Does the European Accessibility Act apply to a company that sells only to other businesses?

Generally, no. Article 2(2) of Directive (EU) 2019/882 covers only services provided to "consumers," and Article 3(22) defines a consumer as a natural person who purchases a product or is a recipient of a service for purposes outside their trade, business, craft or profession. A sale entirely between legal entities, with no natural person on the other side, sits outside the scope. But the boundary is not the company as a whole; it runs service by service. If an individual can buy or sign a contract as a consumer through your website, that part is e-commerce under Article 3(30) and is in scope. A site that only presents the company, a blog or a contact form is not a listed service.

Published 24.09.2026. Checked 24.09.2026.

What is the precise definition of a "consumer", not the feel of B2B?

"B2B" is not a term the directive itself uses; it is shorthand for something the text defines more precisely. Article 2(2) says the Act applies to its listed services "provided to consumers." Article 3(22) defines a consumer as "any natural person who purchases the relevant product or is a recipient of the relevant service for purposes which are outside his trade, business, craft or profession." So the right question is not "are we a B2B company," but "is the recipient of this specific service a natural person acting outside their own business." Selling software to an accounting firm stays out of scope, because the firm buys for a business purpose. The same software sold to an individual freelancer for their personal budget, not their trade, is a sale to a consumer in the part that reaches them.

Which parts of a B2B company can be in scope?

Article 2(2) lists which services are in scope, and a company website as such is not among them. E-commerce under Article 3(30) is a service through a website or app, provided at the individual request of a consumer with a view to concluding a consumer contract. A marketing site, blog, contact form, free demo or support channel that only presents the company or serves business customers is not a listed service. That stays true even when any visitor can reach it. What falls in scope is the part through which an individual can buy or sign a contract as a consumer, an online order with payment open to anyone, for instance. The check runs section by section, not company-wide.

Do your business customers' employees count as "consumers"?

The fact that an end user of your product is a natural person, an employee of your business customer, does not by itself make them a "consumer" under the Act. The definition requires that the person buy or receive the service for purposes outside their own trade, business or professional activity. An employee using an internal tool as part of their job duties acts within their professional activity, not outside it. So the Act does not treat that use as consumer use by default. The line stays practical rather than formal. The more broadly a tool is reachable outside the specific employment context, the more carefully you need to check whether a natural person is showing up as a consumer.

When is a sale to a company still a sale to a consumer?

A company invoice does not settle the question: the purpose of the purchase does. If an individual buys for personal needs, they are a consumer, however they pay. Likewise, if you sell hardware or a product from the list in Article 2(1), a self-service terminal for instance, rather than a service, different rules for products apply. These rules are separate from the services exception for business buyers.

Questions

If we are a B2B SaaS with a public landing page, is that page in scope?

Not necessarily. A public page is in scope only if an individual can buy or sign a contract as a consumer through it. A landing page, pricing page and contact form that only present the product to businesses are not a listed service.

Do we need to check every individual customer's status to be sure?

Listing every customer is not practical and is not required. A more reliable check runs by channel: through which pages, forms or features an individual can buy or sign a contract as a consumer, rather than which customers you have already signed.

Does the Act apply if we sell to a government or municipal body (B2G), rather than a business or a consumer?

Not directly through this Act. Public sector websites and apps fall under a separate law, Directive (EU) 2016/2102, not the European Accessibility Act. But if you are a private company delivering a website, app or other digital product to a public body under contract, that body's own obligation under the 2016/2102 directive means your product has to be accessible too, in practice.

Sources

Check which parts of your site actually sell to consumers.

If you are not sure whether an individual can buy or sign a contract as a consumer through any part of your site, a Digital Accessibility Review goes through the whole path. It shows exactly which section carries an obligation and why.

Ask about a Digital Accessibility Review

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