The EAA microenterprise exemption, in plain terms

The European Accessibility Act (Directive (EU) 2019/882) has applied since 28 June 2025 (Article 31(2)). It exempts the smallest businesses from part of it, not all of it.

Who counts as a microenterprise?

An enterprise that employs fewer than 10 persons and has an annual turnover not exceeding EUR 2 million, or an annual balance sheet total not exceeding EUR 2 million (Article 3(23)). The staff test must be met, and one of the two financial tests. A business with 12 staff is not a microenterprise, whatever its turnover.

What the exemption covers

A microenterprise that provides services is exempt from the Act’s accessibility requirements for those services, and from the obligations that go with them (Article 4(5)).

What it does not cover

• Products. There is no product exemption. A microenterprise dealing with products that relies on the disproportionate burden rule need not document its assessment, but must give a market surveillance authority the facts behind it if asked (Article 14(4)).
• Public sector bodies. Their websites, apps and the documents on them fall under a different law, the Web Accessibility Directive (Directive (EU) 2016/2102).
• National law. Each Member State brought the Act into its own law. Rely on the national text for your country.

Disproportionate burden is a different rule

Any business, of any size, may rely on the requirements applying only so far as they do not fundamentally alter its product or service or impose a disproportionate burden on it (Article 14(1)). The business must assess that itself, document the assessment and keep the results for five years (Article 14(2) and (3)); only a microenterprise dealing with products is spared the documenting. It is not the microenterprise exemption.