European Accessibility Act (EAA) Exemptions Explained

Not every organisation or service is covered by the European Accessibility Act (EAA). While the EAA sets out broad accessibility requirements for products and services across the EU, it also outlines specific exemptions – some permanent, some limited in scope.

This section breaks down who and what is fully exempt from the EAA, so you can quickly see whether the rules apply to you. If they do, don’t worry. We’ll also walk you through what steps to take to get on the path to compliance.

Who and What Qualifies for European Accessibility Act (EAA) Exemptions?

• Microenterprises providing services
• Non-consumer (B2B) services
• Archived web/app content
• Pre-2025 digital content
• Third-party content not under the provider’s control
• Compliance that causes a disproportionate burden or fundamental alteration

Let’s take a closer look at each of these exemptions.

1. Microenterprises

In EU law, a “microenterprise” means a business with fewer than 10 employees and ≤€2 million annual turnover (or balance sheet).

The EU legislature recognised that imposing EAA duties on microenterprises would be a disproportionate burden relative to their limited resources. Even the task of assessing compliance costs could unduly strain micro firms.

Therefore, the Directive exempts microenterprises from its service-related requirements. Recital 70 of Directive (EU) 2019/882 explicitly states:

Note that this exemption applies only to services. Microenterprises that manufacture or sell products covered by the EAA must still ensure those products meet accessibility requirements. They may, however, benefit from simplified administrative duties (Recital 71).

2. Non-consumer (B2B) services

The Act’s scope is limited to services “provided to consumers.” This means purely business-to-business services, internal corporate services, or other services not offered to the general public do not fall under the EAA.

Only consumer-facing services (like retail banking for consumers, e-commerce, telecom for end-users, etc.) must comply. Thus, a software platform or website used exclusively within businesses is exempt under the EAA’s scope definition.

3. Archived web/app content

Archived websites or apps – those with content that has not been updated or edited after 28 June 2025 – are exempt from accessibility requirements.

In other words, if an app or site is frozen in time as of the compliance date (no new posts or modifications thereafter), it need not be made accessible.

This exception allows organisations to leave old content collections online without costly overhauls, as long as they are clearly archived. Any active, maintained content (updated after mid-2025) does not fall under this exemption.

4. Pre-2025 digital content

The European Accessibility Act (EAA) exempts specific categories of web/mobile content from needing to meet accessibility requirements. These are permanent exclusions aiming to avoid retroactive or unreasonable burdens.

According to Article 2(4) of the Directive, the following content on websites and mobile applications is not subject to the EAA:

• Pre-existing media: Pre-recorded time-based media published before 28 June 2025 – for example, audio or video content published on a site before the EAA compliance date is grandfathered (no need to retrofit old videos with captions, etc.)
• Office files: Documents, PDFs, presentations, and similar files published before 28 June 2025 – for example, a downloadable brochure uploaded before the EAA compliance date is grandfathered (no need to retrofit it for accessibility unless updated).
• Online maps: Online maps and mapping services published before 28 June 2025 are exempt, provided essential navigational information (such as addresses or directions) is made available in an accessible format elsewhere.

5. Third-party content not under the provider’s control

Any content on a site/app that is neither funded nor developed by, nor under the control of, the service provider is exempt.

For instance, if a website displays a user-generated video or an embedded third-party widget that the site owner did not create or commission, the owner is not held liable for that component’s accessibility. 

This prevents unfairly burdening companies for external content (e.g. social media feeds, externally sourced ads, or user posts) that they do not fully manage.

6. Compliance that causes a disproportionate burden or fundamental alteration

The EAA allows exemptions in cases where accessibility requirements would impose a disproportionate burden on the economic operator or result in a fundamental alteration of the product or service.

This means that if making your product or service accessible would lead to excessive cost, complexity, or technical difficulty, you may be exempt. But only if you can prove it. Similarly, if compliance would change the core nature or functionality of what you offer, it may qualify for an exemption.

According to Article 14(1) of the European Accessibility Act (Directive (EU) 2019/882):

However, this is not a blanket exemption. The same article also requires businesses to perform an assessment and document the reasons clearly. Authorities can request this documentation, and unjustified claims may still lead to enforcement.

Not Exempt? Here’s What to Do

If your organisation doesn’t fall under one of the exemptions, the EAA applies to both your products and services.

That means you’ll need to ensure that everything from your consumer-facing websites, mobile apps, and e-commerce platforms to hardware products like e-readers or payment terminals meets the EAA’s accessibility standards by 28 June 2025.

To ensure compliance, you’ll need to review your digital services and products. For services, assess your websites, apps, and digital platforms to ensure they’re accessible to all users. For products, check that interfaces, instructions, and user documentation meet the EAA’s accessibility standards.

If you fail to do so, your organisation may face fines or other enforcement actions from national authorities. We’ve covered this in detail in our article “What Happens If You Are Not EAA Compliant.” Give it a read to understand how the EAA enforcement works.

How We Can Help You

We can help you make your website EAA compliant, without all the stress and technical overwhelm. Our tool scans your website, highlights the accessibility issues, and gives you clear guidance to fix them.

Here’s how we support your journey:

• Quick audits: Just enter your website URL to scan for straightforward WCAG 2.1 issues – no setup or technical skills required.
• AI-powered fixes: Get AI solutions you can review and paste directly into your code to fix accessibility issues.
• Ongoing checks: Run regular scans to spot new issues and maintain accessibility over time

Run a free website audit to check if your website is EAA compliant and take the first step toward compliance. And if you’re running late, don’t worry. Our last-minute EAA website compliance plan can help you catch up and avoid legal trouble.