I don't sell products but services — does the law apply to me?

Services are covered by the law too

Yes, the law applies even when services rather than products are sold. The European Accessibility Act is explicitly not limited to online shops with a product catalogue: it targets consumers who can conclude a contract online, and this applies equally to a booking system, a subscription service, a consultation process concluded online, or a platform where someone reserves or pays for a service. The distinction many entrepreneurs make in their minds — "the law is for online shops, I don't sell goods" — does not exist in the directive.

What matters is not what is sold, but how: as soon as a consumer can conclude a contract, make a payment, book, or log in to an account via the website or app, the site counts as electronic commerce within the meaning of the directive. This therefore also affects service providers without a physical inventory: coaches with a booking module, SaaS companies with a sign-up flow, rental platforms, subscription services. What does differ, however, is the scope: a B2B website is assessed differently from a service offered directly to consumers, and in that case too, who the customer is matters more than what is delivered.

Where this is stated in the directive

The scope of the EAA is defined via the service, not the product: Directive (EU) 2019/882 names electronic commerce as a separate category to which the directive applies, without distinguishing between physical goods and services. Anyone wishing to establish whether a service falls precisely within that definition will find a more detailed explanation in the guidance on what the EAA precisely means and from when it applies. For small service providers, there is also an exemption for micro-enterprises: if you have fewer than ten employees and do not generate more than two million euros in turnover, you fall outside the obligation, which is elaborated further on the page on the exemption for micro-enterprises. Compliance oversight in the Netherlands lies with the ACM, which has already called on businesses to prepare for this.