Disproportionate burden assessment under the European Accessibility Act (Directive (EU) 2019/882)
The micro-enterprise exemption reaches service providers only. A
micro-enterprise that manufactures, imports or distributes a product is
not exempt — so answer the first question carefully.
The size test is fewer than 10 staff AND (turnover not above €2 million
or balance sheet total not above €2 million). The financial limb is
satisfied if either figure is at or below €2m. If you are exempt you do not need
the rest of this workbook — but keep evidence of the exemption.
Enter your own figures. Every number you enter should be traceable to a quote, an invoice, or a documented internal estimate — an authority may ask to see the basis.
Remediation quotes, design and dev time, testing, audit. Net of any grants or funding.
Ongoing testing, monitoring, training, maintenance.
A reasoned estimate. EU disability prevalence is commonly cited near 1 in 4 adults; state your basis.
Claiming disproportionate burden does not remove the duty to make the service as accessible as possible. Record what you are doing, with dates. An assessment with an empty remediation plan is the weakest possible position.
| Duty | Requirement |
|---|---|
| Retain this assessment | 5 years from the last time the service was provided |
| Reassess | When the service is altered, on authority request, and at least every 5 years |
| Notify | Inform the relevant market surveillance authority that you rely on the exception |
| Produce on request | Supply a copy of the assessment and its evidence when asked |
Requirements above reflect Directive (EU) 2019/882. Verify the transposing national law in each Member State where you offer the service — penalties and procedure are set nationally.
A mid-sized EU retailer, 24 staff, €8.4m turnover. Not a micro-enterprise, so in scope. A remediation quote comes to €46,000 one-off plus €9,000 a year, against €6.1m of total expenditure.
| Ratio | Value | How this reads |
|---|---|---|
| Cost ÷ expenditure | 0.90% | Under one percent of what the business already spends |
| Cost ÷ turnover | 0.65% | Well inside normal project variance |
| Cost per user served | €4.58 | Against 12,000 users with disabilities a year |
How to read this honestly: these ratios do not support a disproportionate burden claim. That is the most common real outcome, and it is useful — it tells the business to budget the remediation rather than build a case that would not survive scrutiny. A workbook that only ever produced "you are exempt" would be worthless to the person relying on it.
Scope and limits. This workbook structures an assessment against the Annex VI criteria. It does not audit your website, does not determine compliance, and is not legal advice. Whether a burden is disproportionate is judged by the relevant national authority against the transposing law in that Member State.
Enforcement status, stated plainly. As of the research date for this workbook, no EAA penalty had been reported in the sources reviewed — but that is an absence of reporting across 27 national transpositions, not proof that none exists, and enforcement activity has been increasing. There has been real activity — a French court ordered a major retailer to remediate within six months under daily penalties, Sweden's regulator opened investigations on its own initiative, and the Netherlands ran a mandatory self-reporting cycle and is auditing non-responders. Enforcement to date has focused on large operators. Anyone quoting six-figure fines at a small shop is selling fear rather than facts.
Version 0.1 · Directive (EU) 2019/882 · This file contains no tracking and no external requests.