Who the European Accessibility Act applies to

The European Accessibility Act applies to your website if you use it to provide a service the Act lists to consumers in the EU, unless you are a micro-enterprise. It has applied since 28 June 2025, through national law.

Five questions settle it for most businesses, and each one rests on an article of the Directive (Directive (EU) 2019/882). This is a guide to the Directive, not legal advice: your national law and your national authority have the last word.

Our guide to the European Accessibility Act for websites covers what the Act then asks of a website, and how to show you meet it.

1. Do you provide a service the Act lists?

The Act does not cover websites as such. It covers services, and a website is how many of them are provided. Article 2(2) lists the services:

• electronic communications services, such as phone and internet access;
• services that give access to audiovisual media services;
• five elements of air, bus, rail and waterborne passenger transport: websites, mobile apps, electronic tickets and ticketing, travel information, and interactive self-service terminals in the EU (for urban, suburban and regional transport, only the terminals, though selling tickets online is still e-commerce);
• consumer banking services;
• e-books and the software made for them;
• e-commerce services.

E-commerce is the one most websites meet. Article 3(30) defines it as “services provided at a distance, through websites and mobile device-based services by electronic means and at the individual request of a consumer with a view to concluding a consumer contract”. In plain terms: if a consumer can order or book something on your site, you probably provide an e-commerce service. A site that only informs, and sells or books nothing, is usually not an e-commerce service, but it can still be part of another listed service: the website of an airline, or of a bank or telecom operator that serves consumers, is usually part of that listed service. Other laws may also apply.

The Act also covers products, such as computers, phones, payment terminals and e-readers. This guide is about services.

2. Do you provide it to consumers in the EU?

The Act applies to services “provided to consumers after 28 June 2025”. A consumer, in the Directive, is an individual who buys or uses the service for purposes outside their trade, business, craft or profession. A shop that sells only to business customers, and does not offer its service to individuals for private use, does not provide it to consumers; if individuals can buy from it for private use, they are consumers.

Where you are based does not decide it. The Directive’s service provider is anyone who provides a service on the EU market or offers it to consumers in the EU (Article 3(4)), and Article 4(1) requires those services to comply. A shop outside the EU that sells to consumers in the EU is in scope. How an authority enforces that against a business outside the EU is a matter for national law.

3. Are you a micro-enterprise?

Article 4(5) exempts “microenterprises providing services” from the service requirements “and any obligations relating to the compliance with those requirements”. Article 3(23) defines a micro-enterprise as one that “employs fewer than 10 persons” and has “an annual turnover not exceeding EUR 2 million or an annual balance sheet total not exceeding EUR 2 million”.

The money limits are alternatives; the staff limit is not.

Four details change the answer for some businesses:

• Staff are counted as annual work units. Recital 53, which guides how the definition is read, says that to benefit, a micro-enterprise must “genuinely fulfil the requirements” of the EU’s SME Recommendation (2003/361/EC). That Recommendation counts full-time equivalents over the year, with part-time work as a fraction, and owner-managers count as staff.
• Group companies count. Under the same Recommendation, the figures of linked enterprises, such as a parent company, are added in full, and those of partner enterprises in proportion to their share of capital or voting rights, whichever is greater. A small subsidiary of a large group is not a micro-enterprise on its own figures.
• Status changes slowly. Under the Recommendation, crossing a limit changes your status only after two consecutive financial years.
• The exemption covers services only. A micro-enterprise that also makes or sells covered products keeps the product obligations, though it need not document a disproportionate-burden assessment for them; it only has to give the authority the relevant facts if asked (Article 14(4)).

National laws transpose the test. Denmark’s act, for example, uses the Directive’s definition (§ 3, no. 19) and exempts micro-enterprises that provide services (§ 6(3)). Check how your country’s law words it, and how it counts staff.

4. Is some of your content excluded?

If the Act applies, it applies to the service as a whole, but Article 2(4) leaves some website and app content out:

• pre-recorded video and audio published before 28 June 2025;
• office file formats, such as PDFs and documents, published before 28 June 2025;
• online maps and mapping services, provided that, for maps meant for navigation, the essential information is also given in an accessible digital form;
• third-party content that you neither fund, develop nor control;
• websites and apps that qualify as archives, because they contain only content not updated or edited after 28 June 2025.

These exclusions have no end date. They are separate from the Act’s transition periods, which concern products already in use and service contracts agreed before 28 June 2025. Video, audio and office documents you publish from 28 June 2025 on are in scope, and a site no longer counts as an archive once you update or edit its content after that date.

5. Would meeting the requirements be a disproportionate burden?

Article 14 says the requirements apply only to the extent that meeting them neither fundamentally alters the service’s basic nature nor imposes a disproportionate burden. Up to that point you still have to meet them. The burden is weighed against the criteria in Annex VI: the net cost of compliance against your overall costs of providing the service, operating and capital; your estimated costs and benefits against the estimated benefit for people with disabilities, given how much and how often the service is used; and the net cost against your net turnover.

It is not a blanket exemption:

• you make and document the assessment yourself, keep it for five years after you last provide the service, and give the authority a copy if it asks (14(3));
• you renew it when the service changes, when the authority asks, and at least every five years (14(5));
• you cannot claim the burden if you received outside funding to improve accessibility (14(6));
• you tell the authority in each country where you provide the service that you rely on Article 14 (14(8)).

How your authority reviews these assessments depends on your national law.

What to do on each answer

• The Act applies. Start with what it asks of the website: the functional requirements, and how to test them. The Directive names no standard; EN 301 549 is the usual reference, and its web clauses follow WCAG at Level AA. See the EN 301 549 clauses that apply to a website. Then publish the information Annex V asks for; see what Annex V asks a service to publish.
• You are a micro-enterprise. You are exempt from the service requirements, but keep a note of your figures in case your authority asks, and check again as you grow.
• You do not provide a listed service, or not to consumers. The Act does not apply to that service. Other rules may: most public-sector websites and apps fall under the Web Accessibility Directive (Directive (EU) 2016/2102), and a public body that sells online can be covered by both.
• You are not sure. Ask your national authority. In Denmark, for example, § 45(2) of the 2022 act gave supervision of e-commerce, banking, e-book and audiovisual access services to the Safety Technology Authority, which became part of the Danish Business Authority (Erhvervsstyrelsen) on 1 January 2026. Check the current text of your country’s law.