Agency Guide: How to De-Risk Clients from EAA Fines & Build a Profitable Compliance Retainer

The email lands in your inbox from your top client. The subject line reads: "Urgent: European Accessibility Act Compliance."

Your stomach drops.

You know their Shopify store is a conversion machine. The branding is perfect, the UX is seamless. But you also know that, under the hood, hundreds of product images have missing or placeholder alt text. You know the theme has some navigation quirks. You know that, as of June 28, 2025, every one of those small oversights is now a compliance violation for any customer they serve in the EU.

And you know who they'll look to when a regulator comes knocking? You. Their agency.

This is the moment that defines your client relationships. This is client-facing risk, and it's now one of the biggest undisclosed liabilities in your agency. But it's also your single greatest opportunity to evolve. The compliance crisis facing your clients is the catalyst to move beyond project work and build a high-margin, recurring-revenue service that makes your agency indispensable.

This guide will show you how.

The Threat: Why EAA & ADA Compliance Is Now a Core Agency Responsibility

The ground has irrevocably shifted. For any agency managing a Shopify store that sells to customers in the EU or the US, ignoring digital accessibility is no longer an option. The risk is driven by two unstoppable forces.

1. The European Accessibility Act (EAA) Enforcement Has Begun

As of June 28, 2025, the EAA is the law of the land in the European Union. This isn't a "best practice" guideline; it's a mandatory legal standard for e-commerce. For your clients selling into the EU, failure to comply with WCAG-aligned standards exposes them to:

• Significant financial penalties that vary by member state.
• Being legally barred from selling into the EU market.
• Reputational damage and costly, time-sensitive remediation orders.

If your client gets fined, the first question they will ask is why the agency managing their store didn't protect them.

2. Surging ADA Lawsuits Are Targeting E-Commerce

In the US, the threat is litigation. Digital accessibility lawsuits under the Americans with Disabilities Act (ADA) are accelerating, with e-commerce as the primary target.

The data is alarming. In the first half of 2025 alone, a staggering 22.6% of digital accessibility lawsuits were filed against websites that were already using an accessibility "widget" or "overlay." These businesses thought they were protected. Instead, they painted a target on their backs.

The Trap: Why Common "Solutions" Will Get Your Clients Sued

In a panic to address compliance, many merchants—and their agencies—will reach for two seemingly easy fixes. Both are traps that will amplify, not mitigate, your client-facing risk.

1. The Widget Fallacy

Accessibility overlays promise a one-line-of-code fix. In reality, they are a dangerous liability. These tools apply a superficial JavaScript layer over the website, but they do not fix the underlying source code. Legal auditors and their scanning tools bypass these layers and go straight to the code.

When the FTC fined a leading provider, accessiBe, $1 million for deceptive marketing, it sent a clear signal: the government and courts know these widgets don't work. Recommending one is no longer a defensible strategy.

2. The "Keyword-Stuffing" AI Risk

The next temptation is using a generic AI app to auto-generate alt text. Most of these tools don't actually see the image. Instead, they scrape product titles and tags to create keyword-stuffed alt text like alt="Blue T-Shirt - Summer Collection - For Sale".

This is not accessibility. It is a compliance failure waiting to happen.

WCAG guidelines—the technical standard for both the EAA and ADA—mandate that alt text be a literal description of the image for screen reader users. "Blue T-Shirt" is a label. A compliant description is: alt="A person wearing a crewneck, short-sleeve t-shirt in a solid royal blue color."

Using a keyword-stuffing tool fills a data field but fails the legal test, leaving your client exposed.

The Opportunity: Building Your EAA Compliance Retainer

Instead of reacting with risky shortcuts, you can proactively solve this problem for your clients and create a powerful new revenue stream for your agency. It's time to offer an EAA & ADA Compliance Retainer.

This isn't just an add-on; it's a strategic service that protects your clients from catastrophic fines and cements your role as their essential partner. Here's how to structure it.

Phase 1: Baseline Audit & Risk Report (One-Time Project)

First, you establish the risk. This audit becomes your legal and strategic foundation.

• Deliverable: A comprehensive audit of the client's store against WCAG 2.1 AA standards, focusing on high-risk areas like image alt text, forms, keyboard navigation, and checkout flows.
• Action: Use the audit to produce a "Risk Report" that clearly documents vulnerabilities and provides a prioritized remediation roadmap.
• Pricing: Charge a flat project fee based on catalog size. This initial project is the perfect entry point to upsell the retainer.

Phase 2: Initial Remediation Sprint (One-Time Project)

Next, you fix the most critical issues to immediately lower the client's risk profile.

• Deliverable: A fully remediated product catalog with compliant, descriptive alt text for every image, plus fixes for any other high-priority issues found in the audit.
• Action: Use a true Vision-AI tool like Lumi AI to generate genuinely descriptive, WCAG-compliant alt text for the entire product catalog. This is the heavy lift that is simply unprofitable to do manually.
• Result: You demonstrate massive, immediate value by eliminating thousands of compliance violations in days, not months.

Phase 3: Monthly Compliance Retainer (Recurring Revenue)

This is where you turn risk mitigation into a predictable, high-margin revenue engine.

Deliverables:

• Ongoing Monitoring: Monthly scans to ensure all new products and content remain compliant.
• Automated Content Compliance: Use Lumi AI to automatically generate compliant alt text for all new product images as they are added.
• Quarterly Compliance Reporting: Provide documented proof of the store's ongoing compliance status, reinforcing the value of your retainer and giving their legal team tangible evidence of good-faith efforts.

Pricing: Frame this as insurance. A retainer of $300 to $1,500 per month (based on catalog size) is a rounding error compared to a potential five- or six-figure fine. With a tool like Lumi AI automating the heaviest workload, your margins can easily exceed 50-60%.

Lumi AI: The Engine for Your Defensible, Profitable Service

This entire business model is only possible with the right technology. You need a tool that is legally defensible, scalable, and efficient.

Lumi AI was built specifically to solve the core challenges of Shopify agency EAA compliance.

1. Legally Defensible with True Vision-AI: Unlike competitors, Lumi doesn't guess based on product titles. Our Vision-AI analyzes the pixels of each image to generate a truly descriptive alt text that meets stringent WCAG standards. This is the only automated approach that provides a defensible compliance record.

2. Built for Agency Scale: You can't build a profitable service if it takes weeks to remediate one client's catalog. Lumi's bulk processing allows you to process up to 500 products simultaneously. You can fix an entire store's image library in a single afternoon.

3. Brand Voice Intelligence: Compliance shouldn't come at the cost of your client's brand. Lumi's AI learns your client's unique tone, ensuring that all generated content—from alt text to full product descriptions—is not only compliant but also on-brand.

Your Agency's Next Step

The EAA deadline has passed. The ADA lawsuits are accelerating. Your competitors will either ignore the risk or recommend faulty widgets.

This is your chance to lead. By building an EAA compliance service powered by Lumi AI, you can protect your clients, bulletproof your agency's reputation, and create your most profitable recurring revenue stream yet. Don't wait for your clients to ask about the EAA. Be the strategic partner who brings them the solution.

Ready to build your compliance practice? Calculate your ROI or install Lumi AI from the Shopify App Store.

Learn more about compliance: Why accessibility widgets fail, the 2025 alt text mandate, and how accessibility drives SEO.