Does the European Accessibility Act apply to my shop? The small-business test, step by step

Published 28 October 2026

If your online shop sells to consumers in the EU, the European Accessibility Act applies to it, unless your business counts as a "microenterprise". That means two things together: fewer than 10 people, and no more than €2 million in annual turnover or in balance sheet total. Only one of the two money figures has to be within the limit, and in Belgium the exemption ends on 28 June 2030.

The rest of this article walks through the test one step at a time, with invented examples, and says what to do on either side of the line.

Who does the European Accessibility Act apply to?

The law covers a list of services provided to consumers after 28 June 2025. One of them is "e-commerce services". This is the law's definition:

"services provided at a distance, through websites and mobile device-based services by electronic means and at the individual request of a consumer with a view to concluding a consumer contract"

In plain words: a website or app where a consumer can buy from you. A Shopify store that sells to the public fits that description.

The definition is about consumer contracts. If you sell only to other businesses, ask an adviser whether your shop is covered before you rely on that.

The law is an EU directive, so each country wrote it into its own national law. The national laws we read carry over the small-business exemption, sometimes with different wording. More on that below.

The small-business test in two questions

The law calls a small business that meets this test a "microenterprise". The definition has two parts, and you need both.

Question 1: Do you employ fewer than 10 persons?

"Fewer than 10" means 9 or fewer. A business with exactly 10 people does not meet this part.

The EU text says "persons". The Dutch law says "employees". Counting can get less obvious with part-time staff, or if your company belongs to a larger group. If either applies to you and you are close to 10, check how to count with your accountant or a lawyer.

Question 2: Is your annual turnover or your balance sheet total €2 million or less?

This is the part people most often get wrong. The law says turnover "or" balance sheet total. You only need one of the two to be at or below €2 million.

So a shop with €3 million turnover can still meet this part, if its balance sheet total is €2 million or less.

Putting the two together

You are exempt only if the answer to both questions is yes:

Fewer than 10 persons, and
Turnover of €2 million or less, or balance sheet total of €2 million or less.

Worked examples

These shops are invented to show how the test works.

Shop	People	Turnover	Balance sheet total	Exempt?	Why
A	6	€3.0 million	€1.5 million	Yes	Fewer than 10 people, and the balance sheet is within the limit
B	6	€3.0 million	€2.5 million	No	Both money figures are above €2 million
C	12	€0.8 million	€0.3 million	No	12 people is not fewer than 10
D	10	€1.0 million	€0.5 million	No	Exactly 10 people is not fewer than 10
E	9	€2.0 million	€0.4 million	Yes	€2 million exactly is within "not exceeding €2 million"

Shop C surprises people most. A shop with modest sales but a larger team is covered, because the people test comes first.

The exemption is for services

The exemption covers businesses that provide services. Your online shop is a service in the law's terms, even when what you sell is physical goods. That is why the small-business exemption can apply to a Shopify store.

The law also regulates a short list of products in their own right, and it has no small-business exemption for those. If your business makes or imports the kinds of products the law lists, that side needs its own check.

Country differences

The test above comes from the EU law. These national laws, which we read in their official text, carry it over:

Germany: Germany's accessibility law has the same exemption: fewer than ten people, and either turnover or balance sheet total of at most €2 million.
Austria: Austria's accessibility law uses the same test and exempts small businesses that provide services.
Netherlands: The Dutch Civil Code exempts businesses with fewer than 10 employees and annual turnover or balance sheet total of at most €2 million.
Belgium: The exemption is temporary. Belgium's law keeps businesses with fewer than ten employees and turnover or balance sheet total of at most €2 million outside its scope only until 28 June 2030. A small Belgian shop should plan for the requirements to apply after that date.

If you sell from another EU country, check that country's national law or its regulator's guidance, and read the wording yourself rather than relying on a summary.

Just over the line? The "disproportionate burden" route

Some businesses are just above the limits and worry about cost. The law has a separate rule for this, but it is not a general opt-out.

The requirements apply only as far as meeting them would not fundamentally change the service, or place a disproportionate burden on the business. To rely on that, the business must:

Assess it. Work out whether, and why, meeting the requirements would be a disproportionate burden.
Write it down and keep it. The assessment must be documented and kept for five years.
Tell the authority. A business that is not a microenterprise must inform the authority that it relies on this rule.
Renew it. Service providers must renew the assessment at least every five years.

There is one more condition. A business that received outside funding, public or private, to improve accessibility cannot rely on the burden rule.

This is paperwork that an authority can ask to see. If you are thinking about it, speak to a lawyer first.

If the law applies to you: what to do

Being covered means two things for an online shop.

The shop has to meet the accessibility requirements. In practice, most accessibility work is measured against the Web Content Accessibility Guidelines (WCAG), the international technical guide for accessible websites.

You publish information about it. The law asks you to explain how your service meets the accessibility requirements. It puts that information in your general terms and conditions, or an equivalent document. It must be available in written and oral format, be accessible itself, and be kept for as long as the shop runs.

A calm first week looks like this:

Write down your two numbers and your headcount, and keep a note of the test result with the date.
Try to buy something from your own shop using only the keyboard. Our Shopify accessibility checklist has twelve checks like this one.
Read what Shopify covers and what is yours, so you know which parts of your store you can change.
Start a simple dated list of what you checked and what you changed.

If you are exempt

The exemption removes the legal duty. It does not remove the customers who need an accessible shop: people using screen readers, keyboard-only shoppers, people who zoom the page or need stronger contrast.

Two practical points:

Check the test once a year. Hiring your tenth person, or both money figures going above €2 million, changes the answer.
Keep your note. If anyone asks, a dated record of how you applied the test is easier than reconstructing it later.

This is general information, not legal advice.

Sources

Barrierlist: storefront accessibility checks for Shopify