EAA microenterprise exemption for e-commerce

The EAA covers e-commerce services supplied to consumers. These are online services aimed at concluding a contract at a consumer’s individual request. They can involve any goods or services, not just computer equipment.

An exclusively business-to-business service does not meet this consumer-contract definition. An informational website is not automatically an e-commerce service. For mixed websites, examine the functions offered to consumers.

Do not assume a booking is outside scope because payment happens elsewhere. Describe the actual journey: selection, reservation, ordering and conclusion of the contract. Check the service definition before assessing the size thresholds.

The exemption applies to a service-providing enterprise employing fewer than ten persons. Its annual turnover or annual balance-sheet total must not exceed €2 million. Both the workforce condition and the financial condition must be satisfied.

Either financial indicator can satisfy the ceiling. Looking only at turnover can therefore give the wrong answer. Exactly ten persons fails the workforce condition; exactly €2 million satisfies the financial ceiling.

Here, microenterprise means an enterprise-size category under European law. A French micro-entrepreneur tax status does not replace this assessment. Outside the exemption means ten or more persons, or both financial indicators exceeding the ceiling.

These examples are illustrative, not determinations about real companies. They assume correctly calculated workforce and accounts. Any necessary group aggregation must already be included.

Nine persons, €3 million turnover and a €1.5 million balance-sheet total: the exemption thresholds are satisfied. The balance-sheet figure satisfies the financial condition despite turnover exceeding the ceiling.

Nine persons with both financial indicators exceeding €2 million: the exemption thresholds are not satisfied. Ten persons with low revenue: the thresholds are not satisfied either. Failing either required condition changes the result.

Identify the enterprise providing the service, not just the brand or individual store. Gather the latest approved accounts, workforce data and ownership links. Revenue from the online shop alone is not sufficient.

The European recommendation sets out annual-work-unit calculations. It also addresses partner and linked enterprises. A social-network employee estimate is not an equivalent calculation.

Ask your accountant to check the figures, enterprise perimeter and recent changes. Group ownership or borderline cases may require a separate legal assessment. Do not infer a grace period solely from crossing a threshold.

The exemption concerns service accessibility requirements and the related compliance obligations. It does not automatically remove obligations concerning regulated products. Manufacturer, importer and distributor roles need separate consideration.

Other accessibility laws may still apply. French Article L412-13 expressly preserves Articles 47 and 48 of the disability law of 11 February 2005. Exemption from this EAA service regime is not exemption from every accessibility obligation.

Requirements apply from 28 June 2025, subject to specific transitional provisions. An existing website does not automatically receive an extension until 2030. France’s DGCCRF distinguishes websites from older products used to provide a service.

A homepage scan cannot decide whether your enterprise is exempt. It examines technical elements, not your accounts or organisation. A high score cannot establish conformance for the whole purchasing journey either.

An automated scan detects only some accessibility problems and does not replace an audit. You can try the free scan and review the detailed-report offer to begin technical checks. Protected pages must never be considered conforming simply because they could not be tested.

To plan your evaluation budget, read our accessibility audit cost guide. Legal scope and the quality of your customer journey are distinct questions. Even an exempt shop can choose to reduce barriers for its customers.

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