Does the EAA's micro-enterprise exemption apply to your website?

If you've seen "small businesses are exempt from the EAA" repeated online, it's true, but the actual rule is narrower and stricter than that sentence suggests. Here's exactly what the exemption covers, based on the directive's own micro-enterprise definition.

The exact thresholds

To qualify as a micro-enterprise under the EAA, a business must meet both of these conditions at once:

• Fewer than 10 employees (full-time equivalent — part-time and contract workers count proportionally, not as a full head each)
• Annual turnover not exceeding €2 million, or an annual balance sheet total not exceeding €2 million

Both conditions have to be true together. A 6-person business with €5 million in annual revenue doesn't qualify. A 40-person business with €1.5 million in turnover doesn't qualify either. It's an "and," not an "or."

What the exemption actually covers

This is the part that trips people up: the exemption applies to services, not to products placed on the market. If your business sells physical products online, the products themselves (and, depending on the product category, elements of how they're sold) may still fall under EAA requirements even if you personally qualify as a micro-enterprise for the services side of your business. The exemption is narrower than "my business is small, so none of this applies to me."

No grace period for growth

This is the detail that catches growing businesses off guard: the exemption isn't a one-time qualification you keep once you've earned it. The moment you cross either threshold — your 10th employee, or the day your trailing annual turnover passes €2 million — the exemption stops applying, in full, from that point forward. There's no transition window to get your website compliant after the fact. If you're a 9-person business approaching €2 million in revenue, it's worth treating EAA compliance as something to have ready before you cross the line, not after.

If you're not sure whether you qualify

A few common situations worth flagging:

• You're a micro-enterprise today but plan to hire or grow revenue this year. Worth preparing now rather than scrambling once you cross a threshold.
• You're part of a group of companies. "Employees" and "turnover" for the exemption calculation may need to be assessed at the group level depending on your corporate structure, not just the single legal entity that owns the website — this is a case where getting proper legal advice for your specific structure matters more than a general explainer can.
• You sell products, not just services. Re-read the paragraph above — the exemption's service-only scope may mean less coverage than you'd assumed.

If you're not exempt

The EAA's technical requirement is WCAG 2.1 AA, the same standard regardless of company size — there's no reduced technical bar for a smaller business that doesn't qualify for the micro-enterprise exemption. The compliance work itself doesn't get easier because you're small; it just becomes about knowing where you actually stand. Run a free check to see whether your site already has an accessibility statement, or see pricing for a full audit.