A useful store audit tests real shopping journeys—not just the homepage—against accessibility standards and the site’s actual data practices. Work through representative pages, check them manually as well as with automated tools, trace personal data and cookies, compare what you observe with the privacy notice, then document and retest fixes. This is issue-spotting, not a universal legal-compliance determination: applicable duties depend on where your business operates, whom it serves, and what data and services it uses.
1. Define the scope and capture a baseline
Before testing, record the systems and paths that shape a customer’s experience. Note your ecommerce platform, themes or templates, integrations, checkout provider, regions served, and any account, analytics, marketing, or support services. Select representative page types and complete journeys, not merely a list of URLs.
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- Home and category pages
- Product details, including image galleries and variant selectors
- Search results and filters
- Cart and checkout, including error and confirmation states
- Account creation, sign-in, and password recovery
- Customer support and product inquiry forms
- Marketing sign-up and cookie or privacy preference controls
Keep a baseline record of the browser, device, viewport, assistive technology where relevant, date, and steps taken. GOV.UK’s guidance for detailed accessibility audits describes sampling site content and functionality against WCAG 2.2 AA; the right sample for a store should include its important interactions and templates, not just its front page (GOV.UK accessibility testing guidance).
2. Audit accessibility against WCAG 2.2
Use the success criteria in WCAG 2.2 as the technical reference. The W3C’s WCAG 2.2 Quick Reference can be filtered by role, technology, and conformance level, but it is supporting material; the technical standard contains the requirements. Test each selected journey from beginning to end, including the point where a shopper submits information or completes a purchase.
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Check content and navigation
- Images that convey product information have meaningful text alternatives; decorative images do not create distracting redundant announcements.
- Headings describe the page structure, and controls have clear, programmatically associated labels.
- Text, icons, and control boundaries have sufficient contrast for the applicable WCAG criteria.
- Keyboard focus is visible and moves in a logical order; menus, dialogs, filters, galleries, and cart controls can be operated without a mouse.
- Controls behave predictably, and changing a selection does not unexpectedly move focus or submit a form.
Check forms, errors, and authentication
Try product inquiries, account forms, discount fields, shipping details, and checkout with keyboard-only input. Confirm that instructions are available before an error occurs, errors identify the affected field and explain how to correct it, and successful submission is understandable. Test sign-in and account recovery too; authentication barriers can prevent access to the whole shopping journey.
WCAG 2.2 Success Criterion 2.1.1 states: “All functionality of the content is operable through a keyboard interface without requiring specific timings for individual keystrokes, except where the underlying function requires input that depends on the path of the user’s movement and not just the endpoints.” (World Wide Web Consortium, Web Content Accessibility Guidelines (WCAG) 2.2.)
3. Combine automated screening with manual testing
Run an accessibility scanner across representative templates to find issues it can detect, then verify results by using the site. A clean scan does not establish that the store conforms: automated checks cannot determine whether all content is meaningful or whether a shopper can complete the real journey. GOV.UK notes that a detailed audit examines content and functionality and can be carried out by a technically skilled internal reviewer or a paid third party; complex sites may warrant an external audit and quote (GOV.UK accessibility testing guidance).
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- Run a scanner on key pages and save the URL, findings, and date.
- Repeat the shopping path using only a keyboard. Check focus visibility, order, and whether every control works.
- Where available, test with a screen reader and inspect whether headings, labels, instructions, and errors are announced usefully.
- Manually review content and interactions that automated tools cannot judge, including product alternatives, labels, and the clarity of error recovery.
- Record confirmed problems separately from scanner warnings that you have not verified.
4. Map personal data from collection to deletion
Start an inventory for data collected through product inquiries, accounts, checkout, marketing sign-ups, analytics, and support. The FTC’s business guidance puts it plainly: “Effective data security starts with assessing what information you have and identifying who has access to it.” (Federal Trade Commission, Protecting Personal Information: A Guide for Business.)
For each data type, document:
- Where and how it enters the business, including fields, cookies, pixels, and integrations
- The business purpose and whether the data is needed for it
- Where it is stored and how long it is retained
- Which vendors or other recipients receive it, and what they do with it
- Which staff or roles can access it
- How it can be corrected or deleted when appropriate, and who handles the request
- How the business protects it and responds if there is an incident
Follow the information through the whole path: a checkout field may reach the ecommerce platform, payment provider, fulfillment service, and customer-support system. Minimize collection, protect information you keep, dispose of data no longer needed, and prepare an incident response. See the FTC business guide to protecting personal information.
5. Compare actual tracking with the privacy notice
Use a clean browser profile so pre-existing cookies do not obscure what the store does. Record behavior before making a choice, then accept, reject, or customize the available options and observe what changes. Note the cookie or tracker, apparent purpose, vendor, and whether the choice affects its behavior. Cookies may support shopping-cart or preference functions, analytics, or targeted advertising; these purposes should not be treated as interchangeable (FTC guidance on online advertising and cookies).
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Compare those observations with the privacy notice and consent interface. Do they accurately describe what the store and its vendors collect, use, and share? Does the interface’s wording match the choices it actually implements? The FTC advises businesses to honor their privacy promises (FTC privacy guidance). If you find a mismatch, record the observed behavior and the disclosure that appears inconsistent, then assign it for investigation rather than assuming a particular legal result.
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Do I need consent in order to use cookies on my organisation’s website? The answer depends on the jurisdictions and circumstances involved. The EDPB’s SME FAQ describes the general EU rule as requiring users to be informed and consent to storage of or access to information on their devices, with an exception for technically necessary cookies (EDPB SME FAQ). Do not extend that statement automatically to every country, tracking technology, or business situation.
Identify where the business operates and targets customers, what information is involved, and which third-party services are active. Then verify the applicable requirements for those facts with suitable current legal guidance. An audit can identify discrepancies and questions; it cannot decide legal applicability for an unspecified store.
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7. Rank findings, assign fixes, and retest
Prioritize findings using user harm or data risk, how many templates or customers they affect, severity, and effort. A checkout keyboard trap or an unexpected disclosure of sensitive data may warrant faster attention than a low-impact issue confined to one page. Assign an owner and due date, fix the cause where possible, and rerun the same path to confirm the result.
For each finding, retain evidence that another person can reproduce:
- Page URL and steps to reach the issue
- Browser, device, viewport, and assistive technology used
- Observed result and expected behavior
- Relevant WCAG criterion or privacy disclosure, where applicable
- Risk or reach, owner, due date, and status
- Retest date and result after remediation
GOV.UK notes that an external auditor can prioritize issues, recommend fixes, and audit again after remediation (GOV.UK accessibility testing guidance). The same retest discipline is useful for privacy changes: verify that a consent choice, revised form, or vendor change actually alters observed behavior.
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8. Publish an accurate accessibility statement
A statement should help customers understand your commitment and how to get help; it should not claim more than your testing supports. The W3C’s guidance recommends explaining the standard applied, known limitations, measures taken, contact route, prerequisites, and tested environments, with relevant legal references where useful (W3C accessibility statements guidance).
- Name the accessibility standard you are working toward.
- Describe the pages or journeys and environments tested.
- State known limitations and any remediation underway honestly.
- Provide a contact route for reporting an access barrier.
- Update the statement when the site or its tested status changes.
Or skip the browser setup
For repeatable page captures while documenting an audit, ScreenshotNeo offers a website screenshot API and MCP server. A screenshot can preserve what a page looked like at a point in the review, but it does not test keyboard access, prove what data was collected, or establish compliance. Capture different consent states deliberately and keep interaction testing in your audit.
One GET request returns a screenshot or PDF. For example, save a WebP capture of a page you are reviewing:
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curl -G "https://api.screenshotneo.com/v1/shot" -d access_key=YOUR_API_KEY --data-urlencode url=https://your-store.example/ -o shot.webpSee the ScreenshotNeo API documentation for request options. Cookie banners can be accepted and more than 60 known consent platforms, newsletter popups, and chat widgets removed before capture; each of those steps can be turned off. Bot checks, blank pages, timeouts, failed loads, and cache hits cost nothing, and response headers report the page verdict and billing status. Its MCP server gives AI agents tools for screenshots, page information, and PDF capture. The free plan includes 1,000 screenshots a month with no card; paid plans start at $5 for 3,000 screenshots.
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