The European Accessibility Act, Directive (EU) 2019/882, has applied since 28 June 2025. That is not a future deadline: it is already the law in every EU member state. If you run a website for a small business, the useful question is not "what do we need to build" but "does this even apply to us".

Who the EAA actually covers

The directive targets specific products and services: e-commerce, banking, e-books, telecoms and passenger transport services, among others. If your site sells something online, takes payments, or operates as a banking or ticketing service, it is likely in scope. A plain brochure site with a contact form generally is not.

The exemption most small businesses miss

Article 4(5) of the directive is explicit: "Microenterprises providing services shall be exempt from complying with the accessibility requirements referred to in paragraph 3 of this Article and any obligations relating to the compliance with those requirements." A microenterprise means fewer than 10 staff and under EUR 2 million in annual turnover or balance sheet total.

That exemption only covers services, not physical products you manufacture or sell as goods. It also will not stop a marketplace, payment provider or bank you integrate with from asking you to meet accessibility standards anyway, regardless of your own size.

Why it is worth checking even if you are exempt

The European Commission estimates around 87 million people in the EU live with some form of disability, a figure it expects to rise as the population ages. The first EAA court cases were filed in France in November 2025, only months after the law took effect, which suggests this will not stay theoretical for long.

A practical starting point

  • Decide whether your site is a covered service (e-commerce, bookings, payments) or a brochure site.
  • If covered, check your staff count and turnover against the microenterprise thresholds above.
  • If exempt today, treat basic WCAG practice as insurance: you may grow past the thresholds, or a partner may require it regardless.

This is general information, not legal advice. For a definitive answer on your own obligations, speak to a lawyer familiar with the EAA in your country.

Not sure where your site stands? Every AuditMerlin scan includes 11 WCAG 2.2 AA markup checks, from image alt text and page language to form labels, heading order and zoom lock, next to its security checks. A clean result means no visible markup faults, not a full EAA sign-off (colour contrast and keyboard testing still need a human), but it shows you where to start in a couple of minutes.