Accessibility Statement
The European Accessibility Act (EAA) has been in force since 28 June 2025. For most service providers above a certain size, the obligation is already active. The question for smaller businesses is whether the microenterprise exemption applies to them.
Who qualifies as a microenterprise under the EAA?
Directive (EU) 2019/882 defines a microenterprise as a company with fewer than 10 employees and an annual turnover or balance sheet total of no more than 2 million euros. Both thresholds come from the Directive itself — not from an audit report or a national regulator's guidance.
Microenterprises that provide covered services are exempt from the EAA. That means they are not required to publish an Annex V accessibility statement or bring their service into conformance with EN 301 549 and WCAG 2.2 AA.
Does the exemption cover products?
No. The microenterprise exemption applies only to service providers. If your company manufactures or sells a covered product — a self-service terminal, an e-reader, a ticketing machine, an ATM — the EAA applies regardless of your size or turnover.
This distinction matters for businesses that do both. A company with eight employees that sells e-readers and also offers an e-commerce platform must comply with the EAA for the product side, even if the service side is exempt.
Which services are covered?
Covered services under Directive (EU) 2019/882 include:
- E-commerce
- Banking services
- E-books and dedicated software
- Electronic communications
- Passenger transport booking services
- Audiovisual media access services
If you provide any of these and your employee count or turnover exceeds either threshold, the obligation is in full effect now.
What does compliance require for service providers above the thresholds?
An accessibility statement under Annex V of Directive (EU) 2019/882 must include a description of how the service meets the accessibility requirements, the standard used — EN 301 549 and WCAG 2.2 AA — known limitations, and a contact point where users can report barriers.
The statement is not a self-declaration of perfection. It is a dated, honest account of the current state of the service, including what does not yet meet the standard.
The starting point for any business is straightforward: count the employees, check the annual figures. If you are below both thresholds and provide only services, the EAA exemption applies. If you are above either one, the requirements under Directive (EU) 2019/882 apply now.
Key points
- The EAA has applied since 28 June 2025 to covered service and product providers above the microenterprise thresholds.
- A microenterprise is defined in Directive (EU) 2019/882 as fewer than 10 employees and no more than 2 million euros in annual turnover or balance sheet total.
- The microenterprise exemption covers service providers only — it does not apply to manufacturers or sellers of covered products regardless of size.
- Covered services include e-commerce, banking, e-books, electronic communications, passenger transport booking, and audiovisual media access services.
- An EAA Annex V statement must reference EN 301 549 and WCAG 2.2 AA, list known limitations, and provide a contact point for reporting barriers.
Frequently asked questions
Is a microenterprise exempt from the European Accessibility Act?
Only if it provides services. Under Directive (EU) 2019/882, microenterprises — fewer than 10 employees and no more than 2 million euros in annual turnover or balance sheet total — that provide covered services are exempt. The exemption does not apply to products.
When did the European Accessibility Act come into force?
The EAA has applied since 28 June 2025. Service and product providers above the microenterprise thresholds are required to comply now.
Does the EAA apply to companies outside the EU?
Yes, when they offer a covered service to consumers in the European Union. The obligation is based on where the consumer is located, not where the company is registered.
What must an EAA Annex V accessibility statement include?
A description of how the service meets the accessibility requirements, the standard used (EN 301 549 and WCAG 2.2 AA), known limitations, and a contact point for users to report barriers.
My company has 8 employees but sells e-readers. Does the EAA apply?
Yes. The microenterprise exemption covers service providers only. Manufacturers and sellers of covered products — including e-readers, terminals, and ticketing machines — must comply regardless of size.
