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
- Employees. Look at the "about" page, job listings and the company's LinkedIn page. 10 or more → the micro-enterprise exemption does not apply.
- 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.
- 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
- New to the topic? Read our EAA guide.
- Covered? See what to fix first in the WCAG 2.2 checklist and prepare your accessibility information.
- Country rules: Germany, Poland, Czechia, Romania.
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