Does the European Accessibility Act apply to Turkish companies?

The European Accessibility Act can apply to a Turkish company that offers services online to consumers in the EU, regardless of where the company is established. It does not, however, directly cover a company that sells only to other businesses, or a service provider that falls under the directive’s definition of a microenterprise, as far as the service obligations are concerned.

The “European Accessibility Act” (EAA for short) is in fact an EU directive: Directive (EU) 2019/882. A directive is addressed not to companies directly but to member states; each member state transposes it into its own law, and the text that binds a company is that national law. This page summarizes the directive itself and the explanations of the implementing body in Germany; it is not legal advice. Verify the current requirement in the country you sell to with the official source, and consult a lawyer about your own situation.

When did the European Accessibility Act come into force?

The directive requires member states to adopt national rules by 28 June 2022 and to apply them from 28 June 2025. Its scope has two groups. Products: consumer computer hardware and operating systems (the directive’s recitals also cite smartphones and tablets as examples), payment terminals, self-service terminals such as ATMs and ticket machines, interactive consumer devices used for electronic communications and audiovisual media, and e-readers. Services: electronic communications, access to audiovisual media, the websites, mobile applications and e-tickets of air, bus, rail and waterborne passenger transport, consumer banking, e-books and e-commerce.

For a Turkish company, the line most often relevant is the last one. The directive defines an e-commerce service as a service provided at a distance, through websites and mobile device-based services, by electronic means and at the individual request of a consumer, with a view to concluding a consumer contract. So what matters is not that a site exists but that the site mediates the conclusion of a contract with a consumer. How such a service is measured and prepared is described on the web accessibility audit page.

Why can a company based in Türkiye fall within scope?

Because the directive defines a service provider not by its place of establishment but by where it provides its service: any natural or legal person who provides a service on the EU market or makes offers to provide such a service to consumers in the EU. A company established in Istanbul that sells to consumers in Germany through a German-language online store falls under this definition. Whether the company has an entity, warehouse or employees in the EU is not a condition in the definition.

Is a site that sells only to businesses (B2B) in scope?

On the service side, the directive covers only services provided to consumers, and it defines a consumer as a natural person who purchases a product or service for purposes outside their trade, business, craft or profession. An ordering portal that serves only businesses falls outside this definition. The federal body that implements the law in Germany (Bundesfachstelle Barrierefreiheit) reads it the same way, but in cautious language: it writes that services offered only from business to business “should” not be affected by the law. The same body says that a site that merely provides information or only presents products should not be in scope either; a site comes into scope only if the relevant service is provided to consumers through it.

• Online store selling to consumers in Germany — an e-commerce service; appears to be in scope unless the company is a microenterprise.
• Ordering portal open only to dealers and businesses — appears to be out of scope if it is not offered to consumers. If the portal is open to everyone and a consumer can also place an order, the question has to be asked again.
• Corporate site that presents products but takes no orders — appears to be out of scope on the German implementing body’s reading.
• Microenterprise selling to consumers — exempt from the service obligations; but if it places products on the EU market, the product obligations apply separately.

The word “appears” here is deliberate. Borderline cases — such as a store open both to dealers and to end customers — depend on the interpretation of the national law and the market surveillance authority. For an exporter, the right question is not “Are we B2B?” but “Can a consumer conclude a contract with us through our site?” When building a multilingual B2B site, writing down the answer to this question at the very start determines the scope of any compliance work later.

Who does the microenterprise exemption cover?

The directive defines a microenterprise as an enterprise that employs fewer than ten persons and whose annual turnover or annual balance sheet total does not exceed two million euros. Microenterprises providing services are exempt from the accessibility requirements for services and the obligations attached to them. The exemption applies only to services: as the implementing body in Germany also stresses, microenterprises placing products on the market remain in scope. Member states are obliged to provide microenterprises with guidelines and tools that make application easier.

What is the “disproportionate burden” exception?

The directive allows the requirements not to apply where they would require a significant change to the product or service resulting in a fundamental alteration of its basic nature, or would impose a disproportionate burden on the business. But this is possible only through an assessment, not a declaration: the business carries out the assessment according to the criteria in the directive’s annex, documents it and keeps the results for five years. A service provider relying on this exception renews its assessment when the service is altered, when the authority requests it and in any case at least every five years. A business that receives external funding for accessibility cannot rely on this exception; a business that does rely on it informs the authority of the relevant country — microenterprises are exempt from this notification.

What does the BFSG require in Germany?

The directive’s German counterpart is the Barrierefreiheitsstärkungsgesetz, or BFSG for short. Market surveillance of products and services lies with the joint authority of the federal states, the MLBF (Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen); according to the Bundesfachstelle Barrierefreiheit, the authority started work on 26 September 2025, when the interstate treaty it is based on entered into force. For a Turkish company with German-language pages, the practical meaning is this: if you sell to consumers in Germany, this authority and this law are your counterparts.

What is expected technically from a website?

The directive does not refer to WCAG directly; it writes the technical requirements functionally in its annex and presumes that a service conforming to a harmonized European standard meets those requirements. On the web side, the standard prepared for this purpose is EN 301 549; the text of the directive does not name the standard. The V4.1.0 draft of the standard, dated November 2025, was prepared directly for this directive, and its web section was aligned with WCAG 2.2: conformance with WCAG 2.2 AA is treated as equivalent to conformance with all of the standard’s web clauses. According to the draft’s own foreword, the presumption of conformity arises once the reference to the standard is published in the Official Journal of the EU under this directive; verify the current status in the official list.

Beyond the site itself there are two further obligations. The service provider publishes information on how the service meets the accessibility requirements in its general terms and conditions or an equivalent document; this information includes a general description of the service, how it works and how the requirements are met. In practice, this is the commercial counterpart of an accessibility statement. The second is continuity: the service provider puts in place procedures that keep the service compliant and, when it becomes aware of non-compliance, corrects it and informs the authorities of the countries where it provides the service.

• Out-of-scope web content — prerecorded video and audio and office files published before 28 June 2025, third-party content not under the business’s control, and archived content not updated after that date.
• Transition — service contracts concluded before 28 June 2025 may continue unchanged until they expire, but for no longer than five years.

What changes if you also sell in Türkiye?

On the Turkish side, Presidential Circular No. 2025/10 requires service providers engaged in electronic commerce under Law No. 6563 to bring their websites and mobile applications into line with the Ministry’s level A checklist and WCAG 2.2 within two years. Unlike the European act, the circular makes no distinction between selling to consumers and selling to businesses, and sets no size threshold. Details are in the guide to the circular. For a company that sells to both sides, a single WCAG 2.2 AA effort covers the level A the circular requires and meets the core of the web requirement on the EU side.

The deciding question is not “Where are we established?” but “Who are we selling to?”

A practical sequence for a Turkish company

• Who am I selling to? — can a consumer in the EU conclude a contract through my site?
• What size am I? — am I a microenterprise providing services? Do I place products on the market?
• In which country? — what are the national law and authority of the member state I sell to? For Germany, the BFSG and the MLBF.
• What will be measured? — WCAG 2.2 AA and the web section of EN 301 549, including the pages in the target market’s language; template by template and critical flow by critical flow.
• What will be published? — the accessibility information of the service, in the general terms and conditions or an equivalent document.
• How will it be maintained? — an audit repeated with every release; a fix made once breaks silently in later releases.

How do you maintain an accessibility baseline on a trilingual site?

This site is published in Turkish, English and German, and all three languages come from the same generator and the same templates. Because the focus ring, touch target and contrast decisions live in the templates and the color tokens, they are not fixed separately per language; if a decision changes, it changes in all three languages at once. Before release, every version passes an automated accessibility audit (axe) and a suite of 1462 tests; in the suite, the 2-pixel thickness of the focus ring, touch targets of at least 44 pixels and the AA contrast thresholds are guarded.

German needs extra attention in this setup: the same phrase can be noticeably longer in German, and if a button label overflows or is clipped, both legibility and the touch target are affected (German text expansion). For a Turkish company that will sell to consumers in Germany, the measurement has to be done on the German page, not the Turkish one; the person the law protects is the one reading that page.

If you want to know whether your site meets these criteria, the web accessibility audit measures every template against WCAG 2.2 point by point, fixes problems at the source and documents the result.