EAA 2026 SME Exemption: Does Your Business Need to Comply?
EAA enforcement started 28 June 2026. Many small and medium-sized business owners assume they are automatically exempt — but the reality is more nuanced. This guide explains exactly who is covered, who is exempt, and what you need to do if you fall into scope.
The EAA Microenterprise Exemption — Exact Thresholds
The European Accessibility Act (Directive 2019/882) includes an exemption for microenterprises in the private sector. To qualify, your business must meet both of the following criteria simultaneously:
| Criterion | Threshold |
|---|---|
| Employees | Fewer than 10 (full-time equivalent) |
| Annual turnover or balance sheet total | ≤ €2 million |
This is a dual threshold: you must be under both limits. If you have 8 employees but €3 million in turnover, you are not exempt. If you have 15 employees but €1.5 million in turnover, you are not exempt.
Who Is NOT Exempt
Most businesses that think they might be exempt are actually in scope:
Medium and large businesses (≥10 employees): Fully in scope regardless of turnover.
Online retailers: Most e-commerce businesses serving EU customers with more than 10 employees or more than €2M revenue must make their product manuals, T&Cs, catalogues, and warranty documents accessible.
Professional service firms: Law firms, accounting practices, financial advisors — if you distribute client-facing PDFs and exceed either threshold, you are in scope.
Academic institutions: Universities and schools are public sector entities. They fall under Directive 2016/2102 (Web Accessibility Directive), not the EAA microenterprise exemption.
Charities and NGOs over the thresholds: Being a nonprofit does not exempt you. If you employ 10 or more people or have €2M+ in budget and distribute documents to the public, the EAA applies.
What Services and Products Are Covered
The EAA applies to a defined list of services and products. Document accessibility requirements are triggered when you:
- Operate an e-commerce website selling to EU consumers
- Provide consumer banking or financial services
- Operate a transport service (rail, aviation, bus)
- Provide telecommunications services
- Distribute e-books or audiobooks
- Operate media services (streaming, broadcast)
For each of these, the documents associated with the service — terms and conditions, user manuals, invoices, statements, policy documents — must also be accessible.
What If I Am Exempt?
If you genuinely qualify as a microenterprise (fewer than 10 employees AND ≤€2M revenue), you are not legally required to comply with the EAA for services. However:
- Consider voluntary compliance. Accessible documents reach more customers — including the 87 million people in the EU with some form of disability.
- Check national laws. Some EU member states have stricter accessibility requirements that apply to smaller businesses than the EAA floor.
- Plan ahead. If your business grows past either threshold, EAA compliance becomes mandatory immediately — not at your next annual review.
The Disproportionate Burden Clause
The EAA also allows businesses in scope to claim a disproportionate burden exception where full compliance would cause an unreasonable financial or organisational burden. However:
- This is a documented exception, not an opt-out. You must prepare a formal assessment.
- Authorities can challenge the assessment.
- The burden exception does not apply to services specifically designed for disabled people.
- It applies per service or product, not blanket across the organisation.
Most document accessibility improvements do not qualify as a disproportionate burden, especially with automated tools available.
The Fastest Compliance Path for In-Scope Businesses
If your business is in scope, the priority is making your distributed documents accessible. For PDF documents:
The problem: Standard PDFs almost universally fail WCAG 1.4.10 (Reflow) — the criterion that requires content to reflow at 400% zoom without horizontal scrolling. This failure cannot be fixed within PDF without expensive manual remediation.
The fastest solution: Convert PDFs to accessible EPUB3. EPUB3 is inherently reflowable, meets WCAG 2.2 Level AA requirements, and can be validated with free tools (ACE by DAISY, EPUBCheck) to produce documented compliance evidence.
toolkit.bot/pdf2epub converts PDFs to accessibility-focused EPUB3 in seconds — free for your first conversion.
Quick Reference
| Business size | In EAA scope? |
|---|---|
| Fewer than 10 employees AND ≤€2M revenue | Exempt (microenterprise) |
| Fewer than 10 employees BUT more than €2M revenue | In scope |
| 10 or more employees regardless of revenue | In scope |
| Public sector / universities | In scope (under separate directive) |
| Charities/NGOs with 10+ employees or 2M+ budget | In scope |
Key Dates
- 28 June 2025: EAA transposition deadline for member states
- 28 June 2026: EAA enforcement begins — new products and services must comply
- 28 June 2030: Grace period ends for pre-existing lawfully provided services
- New documents created after 28 June 2026: Must comply immediately (not covered by 2030 grace period)
Not sure if your documents meet EAA requirements? Check with a free conversion at toolkit.bot/pdf2epub — the output EPUB3 includes an ACE by DAISY accessibility report.