# Who does the European Accessibility Act apply to?

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Start with the product or service and the person using it. Having a website does not decide whether the European Accessibility Act covers you. Check the category, your business’s role and the exemptions before commissioning a technical review. It shows technical gaps, not legal compliance.

## Which products and services are covered?

Directive (EU) 2019/882 contains a defined list. Products include consumer computers and operating systems, specified self-service terminals, consumer equipment for electronic communications and access to audiovisual services, and e-readers. Each category has definitions and limits; not every “digital product” falls within it automatically.

Services include electronic communications, access to audiovisual media, specified elements of passenger transport, consumer banking, e-books with dedicated software, and e-commerce. For services, provision to consumers matters. The main application date is 28 June 2025; relevant transition provisions and exclusions need a separate check.

A consumer here is not every business customer. Establish whether the individual acts outside their trade or profession. The distinction matters when a website serves both businesses and consumers.

## What is the microenterprise exemption?

The definition is an enterprise with fewer than 10 people and annual turnover not exceeding EUR 2 million or an annual balance sheet total not exceeding EUR 2 million. The financial boundary is inclusive and the financial tests are alternatives. Do not replace it with “under” or require both figures to fall below it.

Microenterprises providing services are exempt from the directive’s accessibility requirements and related obligations. This is not an exemption from all laws. Products do not receive the same full exemption: relief from documenting an assessment of fundamental alteration or disproportionate burden, for example, does not remove all product duties.

Do not determine status from today’s headcount in the office alone. Gather the enterprise information needed and check the applicable rules for the case. If you have mixed activities, consider services and products separately.

## B2B or B2C: what should you check?

Examine the actual service, not just your description of the company. A purely business-to-business service generally falls outside the consumer scope of this list. If the same website also allows consumer contracts, a “B2B” label alone does not settle the question.

Prepare the following for the scope check:

- What you offer and which category might cover it.
- Who enters the contract and in what capacity.
- How the purchase works through the website or application.
- Which markets you serve and which exemption, if any, you rely on.

## Where is the company registered?

Registration outside the EU is not sufficient reason to leave the Act out of the check. Consider provision of covered products and services in the EU market, your role and applicable national law. Whether a particular cross-border transaction falls within a jurisdiction requires case-specific assessment.

The originally published Bulgarian law divides service supervision by service type. It identifies the Commission for Consumer Protection for e-commerce. Do not assume a single authority handles everything; check the current law and the right authority for your activity.

## Questions

### Is a microenterprise making a listed product exempt?

Not in the same way as a service provider. Examine product duties and the particular relief separately. Exemption from documenting a specified assessment does not mean exemption from every requirement for the product.

### Does the Act also concern mobile apps?

The service matters, not just the interface. The e-commerce definition includes services through websites and mobile devices; covered transport services also include mobile apps. This does not mean every application is covered.

### Does a technical review prove legal compliance?

Not by itself. It records technical findings within the agreed scope. Applicable legal duties, exemptions and necessary conformity information need separate determination; a repair list is not a legal certificate.

## Sources

- [Directive (EU) 2019/882: scope and definitions](https://eur-lex.europa.eu/eli/dir/2019/882/oj/eng)
- [Irish authority CCPC: microenterprise guidance](https://www.ccpc.ie/enforcement-and-regulation/market-surveillance/accessibility/accessibility-for-businesses/european-accessibility-act-guidelines-for-microenterprises)
- [Bulgarian State Gazette: originally published national law](https://dv.parliament.bg/DVWeb/showMaterialDV.jsp?idMat=233836)

## Related reading

- [Do you need an accessibility statement?](https://ergostrat.com/en/website-build/accessibility-statement.html)
- [What are the penalties for breaching the European Accessibility Act?](https://ergostrat.com/en/digital-accessibility-review/eaa-fines.html)

## Scope first, then the website.

Check the scope before testing the website. If you are covered and do not use the service microenterprise exemption, a Digital Accessibility Review shows where your website falls short of WCAG 2.2 level AA. That technical check does not itself establish legal conformity.

[Request a Digital Accessibility Review](mailto:contact@ergostrat.com?subject=Question%20after%20the%20article%20Who%20the%20EAA%20applies%20to)
