Are Dutch Microenterprises Exempt From the EAA?

Usually, yes — if they meet the size test. The European Accessibility Act, Directive (EU) 2019/882, has applied since 28 June 2025 and exempts service-providing microenterprises from its service obligations. A Dutch webshop that qualifies as a microenterprise is generally outside the EAA’s service duties, as transposed into Dutch law.

The microenterprise test

A microenterprise for these purposes is a business that employs fewer than 10 people and has an annual turnover or balance-sheet total of no more than €2 million. Both limbs must be satisfied. A shop that exceeds either the headcount or the financial threshold is not a microenterprise and cannot rely on the exemption.

• Fewer than 10 employees?
• Turnover or balance-sheet total of €2 million or less?
• Both true — exemption likely applies; either exceeded — obligations apply.

Why the exemption is not permanent

The exemption is tied to your size, not fixed for the life of the business. A growing Dutch webshop that passes 10 employees or €2 million loses the exemption and must meet the requirements — the standard being EN 301 549, which incorporates WCAG 2.1 level AA. Because retrofitting accessibility under time pressure is expensive, many small shops choose to build to the standard even while exempt.

Accessible design also broadens your market and improves usability for everyone, so the business case rarely rests on the exemption alone. For the detail, see our complete accessibility guide and the accessibility law page.

This answer is educational and does not constitute legal advice.