What Counts as a Microenterprise in the EU?
Accessibility (EAA)A microenterprise is the smallest category of business in EU law. The definition matters here because the European Accessibility Act uses it to decide which small service providers are exempt from its service requirements.
The two-part test
An enterprise counts as a microenterprise when it meets both of these conditions:
- It employs fewer than 10 people, and
- Its annual turnover or annual balance-sheet total is no more than €2 million.
Note the “and” between the two limbs. The headcount condition must always be met. Alongside it you satisfy the financial limb if either turnover or the balance-sheet total is at or below €2 million. If you have 10 or more staff, you are not a microenterprise regardless of your turnover.
Why it matters for the EAA
The European Accessibility Act, Directive (EU) 2019/882, has applied since 28 June 2025 and requires many e-commerce services to meet EN 301 549 and WCAG 2.1 AA. However, microenterprises providing services are exempt from the service requirements. So if your online shop passes the fewer-than-10-staff test and the €2 million test, the EAA’s service obligations do not bind you.
Exempt is not the same as inaccessible
Being exempt only means the law does not compel you. Many microenterprises still choose to follow accessibility good practice, including publishing an accessibility statement, because it widens their customer base and improves usability for everyone. The exemption is a floor, not a ceiling.
For more detail, see our who must comply with the EAA and the complete accessibility guide.
This article is educational and does not constitute legal advice.