Does the European Accessibility Act apply to my business?

Which businesses does the EAA cover?

It covers businesses that offer certain services to consumers in the EU, with the online shop as the most common example. The EAA is an EU directive, Directive (EU) 2019/882. Each country turned it into national law, and those laws apply from 28 June 2025.

The services it covers:

• Online shops and other "e-commerce services": websites and apps where consumers can buy something. The Dutch regulator, the ACM, reads this broadly: websites and apps where a consumer can "purchase, rent, order, take out, or reserve something", including offers where they pay with personal data instead of money.
• Consumer banking services.
• E-books and the software used to read them.
• Phone, internet and messaging services ("electronic communications services").
• Passenger transport by air, bus, rail and water: the websites, apps, e-tickets and travel information.
• Services that give access to TV and video ("audiovisual media services").

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

What counts as a micro-enterprise?

A business with fewer than 10 staff, and an annual turnover or an annual balance sheet total of €2 million or less. Both parts must be true: the headcount, and at least one of the two money figures.

The directive and the Dutch and Belgian laws use the same wording. Some government websites summarise it loosely, for example as "more than 10 staff". The law is clear: at exactly 10 staff, you're not a micro-enterprise.

Two examples:

• A 6-person shop with €5 million turnover and a €3 million balance sheet is not a micro-enterprise. It has fewer than 10 staff, but both money figures are above €2 million.
• A 6-person shop with €5 million turnover and a €1.5 million balance sheet is a micro-enterprise. It has fewer than 10 staff, and one of the two figures is €2 million or less.

The directive also says you have to genuinely meet the EU's general definition of a small business. If your business is part of a group, or you're close to the line, check with your accountant how to count staff and figures.

Is the exemption permanent? At EU level and in the Netherlands, there's no end date. Belgium is different. The Belgian law exempts micro-enterprises only until 28 June 2030. After that date, the rules apply to them too, unless the Belgian government decides otherwise. We didn't find any such decision.

Micro-enterprises that make or sell products covered by the EAA aren't exempt. They get lighter paperwork instead.

What if I only sell to businesses?

If consumers can't order from you, the online-shop rules generally don't apply. The EAA protects consumers: people buying for themselves, outside their trade or profession. An online shop is covered when it's offered to consumers "with a view to concluding a consumer contract".

Mixed shops are a grey area, and we found no official guidance on them by name. The ACM's wording points one way: the rules cover all websites or apps with an offer for consumers, "even if you only offer products or services in a small section of your website or app". So if consumers can buy from you, even in one part of your site, assume the rules apply.

What if my company is outside the EU?

The rules still apply when you sell to consumers in the EU. The EAA defines a service provider as anyone who provides a service on the EU market "or makes offers to provide such a service to consumers in the Union". There's no requirement to be based in the EU. A US or UK shop that sells to Dutch or Belgian consumers is covered in the same way as a local one. If you sell in the US too, the ADA is a separate question: see our guide on the ADA.

Is there a transition period?

Not for websites and apps in the Netherlands. The ACM says: "There is no transitional period for services." Your website or app had to be accessible from 28 June 2025.

The EAA and the Dutch law do have a few limited carry-over rules:

• Equipment you already used to provide a service before 28 June 2025 may stay in use until 2030.
• Contracts with consumers made before 28 June 2025 can continue unchanged until they end, but for no more than five years.
• Self-service terminals, like ticket machines, may stay in use for up to 20 years.

None of these delay the rules for a new or existing website. Belgium's extra time applies only to micro-enterprises (until 2030), as above.

What does "accessible" mean in practice?

In practice, it means your site meets the international accessibility standard, WCAG, at level AA. The EAA itself describes requirements in general terms. The European standard behind it points to WCAG. The ACM says websites and apps must meet WCAG 2.1 level AA now, and that WCAG 2.2 level AA becomes the standard in the course of 2026. It recommends working toward 2.2 already.

The ACM also says an independent audit is not mandatory, and neither is a certificate, label or quality mark. What's mandatory is the result: an accessible service, plus an accessibility statement that explains how your service meets the requirements.

There are two narrow exceptions for businesses that aren't micro-enterprises. A requirement doesn't apply if meeting it would fundamentally change the nature of your service, or would be a disproportionate burden. You have to assess and document that, and report it to the regulator. It's not a general way out.

What to do next

1. Check whether you're a micro-enterprise: count your staff, and look at your last annual turnover and balance sheet total. If you're in Belgium, note the 2030 end date.
2. Check whether consumers can buy, book or sign up on your site or app, even in one section.
3. Find out where your site stands against WCAG level AA. A free scanner is a start. An accessibility review gives you a full list of what to fix.
4. Fix what blocks people first, such as a checkout you can't use with a keyboard.
5. Publish your accessibility statement. See our guide on what it must contain.