Kept Record

Does the European Accessibility Act apply to you? Five questions, each with the article it rests on.

Answer each question by following its link. Every outcome is written out below, including the ones that say the Act does not apply, and each question cites the article of Directive (EU) 2019/882 that decides it. National law can add to the Directive; this follows the Directive.

Start with the first question.

Question 1 of 5

Do you offer products or services to consumers in the European Union, whether or not your business is based there?

makes offers to provide such a service to consumers in the Union Article 3(4), definition of service provider, 17 April 2019.

Question 2 of 5

Is what you offer on the Act's list? For services: an online shop that concludes contracts with consumers, consumer banking, electronic communications, access to audiovisual media, passenger transport information and ticketing, or e-books. For products: computers and operating systems, self-service terminals, phones and other terminal equipment, or e-readers.

the following services provided to consumers after 28 June 2025 Article 2(1) and 2(2), 17 April 2019.

Question 3 of 5

Does your business employ fewer than ten people, and have either an annual turnover or an annual balance sheet total of two million euros or less?

fewer than 10 persons and which has an annual turnover not exceeding EUR 2 million Article 3(23), definition of microenterprise, and Article 4(5), 17 April 2019.

Question 4 of 5

Does the service rely on products you lawfully used before 28 June 2025, or on service contracts agreed before that date?

a transitional period ending on 28 June 2030 during which service providers may continue Article 32(1), transitional measures, 17 April 2019.

Question 5 of 5

Would meeting a requirement change the basic nature of your service, or be a disproportionate burden by the criteria in Annex VI of the Act?

does not result in the imposition of a disproportionate burden on the economic operators concerned Article 14(1), fundamental alteration and disproportionate burden, 17 April 2019.

The Act's service requirements do not apply to you.

The Act covers services provided to consumers, and a consumer is a natural person acting outside their trade, business, craft or profession (Article 3(22)). A business that sells only to other businesses is not providing a service to consumers.

Two things still hold. If you place a listed product on the EU market, the product requirements apply regardless of who buys it. And other laws reach business-to-business websites: in Britain the Equality Act's duty on service providers has no consumer test.

The Act does not apply to you.

The Act reaches products placed on the Union market and services offered to consumers in the Union (Articles 2 and 3(4)). A business with no customers in the EU is outside it. The moment you offer to consumers in the EU, come back to the first question.

If you sell in the United States or the United Kingdom, the pages on the Americans with Disabilities Act and the Equality Act describe what applies there.

The Act does not apply to what you offer.

Only the products and services listed in Article 2 are covered. A service that is not on the list, a company's information website with no consumer contract concluded through it for instance, is outside the Act.

The list has an edge worth checking: a website through which a consumer can buy is an e-commerce service under Article 3(30), whatever else the business does. If yours takes orders from consumers, it is on the list.

The Act applies to your product, whatever your size.

A listed product placed on the EU market after 28 June 2025 must meet the requirements of Annex I Section I and II, carry the EU declaration of conformity and the CE marking (Articles 7, 16 to 18), and is subject to market surveillance (Article 19).

The microenterprise exemption in Article 4(5) is for services only. A microenterprise dealing with products is spared some paperwork under Article 14(4) and 14(8), and nothing else.

The Act's service requirements do not apply to you.

A microenterprise providing services is exempt from the accessibility requirements and from the obligations that go with them (Article 4(5)). A microenterprise employs fewer than ten people and has an annual turnover of two million euros or less, or an annual balance sheet total of two million euros or less (Article 3(23)).

The exemption is by size at a moment in time. A business that grows past either limit comes into the Act. Member states are asked to give microenterprises guidance and tools (Article 4(6)), and the Act's recitals encourage voluntary compliance. If you sell in Britain, the Equality Act still applies to you as a service provider, with no size test.

The Act applies to you. Some of what you use has a transitional period.

Your service is in scope. Products lawfully used to provide the service before 28 June 2025 may continue in use until 28 June 2030, and a service contract agreed before that date may run unaltered until it expires, for no more than five years (Article 32(1)). A self-service terminal in use before that date may be kept to the end of its economic life, up to twenty years, where the member state allows it (Article 32(2)).

A website is not a product lawfully in use before the date; it is the service itself. The transitional period covers the equipment and contracts behind the service, not the site a consumer uses. For the site, go on to the last question.

Go on to the last question

The Act applies to you, and a requirement may lift to the extent you can show why.

A requirement does not apply to the extent that meeting it would fundamentally alter the basic nature of the service, or would be a disproportionate burden judged against the criteria in Annex VI: the cost against the business's resources, the cost against the benefit to disabled people, and the size and nature of the business (Article 14(1) and 14(2)).

The judgement must be yours in writing. The assessment is documented and kept for five years, renewed when the service changes and at least every five years, and given to an authority on request (Article 14(3) and 14(5)). It cannot be claimed where the business took outside funding to improve accessibility (Article 14(6)). Every other requirement still applies in full.

The Act applies to you in full.

Your service must meet the requirements of Annex I, Sections III and IV (Article 4(3)). For a website that means being perceivable, operable, understandable and robust, and for an online shop also making sign-in, security and payment accessible and passing on accessibility information about the products sold.

You must explain how the service meets the requirements, in your general terms and conditions or an equivalent document, keep that explanation while the service runs, and give an authority all information necessary to demonstrate conformity on a reasoned request (Article 13(2), 13(5), Annex V). If the service does not conform you must correct it and tell the authorities of each member state where you provide it (Article 13(4)). Penalties are set by each member state (Article 30); the page on the Act gives three examples.

A worked example: this site's own operator.

Kept Record, which publishes this page, sells a scanning service to businesses, not to consumers, so the first question ends it: the Act's service requirements do not apply. The free scan on the homepage concludes no contract, so it is not an e-commerce service under Article 3(30) either. And had either answer gone the other way, the third question would have ended it: the service is run by one person, well under the microenterprise limits in Article 3(23).

So the Act does not apply to this site. It is held to WCAG 2.2 Level AA anyway, by choice, and its accessibility statement says where it stands against that. The Equality Act 2010 does apply to it, as it does to any service provider with users in Britain, and that duty has no size test.

A directive binds member states, who write it into national law. The national act can name a different authority, set a different penalty, or add duties. The sources here are the directive and three national acts; yours may differ.

This page describes the law as it is written in the sources cited. It is not legal advice, it does not cover every case, and national law can add to what a directive requires. It has not been reviewed by a lawyer.

This page describes what the system does, written by the people who built it. It has not yet been reviewed by a lawyer, and it will be before anything on this site can be bought.

Every source on this page was fetched and its quotation confirmed on 18 September 2026, today. That date is written by the script that checked, not by a person.