The European Accessibility Act targets economic operators that provide an e-commerce service to the public. In practice: almost every European online store is concerned — with two nuances that decide your fate, the nature of the activity and the size of the company.

Who is concerned by default

Any e-commerce service aimed at consumers: selling physical products, services, subscriptions, marketplaces. The EAA more broadly covers online banking, transport ticketing, e-books and electronic communications, but for an e-merchant, remember one simple rule: if a private individual can buy from you online, you're in scope.

The microenterprise threshold

A business is exempt if it meets TWO cumulative conditions: fewer than 10 employees AND (annual turnover ≤ €2M OR balance-sheet total ≤ €2M). Both must be true at the same time. A 4-person store at €3M turnover is therefore not exempt; a 12-person store at €1M isn't either.

⚠ Services yes, products no

The microenterprise exemption only applies to services. For placing products covered by the EAA on the market, the exemption doesn't work the same way. In e-commerce practice, it's the online service that's targeted — and that's where the exemption can apply.

What to do if you're exempt

  1. 01Document the exemption: a dated internal note justifying the thresholds (headcount, turnover, balance sheet)
  2. 02Keep it for at least 5 years
  3. 03Be able to produce it on the authority's request (DGCCRF, ARCEP)

// Why aim for compliance anyway

An exemption is legal, not commercial. Nearly 15% of European consumers live with a permanent or temporary disability. An inaccessible site loses these customers — and more still in organic search, because much of accessibility remediation also fixes technical SEO issues (structure, alternatives, labels).

The trap of the moving threshold

The exemption is lost the moment you cross a threshold durably. Growth that takes you past 10 employees or €2M tips you into the obligation — with no automatic alert. Better to anticipate compliance before reaching the threshold than to have to redo everything in a hurry after a good year.

Frequently asked questions

I only sell B2B, am I concerned?

The EAA targets services aimed at consumers (B2C). A strictly B2B service is less directly targeted — but the line is blurry (a professional buyer may have a disability) and the RGAA remains an expected quality standard. Don't rely on this argument alone.

Are the thresholds assessed at group or entity level?

At the level of the entity operating the service, but belonging to a group may be taken into account when assessing means — particularly to invoke the "disproportionate burden". When in doubt, have it validated by legal counsel.

Is my agency or host responsible instead of me?

No. The obligation falls on the economic operator providing the service — that is, you. You can delegate the implementation, never the responsibility.

Knowing where you stand, exempt or not, starts with a dated stocktake:

→ Run an audit