If consumers can buy something on your website or app and you employ 10 or more people (or turn over more than €2 million), you are almost certainly in scope of the European Accessibility Act. The law has applied since 28 June 2025. So for most online businesses the practical question is no longer "does it apply to me". It is "what can I show if someone asks".

This guide covers who is in, the one exemption that exists (and how narrow it really is), the two defenses the law provides, and a five-question self-check at the end.

What the EAA is, in one paragraph

The European Accessibility Act is Directive (EU) 2019/882, an EU-wide law that each country writes into its own national rulebook. It requires certain products and consumer-facing services sold in the EU to be accessible to people with disabilities. In Germany that national law is the BFSG (Barrierefreiheitsstärkungsgesetz), in Austria the BaFG, in Czechia Act 424/2023 Sb., in Poland the 2024 accessibility act. All of them have applied since 28 June 2025 for products placed on the market and services provided from that date.

Who is covered

Services (the big category for online businesses)

  • E-commerce. Any website or app where a consumer can conclude a contract, meaning complete a binding purchase: buy a product, book a service, take out a policy. This is the broadest hook in the whole law. It catches almost every online shop, booking platform, and subscription sign-up flow. Sectors not named separately (insurers, for example) usually get pulled in through this route the moment consumers can buy online.
  • Consumer banking services. Account access, payments, consumer credit interfaces.
  • Electronic communications / telecom services.
  • E-books and dedicated reading software.
  • Elements of passenger transport services. Websites, apps, electronic ticketing, and real-time travel information for air, bus, rail, and waterborne transport (with some sector-level carve-outs).
  • Access layers to audiovisual media services. The portals and apps through which consumers reach streaming and broadcast content.

Products

Manufacturers, importers, and distributors of: consumer computers and operating systems, smartphones, self-service terminals (payment terminals, ATMs, ticketing and check-in machines), consumer terminal equipment for telecom and audiovisual services, and e-readers.

The micro-enterprise exemption, precisely

This is the most misunderstood part of the law, so here it is exactly:

  • The exemption applies to service providers only.
  • A micro-enterprise employs fewer than 10 persons AND has annual turnover not exceeding €2 million (or a balance-sheet total not exceeding €2 million). Both conditions together: 9 employees with €3M turnover does not qualify, and neither does 15 employees with €1M turnover (source: Directive (EU) 2019/882, EUR-Lex).
  • Product-side actors get nothing. If you manufacture, import, or distribute in-scope products, there is no micro-exemption at any size.

So a truly tiny pure-service business can be out of scope. Everyone else selling to consumers online is in. One more detail worth knowing: if questioned, it is on you to show you qualify as a micro-enterprise, not on the authority to prove you don't.

The defenses that exist (and what they actually require)

The EAA is not absolute. Two relief mechanisms exist, and both get misread as loopholes:

  • Disproportionate burden. A provider may argue that meeting a specific requirement would cost far more than it helps. But you do not just declare this. You do the actual math (cost of compliance versus the benefit for persons with disabilities, relative to your resources), write it down, and keep it available for the market surveillance authority, the public office whose job is to check companies against this law. It is also partial relief: it excuses the one requirement that is disproportionate, not the law as a whole.
  • Fundamental alteration. Accessibility is not required where it would fundamentally change the basic nature of the product or service. A narrow, feature-level argument, not a business-wide one.

Note the pattern: both defenses live or die on paperwork. A claimed defense with nothing written behind it is itself a risk, because the authority can ask to see the assessment.

The five-question self-check

  1. Can a consumer complete a purchase on your site or app: buy, book, subscribe, sign up? If yes, you are providing an e-commerce service under the EAA.
  2. Do you employ 10 or more people, OR does your turnover (or balance sheet) exceed €2 million? If either is true, the micro-exemption is off the table.
  3. Do you sell, import, or distribute in-scope products (terminals, e-readers, consumer hardware)? If yes, no exemption exists regardless of your size.
  4. Do you have a published accessibility statement (a public page saying how accessible your site is) and a documented check of your site against EN 301 549 / WCAG 2.1 AA, the technical standard the law points to? If not, that is the first visible gap an authority or complainant will find.
  5. If you rely on disproportionate burden anywhere: is it written down? An undocumented defense is not a defense.

If questions 1 to 3 put you in scope, the next move is evidence, not adrenaline. Most of what actually fails on real sites (contrast, alt text, form labels, missing statements) is quick to spot and often cheap to fix.

Both halves of question 4 can be done right now: our free website accessibility checker tests one page against WCAG 2.1 AA, and the accessibility statement generator drafts a statement from your own details. Neither needs a signup.

FAQ

Q: We only sell B2B. Are we in scope? A: The EAA protects consumers. Pure B2B services generally fall outside the service obligations. But check whether consumers can in fact buy on your site (a public checkout usually means they can), and remember that product obligations follow the product, not the buyer.

Q: We're based outside the EU but sell to EU consumers. Does it apply? A: Yes. The obligations attach to services provided to consumers in the EU and products placed on the EU market, not to where the company is registered.

Q: Is there any transition period left? A: The core date, 28 June 2025, has passed for services provided from that date. Longer transitions (up to 2030) exist only for narrow cases such as service contracts concluded before that date and certain self-service terminals already in use.

Q: Doesn't our shop platform's theme handle this for us? A: Not by default. Analyses of real sites show standard e-commerce themes fail heavily out of the box (source: WebAIM Million). Theme-level fixes are efficient because they scale across the shop, but someone has to check them against the standard.

Sources

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Related article: From scan to statement: six steps to audit-ready accessibility

This article is informational and does not constitute legal advice.