The European Accessibility Act for small businesses.

The short answer

The European Accessibility Act is Directive (EU) 2019/882, adopted on 17 April 2019. Each EU country had to turn it into national law by 28 June 2022 and apply that law from 28 June 2025, so the rules you deal with are your own country's version, such as Germany's Barrierefreiheitsstärkungsgesetz. The core is the same everywhere.

It covers a fixed list of products and services, not every website. For a small business the line that matters is e-commerce: a service provided at a distance, through a website or app, at a consumer's request, with a view to a consumer contract. In plain words, a site or app where a member of the public can buy something.

Then comes the exemption. A microenterprise is a business with fewer than 10 staff and an annual turnover, or an annual balance sheet total, of no more than 2 million euros. Microenterprises that provide services are exempt from the service requirements. So a five-person shop below that size is exempt for its webshop, and a 30-person shop selling online to consumers is not.

If you are in scope, your service must meet the Act's accessibility requirements, you must publish information on how it meets them, and you must keep it that way as the site changes. Each country sets its own enforcement and penalties, so check your national law with your own adviser.

What the Act covers

Products placed on the market after 28 June 2025:

• Computers and their operating systems, for consumers.
• Payment terminals, and self-service machines such as cash machines, ticket machines and check-in machines.
• Smartphones and other consumer devices used for phone and messaging services or for watching audiovisual media services.
• E-readers.

Services provided to consumers after 28 June 2025:

• Phone, messaging and other electronic communications services.
• Services that give access to audiovisual media, such as TV and video platforms.
• Websites, apps, e-tickets and travel information for air, bus, rail and waterborne passenger transport.
• Consumer banking.
• E-books and the software for reading them.
• E-commerce.

If your business is not on these lists, the Act does not apply to you, however public your website is. A clinic's information site or a plumber's quote form is not e-commerce in the Act's sense, because nobody concludes a contract on the page. Public bodies have a separate law, the Web Accessibility Directive.

When a small business website counts as e-commerce

The definition has four parts: a service at a distance, through a website or app, at a consumer's individual request, with a view to concluding a consumer contract. The recitals add that it covers the online sale of any product or service. Clear cases:

• An online shop that sells to the public, on Shopify, WooCommerce or any other platform.
• A business that sells courses, tickets, gift cards or memberships online.
• A hotel or guesthouse that takes bookings and payment on its own site.

Online bookings and deposits are the grey area. A salon where clients book and pay a deposit online is selling a service at a distance. In Germany, the chambers of commerce list online appointment booking tools as an example of e-commerce under the German law. Other countries may read it differently, so check your national authority's guidance or ask your adviser.

Out of scope: a site that only informs, a contact or quote form that leads to a call, and sales to other businesses. The Act defines a consumer as a person buying for purposes outside their trade, business or profession.

Where you are based does not decide it. The Act defines a service provider as anyone who provides a service on the EU market or offers it to consumers in the EU. A shop in the US or the UK that sells to consumers in the EU falls under the Act for that service, unless it is a microenterprise.

The microenterprise exemption, step by step

The definition is in Article 3 of the Act. An enterprise is a microenterprise if it employs fewer than 10 persons and has an annual turnover of no more than 2 million euros, or an annual balance sheet total of no more than 2 million euros. Both parts must be true: the headcount, and one of the two money tests. Work through it like this:

• Count the people you employ. Ask your accountant how part-time and seasonal staff count where you are.
• If you employ 10 or more people, you are not a microenterprise, whatever your turnover.
• If you employ fewer than 10, check last year's turnover and balance sheet total. If either is at or below 2 million euros, you are a microenterprise.
• If your business is part of a group, ask your adviser whether linked businesses count together.

The exemption covers services only. Microenterprises that provide services are exempt from the service requirements and the duties that come with them. A microenterprise that makes, imports or sells products on the Act's list, such as e-readers or computers, still has duties for those products, with lighter paperwork in some cases.

Growth matters. A shop that hires its tenth employee, or grows past both money tests, leaves the exemption, and its webshop then has to meet the requirements. If you are close to the line, build accessibility into your next website redesign rather than waiting.

Each country must also give microenterprises guidelines and tools to help them apply the rules, so your national authority's website is worth a look even if you are exempt.

What a shop in scope has to do

The requirements are written as outcomes in Annex I of the Act. For websites and apps, the core is that they are perceivable, operable and understandable for people with disabilities, and work with their assistive technology. E-commerce adds three points:

• Give the accessibility information about the products you sell, where the maker or supplier provides it.
• Make identification, security and payment steps accessible when they are part of your service.
• Offer sign-in methods, electronic signatures and payment services that people with disabilities can use.

In practice, the reference for websites is EN 301 549, the European standard for accessible digital products and services, which takes in the WCAG success criteria. Version 3.2.1 points to WCAG 2.1. A new version, 4.1.1, was published on 2 September 2026 to support the Act and points to WCAG 2.2 at levels A and AA. A standard gives you the legal presumption that you meet the Act once the EU cites it in its Official Journal, so ask your adviser which version applies on the day you check.

Whatever the version, the work on a small shop is the same. Product pages, filters, the basket, sign-in and checkout must work with a keyboard and a screen reader, with enough contrast, visible labels on form fields, alt text on product photos and errors explained in words.

The accessibility information you must publish

A service provider in scope must explain how its service meets the requirements. Annex V says to put this in your general terms and conditions or an equivalent document. Article 13 says it must be available to the public in written and oral form, in a way people with disabilities can use, for as long as the service runs. A common way to do it is an accessibility page linked from the footer and from the terms. Annex V asks for:

• A general description of the service, in an accessible format.
• What a customer needs to know to understand how it works, such as how to search, order and pay.
• How the service meets the requirements, for example the standard and level it was tested against.

Two more items make the page useful to customers: the gaps you know about, with a plan to fix them, and a way to get help by phone and by email.

Write it for customers. "If you cannot complete checkout, call us on the number at the top of this page and we will take your order by phone" is more use than a page of legal text. Ask your adviser what the oral form means in your country.

When a business can say the rules go too far

Article 14 gives two exits. The requirements do not apply where meeting them would fundamentally change the basic nature of the service, or would put a disproportionate burden on the business. Neither is a shortcut:

• You must carry out and document an assessment against the criteria in Annex VI, which weigh the net cost of compliance against your overall costs and the benefit for people with disabilities.
• You keep the assessment for five years after you last provide the service, and show it to the authority if asked.
• You renew it when the service changes, when the authority asks, and at least every five years.
• You cannot claim it if you received funding to improve accessibility.
• Unless you are a microenterprise, you tell the authority in each country where you provide the service.

For an ordinary shop on a mainstream platform, a disproportionate burden will be hard to show, because the fixes are part of normal site work. Treat it as a last resort to discuss with your adviser.

Dates and transitional rules

• By 28 June 2022, every EU country had to adopt its national law.
• From 28 June 2025, the rules apply to products placed on the market and services provided to consumers.
• Service contracts agreed before 28 June 2025 may continue unchanged until they expire, but no longer than five years from that date.
• Until 28 June 2030, service providers may keep using products they lawfully used before 28 June 2025 to provide similar services.
• Some older content is excluded: pre-recorded audio and video and office documents such as PDFs published before 28 June 2025, and archived content that is not updated after that date.

The exclusions do not cover anything new. A product page you add, a new video or a new PDF price list falls under the rules if your shop is in scope, and so does old content once you update it.

Who enforces it, and how it differs from the ADA

Each country names the authorities that check compliance and sets its own penalties. The Act requires penalties to be effective, proportionate and dissuasive, and to come with action to fix the problem. A service provider that finds its service does not comply must fix it and tell the authorities in the countries where it provides the service.

Compared with the rules in the US:

• The EAA is enforced by public authorities. In the US, private individuals bring website claims through demand letters and lawsuits.
• The EAA has a technical reference in EN 301 549. No US regulation sets one for business websites.
• The EAA exempts microenterprises that provide services. Title III of the ADA has no exemption for small businesses.
• The EAA covers a fixed list of products and services. The ADA covers businesses open to the public in general.

If you sell in both markets, one site built to WCAG 2.2 AA covers most of the technical ground for both. Our guide to ADA website accessibility covers the US side, including what to do with a demand letter.

What a five-person shop should do now

Take a homeware shop in the Netherlands with five staff, selling to customers across the EU from its own Shopify store:

• Check the microenterprise test with your accountant and write down the result, the date and the figures you used.
• If you are a microenterprise, the webshop is exempt. Fix the basics anyway, such as contrast, labels, alt text and keyboard use, because they cost little and every customer benefits.
• If you are not, or expect to grow past the line, test the shop now: the home page, a category page, a product page, the basket and checkout.
• Ask your platform and theme supplier which WCAG version and level they meet, and whether the checkout and payment steps have been tested.
• Fix what you can in the theme and the content, publish an accessibility page and add a line about it to your terms.
• Put the target, WCAG 2.2 AA, in the contract for your next redesign.

Do not buy an overlay widget to cover the gap. The European Disability Forum and the International Association of Accessibility Professionals have said that overlays do not make a website compliant with European law. See do accessibility overlays work.

GGSites builds online stores on Shopify or WooCommerce. If you are planning one, say at the start that it has to meet the Act, because testing every template against a standard is real work and it belongs in the quote.