Are microenterprises exempt from the European Accessibility Act?

Sometimes, but only in a narrow case. The European Accessibility Act, Directive (EU) 2019/882, exempts microenterprises that provide services from the service-accessibility obligations. To qualify as a microenterprise, a business must meet both of these conditions:

• It employs fewer than 10 people; and
• Its annual turnover or annual balance-sheet total does not exceed EUR 2 million.

Both conditions must be satisfied. A business with 8 staff but EUR 5 million in turnover is not a microenterprise for this purpose, and neither is a business under the turnover ceiling that employs 15 people. Because an e-commerce store is a service, a genuinely micro operator providing e-commerce services can fall within this exemption.

The limits of the exemption

The exemption is real but should be treated cautiously, for several reasons.

• It is for services. The relief is aimed at microenterprises providing services. Businesses that manufacture, import or distribute the products covered by the EAA face different treatment, so a micro service exemption should not be read as a blanket products exemption.
• You can grow out of it. The moment you cross either the staff or the financial ceiling, the exemption stops applying, and accessibility work is far cheaper to build in early than to retrofit later.
• National implementation matters. The EAA is a directive transposed by each Member State, and the exact scope and any additional expectations can vary, so check the rules in the countries you sell to.
• Accessibility is still good practice. Even where you qualify, an accessible store reaches more customers and reduces legal and reputational risk.

In short, the microenterprise exemption exists for the smallest service providers meeting both the staff and financial tests, but it is narrow, easy to grow out of, and not a reason to ignore accessible design.

This answer is a general explanation, not legal advice. Thresholds and national implementation can change, so confirm the current position for the countries you sell to before you rely on the exemption.