Is Your Online Store Exempt From the European Accessibility Act? The Micro-Enterprise Exemption Explained

What the directive actually says

The exemption sits in Directive (EU) 2019/882, the law behind the European Accessibility Act. Two passages matter:

Article 4(5): "Microenterprises providing services shall be exempt from complying with the accessibility requirements referred to in paragraph 3 of this Article."

Article 3(23): "'Microenterprise' means an enterprise which employs fewer than 10 persons and which has an annual turnover not exceeding EUR 2 million or an annual balance sheet total not exceeding EUR 2 million."

In plain terms: the exemption is for small services businesses, and it is decided by the size of the company, not by how simple your website is.

The three tests

1. You provide a service. E-commerce services have been covered since 28 June 2025. The directive defines them as services provided at a distance, through websites and mobile apps, at the individual request of a consumer with a view to concluding a consumer contract (Articles 2(2)(f) and 3(30)). A shop selling physical goods is an e-commerce service, so the services exemption is the one that matters to you.
2. You employ fewer than 10 persons. Ten is already over the line. Count carefully, and note that the limit applies to the whole enterprise, not to one website.
3. Your money stays under €2 million. Annual turnover orannual balance sheet total of €2 million or less. The Commission's general SME definition (Recommendation 2003/361/EC) words this as "and/or"; the directive's own definition says "or". Either way, ask a professional how your national law applies it.

One more trap: ownership. If you belong to a group, or another company holds a significant stake in yours (or you in theirs), the SME rules can require their headcount and figures to be added to yours. A small shop owned by a large company may not qualify.

Worked examples

Illustrative examples only, applying the directive's wording. They are not legal advice and do not account for national rules.

What the exemption does not do

• It does not follow you as you grow. The exemption depends on your size. Once you pass the limits, the service requirements apply, so it is cheaper to build accessible habits before then.
• It is not the same as "disproportionate burden". Article 14 lets a business of any size argue that a requirement would be a disproportionate burden or a fundamental alteration, but only with a documented assessment against Annex VI.
• It does not change who your customers are. Roughly 1 in 4 EU adults have some form of disability. A shop they cannot use loses that sale whether or not the law requires you to fix it.
• It is set and enforced nationally. Each EU member state has its own law and authority. Check the markets you sell to.

Even if you are exempt, check anyway

The most common failures on small shops are cheap to fix: text that is too light, icon links with no name, images with no alt text. When we scanned 30 independent shops, none scored a perfect 100. Fixing them helps shoppers who use screen readers or magnifiers, and the same changes (descriptive alt text, readable contrast, labelled fields) tend to help search engines too.

If you are not exempt, our EAA guide for online stores explains what to do, and the Shopify accessibility checklist shows where each fix lives.

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