Is the European Accessibility Act one law for the whole EU?

No. It is a directive: the EU sets the requirements, but each member state passes its own national law to enforce them, with its own authority and its own penalties. The substance is harmonised, the enforcement is not.

Does the exemption threshold differ by country?

The microenterprise exemption (fewer than 10 employees, at most €2 million annual turnover, for service providers) comes from the directive itself and is consistent across the national laws we have checked. What differs by country is enforcement and penalty amounts.

Which country's law applies to my business?

Generally the law of the member state(s) where you offer your product or service to consumers. A business trading across several EU countries can fall under more than one national law at once - this is a case-by-case legal question, not something a general article can answer for you.

EAA

The European Accessibility Act: who is covered?

3 min readPublished: August 12, 2026

In short

The European Accessibility Act (Directive (EU) 2019/882) has, since 28 June 2025, required many digital B2C offerings across the EU - among them online shops, banking, passenger transport and e-books - to be accessible. Microenterprises providing services (fewer than 10 employees and at most €2 million annual turnover) are generally exempt. Each member state enforces the same substance through its own national law, with its own penalties.

What the European Accessibility Act is

The European Accessibility Act (EAA, Directive (EU) 2019/882) is the EU law behind the accessibility requirements now applying to much of the digital economy. Like any EU directive it does not apply directly - every member state transposes it into its own national law. Germany did so with the Barrierefreiheitsstärkungsgesetz (BFSG); Croatia with the Zakon o zahtjevima za pristupačnost proizvoda i usluga. The substance is the same across the EU: the technical benchmark is the harmonised standard EN 301 549, which for websites and apps in turn references the Web Content Accessibility Guidelines (WCAG 2.1/2.2 AA).

Which services are covered

The directive names specific services for consumers (B2C). Those most relevant to websites and apps:

Electronic commerce (e-commerce): online shops and other services through which consumers order goods or services - the broadest affected area.
Consumer banking services: online banking, consumer credit, payment services, brokerage.
Passenger transport: elements such as websites, apps, electronic tickets and real-time travel information for air, bus, rail and waterborne transport.
Telecommunications services: for example providers' websites and customer portals.
E-books and their reading software.

Which products are covered

Besides services, the directive also covers products - usually secondary for a website operator, but for completeness: consumer computers and operating systems, smartphones, routers, e-book readers, internet-enabled televisions, and self-service terminals such as ATMs, ticket and check-in machines and payment terminals.

The microenterprise exemption

A provider of services that qualifies as a microenterprise is generally exempt under the directive, and every national transposition we have checked carries the same threshold: fewer than 10 employees and at most €2 million annual turnover or annual balance-sheet total. Both conditions must be met. For companies that manufacture, import or distribute products, this blanket exemption does not apply in the same way.

B2B or B2C?

The directive targets offerings to consumers. Pure B2B offerings are in principle not covered - but in practice the line is often blurred, because many businesses sell to both business and end customers. As soon as consumers can order, electronic commerce is covered in case of doubt.

Since when it applies, and where enforcement differs

The EU-wide application date is 28 June 2025, the same date in every member state - that part does not vary. What does vary is enforcement: each country designates its own market-surveillance body and sets its own penalties. Germany's BFSG allows fines of up to €100,000. Croatia's law sets fines from €6,630 to €132,720 for legal entities and €2,650 to €6,630 for responsible individuals, depending on the offence. Both are real figures from the respective national laws, not directive-level numbers - the directive itself only requires penalties to be "effective, proportionate and dissuasive", and leaves the amount to each state.

What this means for your website in practice

If you run a covered B2C offering and are not an exempt microenterprise, your website must meet the requirements of EN 301 549 / WCAG 2.2 AA regardless of which member state's law applies to you. The first step is to know where you stand. How much a defensible audit costs and what drives the price is covered in “What does an accessibility audit cost?”. If Germany is your relevant jurisdiction, the specifics are in “BFSG: Who is affected?”.

Frequently asked questions

Is the European Accessibility Act one law for the whole EU?: No. It is a directive: the EU sets the requirements, but each member state passes its own national law to enforce them, with its own authority and its own penalties. The substance is harmonised, the enforcement is not.
Does the exemption threshold differ by country?: The microenterprise exemption (fewer than 10 employees, at most €2 million annual turnover, for service providers) comes from the directive itself and is consistent across the national laws we have checked. What differs by country is enforcement and penalty amounts.
Which country's law applies to my business?: Generally the law of the member state(s) where you offer your product or service to consumers. A business trading across several EU countries can fall under more than one national law at once - this is a case-by-case legal question, not something a general article can answer for you.

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