In short. The European Accessibility Act covers online consumer contracting and exempts microenterprises providing services under its staff and financial thresholds.
Definition: The European Accessibility Act covers ecommerce services provided through websites or mobile device-based services at a consumer's individual request with a view to concluding a consumer contract. Article 4(5) exempts microenterprises providing services from the service accessibility requirements and the obligations relating to their compliance.
Key facts
- Article 2(2)(f) of the European Accessibility Act covers ecommerce services provided to consumers after 28 June 2025, subject to transitional measures.
- The European Commission's Your Europe accessibility guide lists online shops and ticketing platforms among the services covered.
- Annex Article 5 of Commission Recommendation 2003/361/EC measures staff in annual work units, counting part-time and seasonal work as fractions.
Which online transactions fall within scope?
Article 3(30) of Directive (EU) 2019/882 defines ecommerce services through four elements: provision at a distance, through websites or mobile device-based services, by electronic means, and at an individual consumer's request with a view to concluding a consumer contract.
Under Article 3(22), a consumer is a natural person acting outside their trade, business, craft or profession. Recital 43 explains that the ecommerce obligations cover the online sale of any product or service. The goods sold can therefore fall outside the Act's separate list of covered products. Article 3(4) defines a service provider by reference to services on the Union market or offers to consumers in the Union.
Which businesses qualify for the microenterprise exemption?
Article 3(23) of the Act defines a microenterprise as an enterprise employing fewer than 10 persons with either annual turnover or an annual balance sheet total not exceeding EUR 2 million. The headcount condition applies alongside either financial condition. Article 4(5) exempts qualifying service providers from the requirements in Article 4(3) and related compliance obligations.
Recital 53 points to the enterprise-size rules in Commission Recommendation 2003/361/EC. Annex Article 5 includes owner-managers in staff and uses annual work units: a person working full-time throughout the reference year represents one unit. Annex Article 3 defines linked enterprises through control relationships, including majority voting rights; partner enterprises generally involve holdings of at least 25% without such a link. Annex Article 6 requires aggregation of data from partner and linked enterprises; linked-enterprise data are added in full where they are absent from consolidated accounts.
The exemption concerns the provision of services. Article 4(5) gives no equivalent blanket exemption for a microenterprise's activities involving covered products.
What must a covered ecommerce service make accessible?
Article 4(3) of the Act directs covered services to Annex I, Sections III and IV. Section III(c) covers websites, related online applications and mobile applications. Section IV(g) specifically covers identification, security and payment functionality, including electronic signatures. It also requires information about the accessibility of the products and services sold when the responsible economic operator supplies that information.
The Commission's Your Europe guide describes interoperability with assistive technologies, including screen readers, and different input and output options, including keyboards and voice.
Which website content is excluded?
Article 2(4) of the Act excludes prerecorded time-based media and office file formats published before 28 June 2025. It also excludes third-party content where the operator neither funds nor develops nor controls it.
Online maps are excluded subject to accessible essential navigation information. The archive exclusion covers website and application content that is neither updated nor edited after the application date.
Related terms
FAQ
Does the ecommerce definition cover sales exclusively to businesses?
Article 3(30) of the Act requires a consumer contract. If you sell exclusively to buyers acting for their business, those transactions fall outside that ecommerce definition.
Can you qualify with exactly EUR 2 million in annual turnover?
Yes, provided you also meet the headcount condition. Article 3(23) says turnover must not exceed that amount and also allows the annual balance sheet total as the alternative financial test.
Does an older website receive a general extension?
Article 32(1) provides a transition for products used to deliver services and permits service contracts agreed before 28 June 2025 to continue unchanged until expiry, for up to five years. Website age alone is outside those transition conditions.
Sources
- European Parliament and Council, "Directive (EU) 2019/882 on the accessibility requirements for products and services", 17 April 2019
- European Commission, "Commission Recommendation 2003/361/EC concerning the definition of micro, small and medium-sized enterprises", 6 May 2003
- European Commission, Your Europe, "Accessibility requirements for services and products", last checked 12 July 2026
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