The European Accessibility Act: what actually applies to small businesses

The act exempts microenterprises that provide services: fewer than ten employees and annual turnover or balance sheet up to € 2 million. If you are a one-person business or small team with a webshop or service site, you most likely fall outside the direct obligation.

If you sell physical products that are themselves in scope — e-readers, payment terminals, communication equipment — the exemption does not apply. And if you grow past ten employees or € 2 million, the act applies after all.

Still, this is no reason to stop reading. Your clients may well be obliged — if you work for larger companies, accessibility is part of what they must require from you. And regardless of any law: a substantial share of your visitors has a disability that affects how they use websites. An inaccessible site turns customers away.

In short: businesses above the micro threshold that serve consumers in these categories — webshops and booking platforms, banking and consumer credit, e-books and e-readers, telecom services, interfaces for streaming and TV, passenger transport (tickets, travel information), and the 112 emergency chain.

B2B services and internal tools fall outside it. Public-sector sites fall under a separate, older regime.

The technical bar is WCAG level AA — the European standard EN 301 549 points to it. That sounds abstract; in practice it means readable contrast, full keyboard operability, text alternatives for images that carry information, form fields with labels and errors in text, and visible focus without content that only appears on hover.

Five minutes of self-testing beats ten proposals: navigate your site with only Tab and Enter and try to complete an order or request. If you can’t, you know enough.

The ACM supervises. Practice so far: companies that get contacted first receive a deadline to fix problems. Those who cooperate and show a plan usually walk away with a warning. The maximum fine exists, but it is the endpoint — not the starting point.

In other words: this is not a lottery where you suddenly lose € 900,000. It is a standard being enforced step by step, starting with the biggest players.

One: determine whether you are in scope — the categories above plus the micro exemption. Two: run the five-minute keyboard test on your most important flow. Three: get a real audit of your order or request flow — that is where things break, as the ACM research shows. Four: put WCAG 2.2 AA in your requirements towards your agency or developer. Five: publish an accessibility statement that honestly says what is and is not in order yet.

HearthCode Studio builds sites and apps with accessibility in from the first line — contrast-checked colours, keyboard navigation, screen-reader testing, automated checks in the pipeline. This site is the proof; the source code is public.

Questions about whether your site is in scope, or what concretely needs to happen? One email is enough: info@hearthcodestudio.com.