EAA Exemptions for UK Businesses — Micro-Enterprises and More 2026
„Can my UK business be exempt from the EAA?" That's a question many UK business owners ask when they learn about the European Accessibility Act.
In this guide, we'll explain who is exempt from the EAA, what the micro-enterprise exemption means, and how to claim an exemption.
📌 Quick Answer — EAA Exemptions
The EAA has several exemptions: 1) Micro-enterprises (fewer than 10 employees and less than €2 million turnover), 2) Disproportionate burden (if compliance costs too much), and 3) Specific products/services (military, some medical devices). Micro-enterprises are fully exempt from the EAA.
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Free UK Checker →Overview — EAA Exemptions
The EAA has three main exemptions for businesses:
| Exemption Type | Who It Applies To | Key Condition |
|---|---|---|
| Micro-enterprise | Very small businesses | <10 employees, <€2M turnover |
| Disproportionate burden | Businesses where compliance is too costly | Cost > benefit |
| Specific products/services | Products/services not covered | Military, some medical devices |
1. Micro-enterprise exemption
The micro-enterprise exemption is the most significant exemption for UK businesses. It exempts very small businesses from the EAA entirely.
What is a micro-enterprise?
A micro-enterprise is defined as a business with:
- Fewer than 10 employees
- Annual turnover of less than €2 million
- OR balance sheet total of less than €2 million
📊 Micro-enterprise exemption — Key Facts
- Condition 1: Fewer than 10 employees
- Condition 2: Annual turnover < €2 million
- OR Balance sheet total < €2 million
- Exemption: Fully exempt from the EAA
- UK impact: Many small UK businesses are exempt
Examples of micro-enterprises in the UK:
- A small e-commerce business — 5 employees, £1.5 million turnover
- A local retail store — 3 employees, £800,000 turnover
- A sole trader — 1 employee, £500,000 turnover
- A small consultancy — 6 employees, £1.2 million turnover
- A small restaurant — 8 employees, £1.8 million turnover
⚠️ Important — Exemption is not automatic
Even if you are a micro-enterprise, you must demonstrate that you qualify for the exemption. Keep records of your employee numbers and turnover to prove your status.
Important: This exemption only applies to the EAA. You must still comply with the Equality Act 2010.
2. Disproportionate burden exemption
If complying with the EAA would be a disproportionate burden, you may be exempt. This applies to specific parts of your website or services, not the entire business.
What is a disproportionate burden?
A disproportionate burden is when the cost of compliance is significantly higher than the benefit to disabled users.
Factors to consider:
- Financial cost — How much would it cost to comply?
- Organisational resources — Can you afford the cost?
- Benefit to users — How many disabled users would benefit?
- Alternative access — Is there another way to access the information?
- Size of organisation — What is reasonable for your business?
What is NOT a disproportionate burden?
You cannot claim a disproportionate burden for:
- Basic accessibility features — alt text, colour contrast, keyboard accessibility
- Essential information — core services and information
- New content — new pages, documents, and features
- Core functionality — key features like forms and transactions
You must document your assessment
If you claim a disproportionate burden, you must document your assessment. This includes:
- What you assessed
- Why you concluded it was disproportionate
- What alternatives you considered
3. Specific products and services exemption
Some products and services are exempt from the EAA entirely:
Exempt products and services:
- Military products — weapons, military equipment
- Some medical devices — depending on type
- Some transport services — limited exemptions
- Products/services not covered by the EAA — check the directive for details
What if you are exempt from the EAA?
If your UK business is exempt from the EAA:
1. You do not need to comply with the EAA
You do not need to make your products/services accessible under the EAA.
2. You must still comply with the Equality Act 2010
The Equality Act 2010 applies to all UK businesses that provide services to the public. This is not affected by the EAA exemption.
3. You may still choose to comply
Even if you are exempt, making your website accessible is good for business. It opens your business to millions of disabled customers.
How to claim an exemption
Step 1: Determine if you qualify
Check if you meet the criteria for a micro-enterprise or disproportionate burden.
Step 2: Document your assessment
Document why you qualify for the exemption. Keep records of:
- Employee numbers
- Turnover
- Cost assessments (for disproportionate burden)
Step 3: Publish a statement
If you claim a disproportionate burden, publish a statement on your website explaining which parts are not accessible and why.
Step 4: Review regularly
Review your exemption status regularly (at least once a year). If your circumstances change, you may need to comply.
Frequently Asked Questions — EAA Exemptions
Businesses with fewer than 10 employees and less than €2 million turnover are fully exempt from the EAA.
A disproportionate burden is when the cost of compliance is significantly higher than the benefit to disabled users. You must document your assessment.
No. You must demonstrate that you qualify. Keep records of your employee numbers and turnover.
Yes. You must still comply with the Equality Act 2010, which applies to all UK businesses that provide services to the public.
No. A disproportionate burden exemption applies to specific parts of your website or services, not the entire business.
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