Am I exempt from the accessibility law as a small business?

Exemption applies to microenterprises providing services

A small business providing services falls outside accessibility requirements when it has fewer than ten employees and no more than two million euros in annual turnover — both conditions apply together, not as alternatives. This exemption is set out in the European Directive (EU) 2019/882 itself and therefore does not vary by country: wherever the directive has been transposed, the exemption reappears. In the German transposition, the Barrierefreiheitsstärkungsgesetz, the same threshold is stated word for word, confirming that it is not a national addition but follows the European standard.

What the exemption does not do is automatically exclude every small business. It applies to services, and a webshop is in practice primarily that: a service that sells products. Anyone exceeding either of the two thresholds — more employees, or higher turnover, even if the other threshold has not been reached — falls back within scope. Whether a business qualifies for the exemption is a matter of fact regarding employee numbers and turnover, not an estimate; the free scope check based on those same two criteria provides an initial answer to this question, without requiring an account or payment.

Where the threshold comes from

The threshold of fewer than ten employees and no more than two million euros in annual turnover is set out in Directive (EU) 2019/882 as an exception for microenterprises providing services, and has been incorporated in the same way in German legislation (the BFSG). The transposition in other member states has not been checked article by article, but because the exemption comes directly from the directive, it is reasonable to expect it to reappear in comparable form in the national laws that transpose the directive.