Does the European Accessibility Act Apply to You: Two Numbers Instead of Panic

It’s evening, you’re scrolling with one hand because the other is holding a mug. The headline: “Fines for inaccessible websites are already in effect.” Below it - a number with several zeros and the word “everyone.” You open it, read three paragraphs, understand approximately nothing except that you’ve already violated something. You close the tab, go to bed with a new anxiety you can neither verify nor fix, and in the morning it’s still there.

And here’s the real trick. In that same law that just scared you, there’s a separate clause that may apply to your specific size of business - and exempt you from the requirements. It just lives in the part of the text that headlines never reach: there are no sums there, no word “fine,” so it never makes the news. The fastest way to ruin your week is to read about a law that has an exemption written specifically for you, and stop at the paragraph about penalties.

This article is about how to check whether you’re even inside this law at all, before paying someone to rebuild your site. Not about how to make your site accessible - that’s a separate long conversation, and it only makes sense once you already know the answer to the first question. Here it’s only about whether you’re required to.

The document everyone calls the European Accessibility Act is officially named Directive (EU) 2019/882. This is not a separate “website law” or a special rule for online shops. It’s a European Union directive that sets uniform accessibility requirements for a range of products and services - essentially bringing different national rules to a common denominator so businesses don’t have to invent a separate approach for each country. E-commerce is included in that list, and for it the obligations have been in effect since June 28, 2025.

Now a small detail worth understanding once and never confusing again. A directive is a framework, not a ready-made law that can land on you tomorrow. It doesn’t apply to you directly the way your own country’s law does: each EU country transposes the directive into its own national legislation - with its own wording, its own supervisory body, its own list of sanctions, sometimes with its own clarifications. That’s why an article about fines in one country doesn’t describe the situation in another. And that’s why you won’t see any specific figures here: any number from a headline refers to a specific country, not “all websites in the world.”

What you take from this: the phrase “European Accessibility Act is in effect” says nothing about you personally. It says that the EU now has shared requirements for a certain set of products and services - and that’s it. After that there are exactly two questions. First: do you actually provide something from that set and does it reach the EU market. Second: does the directive exempt you separately, based on company size. The second question is cheaper - you can check it yourself, with your own documents, without calling a developer. So let’s start there.

Article 4(5) is that article headlines never reach. It exempts microenterprises providing services from accessibility requirements and the related obligations. Not softens, not grants a grace period, not offers a “simplified mode” - exempts. It’s worth reading exactly as written: this isn’t a concession you still need to earn, it’s that the requirement simply doesn’t apply to you.

The next logical question: who counts as a microenterprise. Here the directive doesn’t invent anything of its own - it takes the ready-made definition from a document called Recommendation 2003/361/EC. Under it, a microenterprise is a company with fewer than 10 employees and an annual turnover or balance sheet total not exceeding 2 million euros.

Those are your two numbers. How many people work for you and how much money flows through your company per year. Not “how complex is your website,” not “do you have a lawyer,” not “have you heard anything about accessibility.” Two numbers you already know without a consultant, because they live in your payroll and in your annual report. Note the word “or” in the second criterion: both turnover and balance sheet don’t have to match at the same time - so write out both, so you don’t have to calculate twice later.

What These Two Numbers Look Like in a Real Example

Imagine Oksana. She makes ceramics in a workshop near Lviv, sells through her own shop, and some orders go to Germany and Poland. Four people work with her: two at the wheel, one on packing and one on orders and correspondence. Last year the shop did around 280 thousand euros. Oksana read that same evening headline and spent three days wondering whether she’d have to pay for a new site, and how much that would cost before peak season. Her two numbers - five people and 280 thousand - both fit comfortably within the limits. Her shop provides an e-commerce service, and Article 4(5) is exactly the article for a situation like hers.

It’s worth being honest about the limits of this text: checking two numbers is not a legal opinion for your company. It’s a quick way to understand what field you’re even in before spending money. If you’re close to the boundary - nine people, turnover approaching two million - that’s exactly the case where one paid hour with a lawyer is worth more than three sleepless nights. Structures with related or partner companies can be separately tricky: there the math of “how many of us are in the office” stops working, and it’s better not to calculate that alone.

And one more scenario that’s easy to miss. Numbers don’t lock in forever. A company with eight people and 1.4 million in turnover last year can easily become a company with twelve people and three million this year - and microenterprise status disappears along with the exemption, with no warning at all. Nobody will send you a letter saying the exemption is no longer yours: it will simply stop being true. So checking two numbers should not be a one-time event after a scare, but a short note in the same place where you look at your annual report once a year.

Now a detail that makes it easy to celebrate too soon. The Article 4(5) exemption is written about services. The directive does not separately exempt microenterprises from requirements for the products themselves. That means one and the same business can be fully exempt in one part of its work and not exempt in another - and this isn’t a contradiction in the text, it’s a deliberate design.

The difference isn’t philosophical, it’s very practical. An online shop through which you sell is a service. But a thing with its own digital interface that you manufacture and bring to market is a product, and it lives under different rules in the directive. “Digital interface” sounds scarier than it is: it’s just a screen, buttons, sound or software through which a person operates the thing.

Imagine Igor. He has six people and turnover of about one million euros - by the two numbers he’s a microenterprise, just like Oksana. But Igor doesn’t resell other people’s goods: he makes his own kitchen scales with a screen, buttons and voice readout of the weight, and sells them including to buyers in the EU. Igor’s shop is a service, and the exemption works for the shop the same way it does for Oksana. But the scales themselves are a product with a digital interface that he brings to market, and the size-of-company exemption does not extend to them. Igor with his “fewer than 10 people” still has to understand the requirements - just not for the website, but for what he manufactures.

So the actual sequence of questions is: first - what exactly am I selling, then - what are my two numbers. If you’re selling other people’s goods through your own shop and the numbers are within range, the conversation is short. If you’re a manufacturer - the conversation about the site is short, but the rest of the questions remain open.

Let’s say you checked and exhaled: the exemption is yours. That’s wonderful news for the budget and a terrible reason to do nothing. The law and the customer are two different authorities, and the second one has never read a directive.

An accessible website is not charity and not a checkbox for an inspector. It’s an order form where fields have labels above them, not just grey text inside that disappears the moment you start typing. It’s a button you can reach with the Tab key when the mouse isn’t working or the person simply doesn’t use one. It’s contrast that makes the price visible in sunlight when the customer is standing outside with their phone. It’s photos with a proper text description instead of “IMG_2841.” None of this requires permission from a legislator, and none of it is done for one.

Why an Inaccessible Website Takes Money Silently

And here’s where the calculation gets personal. A person who couldn’t fill out your form doesn’t write you a letter of explanation. They simply go to a competitor, and in your analytics you see exactly nothing - no error message, just another incomplete purchase among a hundred others. This is the quietest kind of money loss there is: a broken process that never complains.

Practically, this means accessibility is worth keeping not in the folder marked “legal risks” but in the same routine where page load speed and checkout usability live - that is, in the ordinary technical work on your website and shop. That way this topic stops being an event and becomes part of how you maintain your site at all.

A separate word about the set of rules you’ll inevitably find in search results. The technical accessibility standard for web pages is called WCAG, and most checklists and plugins are based on it. It’s genuinely useful as a reference: most of its points are those same simple things about contrast, keyboard navigation and field labels. But no checklist and no plugin automatically guarantees full compliance with the directive. A plugin that promises to “bring your site into compliance with one button” is selling you peace of mind, not a result.

Not with the site. With a sheet of paper where you write down a few lines and come back to them in a year.

1. Number of employees as of today - the exact figure from your payroll, not a feeling of “there aren’t many of us.”
2. Annual turnover for the last closed year and, separately, the balance sheet total.
3. What you sell: other people’s goods through your own shop, your own services - or your own product with a screen, buttons or software component.
4. Whether you have buyers from EU countries and whether you accept orders from there at all.
5. The date of the check and the name of the person who did it - so that next year it’s clear what exactly has changed.

The first two points give the answer about the exemption. The third shows whether that answer covers your whole business or just the site. The fourth determines whether this conversation is about you at all. The fifth saves you next time a new evening headline with zeros appears.

And only after that does it make sense to look at the site itself. And your first check you’ll do by hand with no tools at all: open your checkout page, put the mouse aside and try to go through the whole path to the payment button using only the Tab and Enter keys. If you get lost even once and don’t know where you are - you’ve just seen your site through the eyes of some of your buyers. This check proves nothing legally, but it honestly shows you what you’re dealing with.

Your first step today: open your payroll and annual report, write down two numbers - headcount and turnover - and stop there. Then you’ll see whether you need the rest of this topic at all.