Yes, if the online shop sells to consumers and the business is not a microenterprise. From 28 June 2025, the Act also applies to online shops, but not to services provided by microenterprises, meaning businesses with fewer than 10 persons and annual turnover or an annual balance sheet total of no more than 2 million euros. A small business above this threshold is not exempt. It may apply the requirements to a limited extent only if meeting them would fundamentally alter the nature of the service or impose a disproportionate burden. However, it must assess this and notify the inspection authority.
From 28 June 2025, information society services provided to consumers, including online shops, must meet accessibility requirements for persons with disabilities. This is required by Act No. 351/2022 Z. z. on the Accessibility of Products and Services for Persons with Disabilities, which transposes the European Accessibility Act. A small business is exempt only if it qualifies as a microenterprise. The article accessibility of online shops and digital services (forthcoming) (in Slovak) explains in more detail what the Act requires of online shops and how the Slovak Trade Inspection monitors compliance.
When you qualify as a microenterprise
The Act provides for the exemption as follows:
The following quotation is reproduced in its original language:
Tento zákon sa nevzťahuje na služby poskytované mikropodnikom.
The Act takes the definition from Commission Recommendation 2003/361/EC. A microenterprise employs fewer than 10 persons and has annual turnover or an annual balance sheet total not exceeding 2 million euros (Article 2(3) of the Annex to Recommendation 2003/361/EC). Both conditions must be met: the headcount and the financial threshold. However, meeting either of the two financial criteria is sufficient.
Headcount, expressed in annual work units, includes not only employees but also owner-managers and partners who regularly work in the business (Article 5 of the Annex). If the online shop has partner or linked enterprises, for example because it belongs to a group of companies, their data must also be included in the calculation (Articles 3 and 6 of the Annex). Microenterprise status is lost or acquired only when the enterprise exceeds or falls below the thresholds in two consecutive accounting periods (Article 4(2) of the Annex).
Small businesses above the threshold
A business that does not meet both microenterprise conditions is not exempt, even if it still qualifies as a small enterprise. However, it must apply the accessibility requirements only to the extent that they neither require a fundamental alteration of the basic nature of the service nor impose a disproportionate burden (Section 7(1)). Anyone relying on this must assess the application of the requirements, retain the assessment for 5 years after the service was last provided (Section 7(2)), and notify both the Slovak Trade Inspection and the supervisory authority of the country in which the service is provided in writing (Section 7(5)). The disproportionate burden assessment must be renewed when the service changes, at the inspection authority’s request, and every 5 years after the last assessment (Section 7(3)). A provider that has received funding from sources other than its own resources to improve accessibility cannot rely on disproportionate burden (Section 7(4)).
For failure to meet the requirements or make accessibility information available, the inspection authority may impose a fine ranging from 200 euros to 3 % of turnover for the preceding accounting period, capped at 6 000 euros. For other administrative offences, the cap is 20 000 euros or 30 000 euros (Section 10(2)). For failure to meet the requirements and failure to establish procedures to maintain compliance, the inspection authority will refrain from imposing a fine if the provider takes corrective measures or demonstrates a fundamental alteration of the service or a disproportionate burden (Section 10(3)).
When the Act does not apply to an online shop
The Act covers only services provided to consumers (Section 2(1)). An online shop selling exclusively to businesses falls outside its scope. It also does not apply to website content that was neither created nor funded by the service provider or an entity under its control (Section 2(2), letter b)). A service provided under a contract concluded by 28 June 2025 is exempt from the requirements until that contract ends, but no later than 28 June 2030 (Section 12(1)). This transitional provision will generally not help an online shop that concludes a new contract with each order. The requirements also do not apply to pre-recorded media and office files published before 28 June 2025, or to archives whose content is not updated after that date (Section 12(2)).
Sales between Slovakia and Czechia
Under the Act, a service provider is anyone who provides or offers a service to consumers on the Slovak market (Section 3, letter b)), including a Czech online shop selling to Slovak customers. The Czech rules in Act No. 424/2023 Sb. on Accessibility Requirements for Certain Products and Services apply to e-commerce services and also include a microenterprise exemption (Section 2 of Act No. 424/2023 Sb.). Supervision is carried out by the Czech Trade Inspection Authority (Section 19(2)).
We can help you determine whether you qualify as a microenterprise, prepare a disproportionate burden assessment and notification to the inspection authority, and add accessibility information to your terms and conditions. A developer or accessibility specialist carries out the technical assessment of the website. We can draft your contract with them so that the obligation to maintain accessibility also applies to subsequent changes. We will review accessibility alongside your other obligations during the initial audit included in our legal services for online shops.
This answer provides general information on the law as at 3 October 2026. It does not constitute legal services or replace an assessment of an individual case. The details of your situation may differ. Book a consultation to discuss them.
