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Who has to make their website accessible?

The most common question first — answered honestly. Not every website has to be accessible. Three questions are enough for a first assessment.

How many people do you employ?

Count everyone employed by the company, not only the people working on the shop.

What is your annual turnover?

The annual balance sheet total counts as an alternative. If either figure exceeds €2m, the exemption does not apply.

Who is your offering aimed at?

What matters is whether consumers can buy or book from you. A shop anyone can register with is not a purely business-to-business offering.

This assessment is a first orientation based on the two most important exemptions and does not replace legal advice. When in doubt, a lawyer specialising in IT law can clarify your individual case.

The micro-enterprise exemption — what exactly applies?

The European Accessibility Act exempts micro-enterprises from the requirements for services. A micro-enterprise employs fewer than 10 people and has an annual turnover or balance sheet total of no more than €2m. Both conditions must be met together: 8 employees on €4m turnover is not enough.

This is not the same as any national small-business scheme for VAT purposes. Confusing the two is the most common misunderstanding on this topic.

The distinction between service and product also matters. The exemption only covers services. For products — devices with screens, e-book readers, self-service terminals — there is no micro-enterprise exemption.

What counts as “purely B2B” — and when does that break down?

The obligation attaches to services for consumers. A portal that serves only trade customers and actually verifies access is not covered.

In practice this breaks down quickly: open registration without proof, spare parts sold to private individuals, an order form open to everyone. If you rely on being B2B, you should be able to evidence that consumers are excluded.

Separately: public sector bodies are subject to their own accessibility rules. Anyone working for or supplying them frequently gets accessibility back through the procurement documents — independently of the Accessibility Act.

Who should act despite being exempt

Anyone growing. The exemption hangs on numbers that change. Cross 10 employees or €2m during the year and you are obliged, with no transition period.

Anyone selling or raising money. In due diligence, an untested consumer shop is an open item.

Anyone who wants reach. A substantial share of the population depends on accessible operation, and many more benefit from it: larger controls, clear contrast and clean forms reduce drop-off for everyone.

Anyone who needs trust. A verifiable test mark works especially well for small providers who otherwise have little to show.

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