Who must comply with the European Accessibility Act: worked examples

The European Accessibility Act applies to companies that provide consumers in the EU with services on the Act's list, such as e-commerce, and that are not micro-enterprises. Where the company is registered does not matter: what matters is which service it offers and to whom. Below we go through typical examples and the mistakes that most often get in the way of a correct answer.

The short version of the filter is in the article “Who does the EAA apply to”. Here we go into more detail, with the practical nuances.

Three conditions

A company must meet the EAA requirements for services if all of the following apply:

1. the service is for consumers — private individuals, not only businesses;
2. the service is on the Act's list: e-commerce, consumer banking services, e-books, elements of passenger transport services, electronic communications, access to audiovisual media services;
3. the company is not a micro-enterprise.

How a micro-enterprise is defined

Under Article 3(23) of Directive 2019/882, a micro-enterprise is a company that:

• has fewer than 10 employees, and
• has an annual turnover of no more than €2 million or an annual balance sheet total of no more than €2 million.

Note the “or” inside the second condition. A company with a small team remains a micro-enterprise if at least one financial figure is no more than €2 million. With fewer than 10 staff, a company stops being a micro-enterprise only if both figures exceed €2 million.

Worked examples

The figures in these examples are illustrative and only show the logic.

Clothing shop with 30 employees

Sells to private customers in several EU countries. More than 10 employees, so not a micro-enterprise. Must comply.

Dropshipper with €3 million turnover

4 employees, €3 million turnover, €0.4 million balance sheet. Fewer than 10 employees and a balance sheet of no more than €2 million. This is a micro-enterprise despite the high turnover. Exempt.

Electronics shop with 8 employees

€5 million turnover, €2.6 million balance sheet. Both figures exceed €2 million. Must comply, despite the small team.

Wholesale supplier

Sells only to shops and restaurants, not to private individuals. This is not B2C. The EAA requirements for services most likely do not apply.

Clinic brochure website

Describes the clinic's services, with no online booking or payment. This is not e-commerce in the sense of the Act. Most likely they do not apply, but if the clinic starts selling services to consumers online, it is worth looking at the question again.

Shop from Israel selling into the EU

Sells to consumers in the EU, 15 employees. Being registered outside the EU does not exempt it by itself. Assume the Act applies and discuss the details with a lawyer.

Baltic company with a multilingual website

Sells to consumers in Lithuania, Latvia and Estonia, 12 employees. Must comply; it makes sense to publish the accessibility information in the languages of the countries where it sells.

Common mistakes in the assessment

“Our turnover is small, so it doesn't concern us.” Turnover is not the only factor. If you have 10 or more employees, you are not a micro-enterprise.

“Our turnover is large, so it concerns us.” Not always either: with fewer than 10 staff and a balance sheet of no more than €2 million, the company remains a micro-enterprise.

“We are not in the EU.” The Act looks at the service offered to consumers in the EU, not at the registered address.

“We are B2B, but our cart is open to everyone.” If private individuals can actually buy, those sales are B2C.

“The deadline has passed, so it's too late.” The requirements have applied since 28 June 2025, but it is never too late to start putting the site in order. Every new site and every redesign has to be checked again anyway.

What if the company is part of a group

If your shop is part of a group of companies or has a parent company, assessing its size may be more complicated than counting the employees of one legal entity. The EU has separate rules for linked and partner enterprises, so it is best to go straight to your accountant or a lawyer. Do not conclude “we are small” from the figures of just one company in the group.

What if we have several websites

The requirements apply to the service, not to the domain. If the company has several shops or language versions that sell to consumers in the EU, all of them should be checked and fixed. It is easiest to start with the version that brings in the most orders and then carry the template fixes over to the others.

What if EU sales are occasional

Sometimes a shop is aimed at another country but occasionally accepts orders from the EU. There is no clear-cut answer here: a lot depends on whether the shop deliberately offers its service to consumers in the EU, for example whether it ships to EU countries, shows prices in euros or has versions of the site in EU languages. In such cases, discuss the situation with a lawyer.

How to get the figures for the assessment

1. Employees. Your own HR records; for other companies, the “About us” page, job ads, LinkedIn.
2. Balance sheet and turnover. Your own financial statements or your accountant; for other companies, public registers such as the Unternehmensregister in Germany or KRS in Poland.
3. If data is missing, treat the result as “unclear” and check with an accountant or a lawyer.

A quick self-check

Answer “yes” or “no”:

• private individuals in the EU can place an order with us;
• we sell online or provide another service on the Act's list;
• we have 10 or more employees or both our turnover and our balance sheet exceed €2 million.

Three “yes” answers — the Act most likely applies. At least one “no” — most likely it does not. Not sure? Treat the result as “unclear” and check with a specialist.

If you must comply: what next

• Read the European Accessibility Act guide and the practical guide for online shops.
• Check your site: start with a free one-page check.
• Prepare your accessibility information.
• Look at your country's requirements: Germany, Poland, Czechia, Romania.

If you don't have to

An accessible website is still easier to use for older customers, for people with low vision and for anyone who temporarily can't use a mouse. But that is a matter of site quality, not a legal obligation. Don't let anyone scare you with fines if the Act does not apply to you.

Our service helps you assess the situation and find issues on your site. It is an automated check, not a full audit, and not legal advice.