Is My Business Covered by the European Accessibility Act? (Free Checker)

The European Accessibility Act (EAA) has applied since 28 June 2025, and enforcement is now visible: market surveillance letters went out to e-commerce and e-book providers in late 2025, the first lawsuits were filed in France in November 2025, and fines already range from around €60,000 (Ireland) to roughly €900,000 (Sweden). Naturally, a lot of small business owners are asking the same question: does this actually apply to me?

Short answer: probably, if you sell to consumers online anywhere in the EU — but there's an important exemption most business owners haven't heard of. Answer the three questions below for an instant read.

Quick check (nothing here is uploaded or recorded — it's just three questions):

1. Do you sell products or services to consumers in the EU (including via a website), or provide public transport, banking, or telecoms services there? Yes No

2. Do you have fewer than 10 staff AND less than €2 million in annual turnover (or balance sheet total)? Yes No

3. Do you sell physical products only, with no online sales, digital services, or EU public-facing operations? Yes No

What the EAA actually covers

The EAA applies to specific categories of products and services sold to consumers in the EU, including:

E-commerce — this is the big one. Almost any business selling online to EU consumers counts as providing an "e-commerce service."
Consumer banking and financial services — statements, contracts, fee disclosures.
Passenger transport (air, rail, bus, waterborne) — booking systems, tickets, travel information.
Electronic communications (phone/internet service providers) and audiovisual media services.
E-books and dedicated e-readers.
Certain hardware: computers, smartphones, ATMs, ticketing and check-in machines.

If none of these describe your business, the EAA likely doesn't apply to you directly yet — though sector-specific or national rules may still.

The exemption most SMEs don't know about

Article 4(5) of the EAA exempts microenterprises — businesses with fewer than 10 staff and either annual turnover or an annual balance sheet total under €2 million — from the accessibility requirements, specifically for the services they provide. This is automatic; you don't need to apply for it or prove hardship. If you're a two-person shop selling a handful of products online, you may well be exempt. If you're a 30-person e-commerce business, you're not.

Two caveats worth knowing: the exemption covers services, not products (a microenterprise manufacturing a covered hardware product doesn't get the same automatic pass), and it doesn't mean "ignore accessibility entirely" — general disability discrimination law (in the UK, the Equality Act 2010) can still apply regardless of company size.

UK businesses: a common point of confusion

The EAA is EU law. A UK-only business selling only to UK consumers is not directly covered by it — your obligations instead come from the Equality Act 2010, which works differently (a "reasonable adjustments" duty, enforced through individual complaints rather than market surveillance). But if you sell to EU consumers — which, for an e-commerce business, is very easy to do without realising it — the EAA applies to that part of your business regardless of where your company is based.

Germany: the BFSG

Germany implemented the EAA through its own law, the Barrierefreiheitsstärkungsgesetz (BFSG). If you sell into the German market, this is the name your obligations will actually appear under in local guidance and enforcement — German buyers and officials generally say "BFSG," not "EAA."

What "covered" actually requires

Being in scope means your customer-facing digital content and documents — websites, apps, PDFs like invoices, contracts, and statements — need to meet WCAG 2.1 AA-equivalent accessibility requirements (via the harmonised standard EN 301 549). For PDFs specifically, that means PDF/UA (ISO 14289-1) conformance: proper tagging, alt text on images, a declared document language, and more.

Check a document now. If you're in scope, the fastest first step is finding out where your existing PDFs actually stand. Our free checker runs an instant scan in your browser — no upload — and can run a full PDF/UA audit with a downloadable report if you want the detail.

This guide is general information based on the EAA (Directive (EU) 2019/882) and public enforcement reporting as of July 2026. It isn't legal advice — for a decision your business will rely on, check with a solicitor familiar with your specific situation.

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