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Selling to consumers in the Netherlands · regulator: ACM

You sell online in the Netherlands, so your webshop or app has to meet the European Accessibility Act. Here is what to do

Since 28 June 2025 a webshop, app or online service for Dutch consumers must be accessible, and the ACM checks whether it is. On this page: what the ACM looks at, what you must report and by when, what counts as an exception, and how we get your shop through it. Kept up to date with the ACM’s own pages.

Does it apply to you: 10 or more employees, or a turnover above €2 million, and you sell to consumers
What you must do: make the shop accessible; if you cannot fix a problem at once, report it to the ACM within a week or a month
Who can help: an audit of the full checkout, the wording for the ACM form, and a retest that proves the fix

Webshops and online services we audited

Jumbo Plus De Bijenkorf Crisp NRC

What the ACM checks, and what it expects from you

Supervision

Reports from consumers, and checks the ACM starts itself

The ACM writes that it is the regulator that watches whether e-commerce services and electronic communication services are accessible according to the law. Consumers can file a report with the ACM when they notice that your website or app is not accessible. The ACM also selects websites and apps to investigate on its own initiative. How it acts, in its own words, depends on how big the problems are and on the steps the company takes to solve them.

Who must comply

The ACM's threshold

  • 10 or more employees, or an annual turnover above €2 million: your e-commerce service must be accessible
  • Fewer than 10 employees and a turnover of at most €2 million: a microenterprise, exempt for services
  • The directive also counts a balance sheet total of at most €2 million. The ACM leaves that out; check it legally if it matters to you.
Reporting duty

Fix it at once. If you cannot, report it

If your service is not accessible, the ACM expects you to repair it immediately. If that is not possible, you must report it to the ACM through its online form. In the report you state which parts are not accessible, what level of impact the problem has on the consumer, and you attach a plan to make the service fully accessible. You do not have to report a problem you have already solved within the deadline. After you file, you receive a confirmation by email; the ACM does not contact you unless it has questions.

Deadlines

Report within

  • 1 week for problems with a critical or serious impact
  • 1 month for problems with a moderate or minor impact
  • Also report when you rely on the exception for disproportionate burden or fundamental alteration
The 2026 approach

Ten full investigations, over a hundred spot checks, three months to fix

At the Dutch Digital Accessibility Day on 25 June 2026 the ACM presented how it started. Ten companies received a full investigation following WCAG-EM, with a report, and two weeks later a company visit with the CEO at the table and an ACM employee with a disability present. At over a hundred other companies the ACM looked at one important function of the website. Companies that did not comply were given three months, followed by a retest. When the ACM tests a webshop, it goes through the entire checkout, from product in the basket to payment. We were there; our full report is in the article linked below.

Exceptions

What does not count as disproportionate burden

  • A lack of time or knowledge
  • If you receive external funding to make your website or app accessible, you cannot use this exception
  • You must still meet as many requirements as you can
  • You must report to the ACM that you rely on it

How we help a webshop through this

  1. 1

    Audit the checkout the way the ACM does

    A senior auditor goes through the full customer journey by hand, from product listing to payment, with a screen reader, the keyboard and zoom. A full accessibility audit of a webshop starts from approximately €2,895 excl. VAT for a simple shop and takes three to five weeks. A mini audit of €495 gives you the biggest problems within five working days.

  2. 2

    Give you the wording for the ACM form

    The report groups findings per component, with the WCAG criterion, a severity and a fix. That is the information the ACM form asks for: which parts, what impact, what plan.

  3. 3

    Retest and record

    After your fixes we retest per finding and record what is solved. If the ACM comes back after three months, you have evidence instead of a promise.

Frequently asked questions

Which services does the ACM supervise?

E-commerce services, which the ACM describes as webshops and apps, and electronic communication services such as telephony and internet subscriptions. Banking and other financial services are supervised by the AFM, and passenger transport by the ILT, also when they are sold online.

Our webshop runs on Shopify, Magento or WooCommerce. Does that matter?

Not to the ACM, and not to us. We test the shop your customers use, including themes, plug-ins and payment providers. Where a problem cannot be solved within the platform, we suggest an alternative.

What if a customer complains to the ACM about our webshop?

The ACM says it takes reports from consumers and decides on its own how to act, depending on the size of the problems and the steps you take. In 2026 companies that did not comply were given three months and then retested. A documented audit and a repair plan are the strongest position to be in when that happens.

What are the fines?

The ACM writes that keeping your service accessible is how you avoid fines, and publishes no amounts. We do not quote figures we cannot source.

Where can I read the ACM's rules myself?

On the ACM page accessibility of e-commerce services and electronic communication services (in Dutch) and its English overview at acm.nl/en/accessibility. Our account of the ACM’s 2026 presentation is in what does a regulator do? The ACM on the EAA (in Dutch).

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Julia Tol Directeur
Phi Pham Projectmanager