Does the accessibility law apply to my webshop?

Yes, in most cases your webshop is subject to the law

If you sell products or services online to consumers in the European Union, your webshop is in most cases subject to the European Accessibility Act. The directive explicitly names electronic commerce as a service within its scope, and this applies to every webshop that has been active since 28 June 2025, regardless of which Member State the undertaking is established in. The rules have been transposed into national legislation in each Member State — in the Netherlands the Implementation Act on accessibility requirements for products and services, in Germany the Barrierefreiheitsstärkungsgesetz, in France the transposition in the Consumer Code and in Belgium that in the Economic Code — but the core of the scope is the same in each of these countries.

An important exception: micro-enterprises that provide services are exempted, provided they have fewer than ten employees and a maximum annual turnover of two million euros. Both conditions apply at the same time. A webshop that stays below both thresholds falls outside the law; if one additional employee or one euro in turnover comes on top, the exemption ceases to apply. This exception is stated literally in the directive and can also be found in the national laws that have been reviewed, such as the German BFSG, which explicitly limits the micro-exemption to services.

Where the scope is set out in the directive

The scope of the EAA and the exemption for micro-enterprises follow directly from Directive (EU) 2019/882, which places electronic commerce as a service within the law and establishes the exemption for small service providers. The ACM points out in its publication on supervision of websites and apps that companies should prepare for this, which shows that the scope is broadly applied in practice. Whether a specific webshop falls precisely within the limits of the exemption depends on the number of employees and the turnover of the undertaking itself at the time this is assessed.