Does the EAA apply to my micro-enterprise?

It depends what you do. If you are a true micro-enterprise (fewer than 10 employees and under €2 million annual turnover) providing services only, you are exempt from the EAA's service obligations. If your micro-enterprise manufactures, imports or distributes a covered product — for example consumer electronics or e-readers — the product requirements still apply regardless of your size.

Does it matter where my company is based?

No. What matters is where your customers are. If you sell products or services to consumers in the EU, the European Accessibility Act applies to that part of your business even if your company is registered outside the EU.

What deadline am I actually at risk of missing?

The EAA has applied since 28 June 2025 — that deadline has already passed. There is no new grace period; enforcement is a matter of when your national authority runs a check or receives a complaint, not a future date to prepare for.

EAA deadline 2025: who actually has to comply with the European Accessibility Act?

EAA Comply · Updated July 2026 · 7 min read

The European Accessibility Act — Directive (EU) 2019/882 — has applied since 28 June 2025. That date already passed over a year ago, which means the question is no longer "when," it's "am I covered, and how exposed am I right now." This article gives you a fast, honest answer, including the one exemption people keep getting wrong.

The short version

You are almost certainly covered unless you are a true micro-enterprise offering services only. If you sell products or services to consumers anywhere in the EU — regardless of where your company is registered — the EAA very likely applies to some part of what you do.

Who is covered

The Act lists specific sectors, and it's broader than most business owners assume. It's not just "assistive tech companies" — it's ordinary commerce:

E-commerce — any online shop selling to EU consumers is explicitly in scope. This is one of the most commonly missed categories, because founders assume the Act is about accessibility-specialist products.
Banking and consumer financial services — online banking interfaces, contracts, and related apps.
Transport ticketing — self-service kiosks, apps and websites for buying tickets (air, rail, bus, ferry).
E-books and e-reading software.
Consumer electronics with interactive interfaces — smartphones, computers, TV equipment with digital services.
Telecoms services — including the apps and portals customers use to manage them.

The rule that trips people up most: it doesn't matter where your company is based — what matters is where your customers are. A US-based or UK-based online shop selling to French or German consumers is squarely inside the EAA's scope for that part of its business, exactly as if it were headquartered in Paris or Berlin.

The micro-enterprise exemption — and the nuance almost everyone misses

The Act does carve out an exemption for micro-enterprises: businesses with fewer than 10 employees and under €2 million in annual turnover. So far, straightforward.

The nuance: this blanket exemption only applies to microenterprises providing services. If your micro-enterprise manufactures, imports or distributes a covered product — say, a small electronics brand selling a connected device, or a niche e-reader manufacturer — the product-side obligations still apply to you, regardless of your headcount or turnover.

In other words: "I'm too small" protects a nine-person accessibility-consulting shop offering only services. It does not automatically protect a nine-person hardware startup shipping a physical product with a digital interface.

Practically, this means the exemption is narrower than the number of people who invoke it. If your business is a service (an online shop selling other people's goods, a booking platform, a SaaS tool used by consumers) and you genuinely sit under both thresholds, you likely qualify. If any part of what you sell is a physical product with digital functionality, check the product rules specifically before assuming you're exempt.

Quick decision flow: whether the EAA applies depends on where your customers are, your company size, and whether you sell a physical product.

How enforcement differs by country

The EAA is a directive, which means each EU member state transposed it into its own national law — with its own enforcement body and its own penalty scale. A few examples worth knowing, briefly:

Country	National law / enforcement
Spain	Ley 11/2023 transposes the EAA; Spain's existing accessibility enforcement framework already reaches six-figure fines for serious cases.
Germany	The Barrierefreiheitsstärkungsgesetz (BFSG) is Germany's transposition, with fines that can reach up to €100,000 and active market surveillance.
France	Décret n° 2023-931 plus the existing RGAA standard set the technical bar; French courts have already ruled on non-compliant e-commerce (see below).
Netherlands	The ACM (Autoriteit Consument & Markt) is the designated market surveillance authority handling EAA enforcement and complaints.

The pattern across all four: each country runs its own inspections and complaint process, so "the EAA" in practice means whichever national authority covers your customers — sometimes several at once if you sell across borders.

What "comply" concretely means

The Act points to the technical standard EN 301 549, which for websites and apps effectively means WCAG 2.1 level AA: keyboard operability throughout, real form labels, sufficient colour contrast, meaningful text alternatives for images, and no information conveyed by colour alone. Alongside the technical work, you need one published document: an accessibility statement describing honestly how your service meets the requirements and how users can report problems.

No private company needs an external certificate or seal — the legal obligation is that your site actually conforms and that your statement is accurate, not aspirational.

What happens if you ignore it

The clearest recent signal came from France. In June 2026, a court in Caen ordered a major retailer, Carrefour, to bring its e-commerce site to full accessibility compliance within six months — despite Carrefour already measuring at 71% RGAA compliance, which the company argued should count as substantial progress. The court disagreed: partial compliance was ruled insufficient, and the corrective order applied regardless of the effort already made.

That's the practical lesson for anyone tempted to do a partial fix and call it done: courts and regulators are not grading on a curve. Beyond corrective orders, fines under national transpositions can run into six figures in several member states, and any consumer or disability organisation can file the complaint that triggers an inspection in the first place.

Quick self-check

Do any of your customers live in the EU — regardless of where your company is registered or hosted?
Do you sell online — a shop, a booking engine, a subscription, a marketplace listing?
Do you have 10 or more employees, or turnover above €2 million — or, even if not, do you manufacture or distribute a physical product with a digital interface?
Have you ever tried completing your own checkout or sign-up using only a keyboard, with the mouse unplugged?
Do you currently have a published, honest accessibility statement — not a template nobody checked against your real site?

If you answered yes to the first two and either part of the third, you're covered. If you're unsure how your actual code performs against WCAG 2.1 AA, that's exactly what a scan is for rather than guesswork.

Find out exactly where you stand

Run the free scan on your homepage — real axe-core analysis of your actual code, not a checklist guess. If you fall into a covered category, it's the fastest way to see your real exposure.

Run my free scan

Once you know you're covered, the next steps are concrete: read the full European Accessibility Act guide for the complete compliance path, work through our 2026 online shop accessibility checklist page by page, and if someone has already pitched you a one-line fix, see why accessibility overlays don't hold up under the EAA. Web agencies fielding these questions from clients can see our white-label audit programme. For the paid, page-by-page version of this work, see audit pricing.