to stand behind.
WCAG 2.2 added nine success criteria. Six of them are easy to picture in a store:
- Target size (minimum), level AA. Buttons and links are big enough to hit on a phone.
- Dragging movements, level AA. A price slider or image gallery also works without dragging.
- Accessible authentication (minimum), level AA. Logging in does not force a memory or puzzle test with no alternative.
- Redundant entry, level A. Customers are not asked to type the same details again in one process, with some exceptions.
- Focus not obscured (minimum), level AA. A sticky header or cart bar does not fully hide the item in focus.
- Consistent help, level A. Contact and help links stay in the same place across pages.
What Shopify says about its part
Shopify's accessibility statement, last updated 7 July 2025, says it uses WCAG 2.2 as its guiding principle and tests for Level AA. It publishes accessibility conformance reports in the VPAT (Voluntary Product Accessibility Template) format. The checkout report covers WCAG 2.2 A and AA. The admin report covers 2.1 A and AA. The report for its Dawn theme, version 2.4.0, covers 2.1 A and AA. The statement also says merchants have full control over their theme code and gives an email address for reporting problems.
As we read it, the statement does not settle who is responsible for your content, your edits or your apps. So treat the parts you choose as yours to check: theme changes, apps, product images, videos, pop-ups and every line of text. Ask each theme maker and app vendor for a conformance report, as Shopify publishes for checkout.
Test your store in one afternoon
W3C says no tool alone can decide whether a site meets accessibility standards, and DOJ says automated tools should be combined with manual checks. So plan the afternoon around the journeys that make you money.
- List your key journeys: find a product, pick options, add to the cart, check out as a guest, log in or reset a password, contact you, start a return.
- Do each journey with the keyboard only. Can you reach every control, use it and see where you are?
- Repeat on a phone, then zoom the browser in. DOJ's guidance lists text size and zoom among its accessibility practices.
- Run an automated checker on each page type: home, collection, product, cart and account.
- Check what a checker cannot judge: whether alt text describes the product, whether videos have captions, whether forms have labels and clear error messages, and whether color alone carries meaning.
- Ask someone who uses assistive technology to try the same journeys. W3C says bringing in the right people and skills improves an evaluation, and it has a guide on involving users with disabilities.
- Write down the date, pages, tools and results. This record feeds your statement and your fix list.
Rank the fixes using the factors in DOJ's first-steps guidance, which is written for governments but fits a store: does the content enable a key task, is it used often, has someone flagged it, and is it shared across many pages. A broken filter on every collection page comes before a missing label on a rarely used page.
An accessibility statement you can stand behind
W3C says a statement should give your commitment, the standard you apply, such as WCAG 2.2, and a way to contact you. It also suggests known limitations, the measures you take, supported browsers, tested environments and the laws that apply to you. DOJ's guidance also advises a way for the public to report problems.
A short outline for a store:
- One sentence of commitment, in your own words.
- The standard you work toward, and the date of your last test.
- What you tested and what you found, including known gaps.
- How to reach a person, and who answers.
- The date you last updated the page.
Write only what you tested. Do not claim full conformance without evidence. Make sure someone reads the contact inbox and replies.
Clauses for your agency brief or contract
- Target. Name WCAG 2.2 Level AA for listed templates: home, collection, product, cart, account, contact and policy pages, plus any custom cart or checkout features. Shopify publishes its own accessibility report for checkout, so ask what you can change there.
- Evidence. A dated test report that lists pages, tools, manual checks and open issues.
- Apps. A list of apps, with each vendor's conformance report requested before install.
- Fixing. Who fixes issues found after launch, within what period, and at what price.
- Content. Who writes alt text and captions, and who trains your team.
- Change control. A re-test after theme updates and after each new app.
- Handover. Test records, statement text and the list of known issues.
If a vendor promises instant compliance from one script, ask for test evidence on your own pages. For more on briefs and quotes, see a one-page brief for a web agency and questions before hiring an agency. If you want a partner for this work, see our web development and UI/UX design services.
Questions for a US lawyer
- How do courts and agencies in our state treat store websites under Title III?
- Do state or local laws add rules for our kind of business?
- Do we sell to, or build for, a government body that passes Title II duties to us?
- What should our statement say and not say?
- What should we do if a customer reports a barrier or sends a complaint?
This is general information, not legal or tax advice. Check the current rules or ask a qualified adviser before you decide.
How we can help
ESTASOFT shows a Clutch 2026 ranking as Top Shopify Company in New York City. To talk about accessibility in a Shopify build, see our web development and UI/UX design services, then send a short brief on the contact page. You may also want the website maintenance checklist, so that fixes last after the next theme update.
Sources
- ADA.gov: guidance on web accessibility and the ADA: Title III scope, no detailed web standard, informal status, barriers list (checked 3 November 2026)
- ADA.gov: fact sheet on the web rule for state and local governments: WCAG 2.1 AA rule, extended compliance dates, contractors (checked 3 November 2026)
- ADA.gov: web rule first steps (written for governments): combined automated and manual testing, how to prioritize fixes (checked 3 November 2026)
- W3C: WCAG 2 overview: versions, levels, backward compatibility (checked 3 November 2026)
- W3C: Web Content Accessibility Guidelines 2.2: new success criteria and their levels (checked 3 November 2026)
- W3C: WCAG 2 Level AA conformance: what AA includes, conformance claims not verified by W3C (checked 3 November 2026)
- W3C: evaluating web accessibility: tools versus manual review, involving users (checked 3 November 2026)
- W3C: developing an accessibility statement: what a statement should contain (checked 3 November 2026)
- Shopify: accessibility statement: WCAG target, VPAT reports, merchant theme control (checked 3 November 2026)