Here is the answer up front. If your company sells products or provides services to consumers in the EU, the European Accessibility Act (EAA) applies to you, wherever you are based. If you sell only to UK customers, or only outside the EU, it does not. Brexit changed neither half of that sentence, because the Act never turned on where a company is registered in the first place.
That single distinction catches UK founders out in both directions. Some assume EU law stopped mattering in 2020 and ignore an obligation they genuinely have. Others read alarming headlines and start compliance work they may not need. This post gives you the test that decides it, the exemptions worth checking, what UK law expects of you either way, and what the first year of the Act has actually produced.
The Short Answer, and the One Test That Decides It
The EAA is Directive (EU) 2019/882(opens in new tab), an EU law whose requirements have applied since 28 June 2025. It is not UK domestic law. The UK left the EU and did not adopt it, and no UK regulator enforces it. None of that is the test.
The test is where your customers are. The Act binds economic operators. That is the legal term for any business in the chain that supplies a product or service. It applies when they place products on, or provide services to, the EU market, wherever the operator is established. Being outside the EU does not put you outside the Act. Being outside the EU market does.
In practice, you are offering into the EU market if any of these describe you:
- Your app is live on EU App Store or Google Play storefronts, in France, Germany, Ireland or any other member state
- Your website has EU-language versions or shows prices in euros
- Your checkout accepts delivery addresses in EU countries
- You sell through an EU entity, distributor or reseller
A Leeds company with an app on the French App Store is in scope. The same company selling only to UK customers is not. The rest of this post assumes you want to know which one you are, with evidence, rather than a guess.
Why Brexit Did Not Get You Out of It
It can feel wrong that a law finalised in Brussels after the UK voted to leave still reaches a company in Manchester. The reasoning is less exotic than it sounds. The EAA regulates access to the EU's market, not the nationality of the seller. Any business that wants EU consumers' custom takes on the obligations that come with it. An overseas business selling into the UK takes on UK consumer law the same way.
That puts a UK software company with users in Dublin or Paris in the same position as a US software company with the same users. A UK headquarters is irrelevant to the obligation. What Brexit removed was the prospect of the EAA becoming UK domestic law, and with it any UK enforcement route. What it did not remove is the ability of French, German or Irish authorities to police their own markets, and their markets include every foreign company selling into them.
So the Brexit question is a red herring. The useful question is the one from the previous section: do EU consumers buy from you? If yes, the Act applies. If no, it does not, and no amount of alarming marketing changes that.
The Exemptions That Might Actually Apply to You
Two genuine carve-outs are worth checking before you do anything else.
The first is the microenterprise exemption for service providers: fewer than 10 staff and annual turnover of €2 million or less. You must meet both limbs, not either one. A six-person studio turning over €3 million does not qualify. A nine-person company under €2 million does. If you are close to either line, count carefully, because the exemption disappears the moment you cross one of them.
The second is the transitional period. Products and services already on the EU market before 28 June 2025 have until 28 June 2030. A product significantly updated before then loses that grace. Anything new gets no transition at all and must comply now.
If neither applies to you, scope comes down to the market test above. For the full picture of who the Act covers, which sectors it names and how the thresholds are counted, see our guide to who the European Accessibility Act applies to.
What UK Law Asks of You Anyway
Suppose your answer is no. UK customers only, no EU storefronts, out of scope. That settles the EAA question, but it does not mean UK law asks nothing of you.
In the UK, digital accessibility runs on WCAG, the Web Content Accessibility Guidelines. The legal anchor is the Equality Act 2010(opens in new tab). It requires service providers not to discriminate against disabled people, and it reaches websites and apps. Public sector bodies carry a further set of accessibility regulations covering their own digital estate. These are separate regimes from the EAA, with different tests and different standards, and it is a mistake to treat them as the same law under a different flag.
We keep a full guide to UK accessibility regulations, including where UK regulators point to WCAG, so we will not repeat it here. The short version: an EAA "no" is not a free pass. It simply moves the conversation to a different statute.
What Enforcement Looks Like Right Now
EAA enforcement is run country by country. Each member state sets its own penalties and appoints its own market surveillance authority, and there is no single EU-wide fine. The per-country penalty figures circulating online are vendor summaries, indicative at best, so treat any precise number with caution. One fact is worth stating plainly: no fine has been issued under any EAA transposition anywhere in the EU.
That does not mean nothing is happening. On 4 June 2026, the Tribunal judiciaire de Caen ordered Carrefour France to bring carrefour.fr and its mobile app to full accessibility within six months, with a daily penalty of €500 if it misses the deadline. Read that precisely. It is a court order with a prospective daily penalty attached, not a fine, and nothing has been paid. It is also the first order in the regime to name a mobile app, which matters to any UK company whose EU presence runs through the app stores. Our breakdown of the Carrefour ruling covers the detail.
The French docket is still moving. A near-identical case against Auchan was dismissed in Lille on 5 May 2026 on a domestic threshold reading and is now on appeal at the Cour d'appel de Douai, and an E.Leclerc hearing is listed for 22 September 2026 in Créteil. The direction of travel is court orders to comply by a deadline, and the companies that come through best are the ones holding evidence of work already done when the question arrives.
How to Find Out Where You Stand This Week
You do not need a law firm to answer the scope question. Three checks, none of which should take longer than an afternoon:
Check your storefronts. Open your App Store and Google Play listings and look at country availability. If EU storefronts are switched on, you are offering into the EU market, whether or not anyone has downloaded yet. If your EU presence is accidental, this is also where you can switch it off.
Check your analytics. Look for EU traffic, and more importantly for EU checkout completions and subscriptions. Revenue from EU consumers is the clearest possible signal that you are providing a service to the EU market.
Check your statement. Do you have a published accessibility statement, and does it reference EN 301 549, the EU's harmonised accessibility standard? The current version, 3.2.1, incorporates WCAG 2.1 Level AA, and it is the yardstick your product will be measured against if you are in scope.
If the checks say you are in scope, the path is the same as for any EU company: audit your website and app against EN 301 549, fix what you find in order of severity, and publish a statement that reflects your real, current status.
Find Out Where You Stand, Then Decide
The worst position is not "in scope". It is "no idea". AUDITSU is the guided audit toolkit that lets your own team run an EN 301 549 audit, log the evidence and generate an accessibility statement from what you find, with no accessibility expertise required. Websites are free to audit on the free plan, so a UK company can establish its baseline this week without spending anything. If your answer turns out to be yes, you already hold the record, and a year of AUDITSU costs at least 84% less than a one-off manual audit, often more. If the answer is no, you have certainty instead of a guess, and that is worth an afternoon.