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Who does the European Accessibility Act apply to?

Updated October 12, 2026 · 3 min read

The European Accessibility Act applies to a website or app when three conditions are all met: the business offers a consumer (B2C) service, the service is in a covered sector such as e-commerce, and the business is not a micro-enterprise. If any one answer is "no", the EAA service requirements do not apply.

The three questions

1. Is it a B2C service?

Does the site sell or provide a service to private individuals? An online shop for consumers: yes. A brochure site of an industrial supplier, or a shop that only sells to registered businesses: generally no.

2. Is the service in a covered sector?

The EAA lists specific services:

  • e-commerce — goods or services ordered online by consumers;
  • consumer banking services;
  • e-books and reading software;
  • passenger transport services (websites, apps, e-tickets, travel information);
  • electronic communications;
  • access to audiovisual media services.

A restaurant's menu page, a blog or a local craftsman's portfolio does not fall under these categories unless it actually sells to consumers online.

3. Is the business a micro-enterprise?

Under Article 3(23) of the directive, a micro-enterprise has fewer than 10 employees and an annual turnover or an annual balance sheet total of no more than €2 million. Micro-enterprises providing services are exempt (Article 4(5)).

Read it carefully: a business is not a micro-enterprise if it has 10 or more employees, or if both its turnover and its balance sheet exceed €2 million. High turnover alone is not enough.

Examples

Business B2C? Sector? Micro? Result
Fashion shop, 25 employees, sells online to consumers in Poland yes e-commerce no covered
Drop-shipping store, 4 employees, €3m turnover, €0.4m balance sheet yes e-commerce yes (balance ≤ €2m) exempt
Furniture shop, 6 employees, €5m turnover, €2.5m balance sheet yes e-commerce no (both above €2m) covered
Industrial parts supplier, 60 employees, B2B-only portal no — — not covered
Online ticket sales for a bus company, 40 employees yes passenger transport no covered
Web design studio's own portfolio site no — — not covered

The drop-shipping example matters: many small online shops have high turnover but a small balance sheet and few staff. They are exempt.

How to check in practice

  1. Employees. Look at the "about" page, job listings and the company's LinkedIn page. 10 or more → the micro-enterprise exemption does not apply.
  2. Fewer than 10? Look at the balance sheet total. In Germany small companies publish abbreviated balance sheets in the company register; in Poland financial statements are available via KRS. Balance sheet ≤ €2 million → exempt.
  3. Balance sheet above €2 million, turnover unknown → treat as unclear and ask the owner or a lawyer.

When in doubt, we treat a case as "not covered" in our communication. We would rather under-claim than frighten a business without reason.

Non-EU businesses

The EAA can apply to companies registered outside the EU — for example in Ukraine, the UK or the US — when they provide a covered service to consumers in the EU. The same three questions apply.

If the EAA does not apply

Accessibility still pays off: customers with low vision, older shoppers, people on mobile phones in bright sunlight, and search engines all benefit from clear structure, contrast and labelled forms. You simply do not have a legal duty under the EAA.

Next steps

Our filter is built into every account. Start with a free check — an automated check, not a full audit, and not legal advice.

Sources

  • Directive (EU) 2019/882, Articles 2, 3(23) and 4(5), EUR-Lex: https://eur-lex.europa.eu/eli/dir/2019/882/oj