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In force since 28 June 2025

You have to comply with the European Accessibility Act in the Netherlands, and nobody explains plainly what that means. This page does

The EAA requires companies that offer digital services to consumers to make those services accessible. In the Netherlands six regulators enforce it, each for its own sector. This page tells you which rules apply to you, who supervises you and what to do first.

Directive (EU) 2019/882, implemented in Dutch law and applied since 28 June 2025
The standard is EN 301 549, which currently points to WCAG 2.1 level A and AA
Six regulators: the ACM for webshops and online services, the AFM for financial services, the ILT for passenger transport
Ask us where you stand Call 085 5055 890

Audited for, among others

De Bijenkorf Plus Jumbo NRC Eteck

What the law asks, in four points

Who

Companies that offer covered services to consumers

The EAA covers services to consumers: e-commerce, banking and other financial services, passenger transport by air, bus, rail and water, electronic communication, e-books and access to audiovisual media. The ACM and the AFM describe the obligation by the service you offer and by your customer being a consumer, not by where your company is registered. Whether a company outside the EU that sells to Dutch consumers is in scope is a legal question; have it checked. Our advice: if you offer one of these services to consumers in the Netherlands, assume the EAA applies until a lawyer tells you otherwise. Public sector bodies fall under a different law, the Dutch decree on digital accessibility for government.

The exception

Microenterprises are exempt for services

  • Fewer than 10 employees, and
  • An annual turnover or an annual balance sheet total of at most €2 million (article 3(23) of the directive)
  • The ACM only mentions turnover on its page. If your case turns on the balance sheet total, have it checked legally.
  • The exemption applies to services. Products keep their obligations, with lighter paperwork.
What

An accessible website or app, measured against EN 301 549

The law requires an accessible service. It does not require an audit; an audit is how you find out where you stand. The benchmark is EN 301 549, the European standard for accessible ICT. That standard currently points to WCAG 2.1 level A and AA. We test against WCAG 2.2, which contains everything in 2.1 plus nine new criteria, because the AFM already asks firms to work towards it. EN 301 549 goes beyond the web page: your customer support has to be reachable by someone who cannot phone, and documentation you supply has to be accessible too.

In practice

What that means for your site

  • Every form field has a visible label
  • The whole order or application can be completed with the keyboard alone
  • Error messages say what is wrong and at which field
  • A screen reader reads buttons with a name that makes sense
  • Text can be enlarged to 200% without losing content
Who checks

Six regulators, each for its own sector

There is no single accessibility authority in the Netherlands. Enforcement of the EAA is divided over six existing regulators. For most companies one of three matters: the ACM for webshops, online services and telecom, the AFM for banking and other financial services, and the ILT for passenger transport. All three take reports from consumers and select services to check themselves. The ACM and the AFM also require you to report to them when your service does not comply. We describe each regulator on its own page.

Regulators

Which one supervises you

  • ACM: webshops, apps, online services, electronic communication
  • AFM: consumer banking and financial e-commerce services
  • ILT: passenger transport by air, bus, rail and water
  • RDI: devices such as ATMs, payment terminals, ticket and check-in machines, e-readers
  • Dutch Media Authority: e-books and access to audiovisual media
  • Inspectorate of Justice and Security: the emergency number 112
Two exceptions

Disproportionate burden is a file, not an opt-out

A company can argue that a specific requirement is a disproportionate burden, or would fundamentally alter the product. That is not an automatic exemption. The assessment must be documented, must be redone at least every five years (article 14(4) of the directive), and the regulator may ask for it. The ACM adds two limits: a lack of time or knowledge does not count, and a company that receives external funding to make its service accessible cannot use this exception at all. Both the ACM and the AFM require you to report to them when you rely on it.

Timing

The dates that matter

  • 28 June 2025: the rules apply to services offered from this date
  • 28 June 2030: services that were already running may continue with products that already existed until this date
  • Self-service terminals in use on 28 June 2025 may stay until the end of their economic life, at most twenty years
  • A website or app you maintain today has no transition period

What to do first

  1. 1

    Find out where you stand

    A manual audit following WCAG-EM shows which problems your service has and how severe they are. A mini audit of €495 gives you the biggest issues within five working days; a full audit gives you every finding per component.

  2. 2

    Fix, and report where required

    The ACM and the AFM require you to fix problems at once or to report them, with a deadline of one week for critical and serious problems and one month for moderate and minor ones. Our report gives you the wording: which function, which WCAG criterion, which platform, what you are doing about it.

  3. 3

    Prove it and publish it

    A retest records per finding that the problem is gone; that is what a regulator wants to see. Then publish information about the accessibility of your service on its own page on your website, so a visitor can find it without reading your terms and conditions.

EAA monitor · measured 7 September 2026

How many companies in the Netherlands publish accessibility information?

Every Monday our EAA monitor checks the footer of Dutch websites in seven sectors for a link to an accessibility statement. A statement is a promise, not proof: whether a site works for someone with a disability only shows in a test of the site itself. But a company without one has not started.

Share of websites without an accessibility statement, per sector
Accessibility statements per sector, measured 7 September 2026
SectorRegulatorCheckedWith statementWithout statementCould not be checked
Web shopsACM10,271202 (2%)8,523 (83%)1,546 (15%)
Banks, insurers and payment servicesAFM6842 (62%)21 (31%)5 (7%)
Telecom providersACM1812 (67%)5 (28%)1 (6%)
Passenger transportILT216 (29%)11 (52%)4 (19%)
Media and streamingCvdM158 (53%)5 (33%)2 (13%)
E-book platformsACM105 (50%)1 (10%)4 (40%)
Tour operators and travel agenciesACM244 (17%)18 (75%)2 (8%)

"Could not be checked" means the site blocked the automated check, for example with bot protection. Sources for the lists: Thuiswinkel.org and WebwinkelKeur for web shops; the other sectors are curated lists. The regulator column names the Dutch authority that supervises that sector under the EAA.

See the live figures on the EAA monitor

Frequently asked questions

Does the EAA apply to B2B services?

The EAA is about services to consumers. The AFM writes on its page that services to business customers fall outside the EAA, and adds that a sole trader who takes a service privately is a consumer. If your website serves both, the consumer part is in scope.

Is WCAG 2.1 AA enough to comply?

WCAG 2.1 level A and AA is what EN 301 549 currently points to, so that is the legal floor for the web part of your service. Two things to know. First, EN 301 549 also covers your customer support and documentation, so a website that passes WCAG can still fall short on the standard as a whole. Second, a new version of EN 301 549 that adopts WCAG 2.2 exists as a draft and is expected to be designated in the Official Journal; the AFM already asks firms to work towards WCAG 2.2. We test against 2.2 for that reason.

Do we need to publish an accessibility statement?

Under the EAA you publish information about the accessibility of your service on a separate page on your website; the AFM calls this an accessibility statement and expects it from every firm it supervises. It is not the same as the accessibility statement in the Dutch government register: that register belongs to the government decree, not to the EAA.

What are the penalties?

The ACM writes that keeping your service accessible is how you avoid fines. Neither the ACM nor the AFM publishes fine amounts, so we do not quote any. What the ACM did in 2026: companies that did not comply were given three months to fix the problems, followed by a retest. If you operate in several EU countries, note that sanctions and repair deadlines differ per country.

Do we have to have an audit done?

No. The law requires an accessible service, not an audit. The practical reason to have one: without it you do not know what is wrong, and the ACM tests according to WCAG-EM itself, so an audit in that same method gives you something to put on the table when questions come. An average audit at Proper Access produces around a hundred findings, and they are rarely where people expect them.

Does an overlay tool make us compliant?

No. An overlay is a script that runs on top of your site and leaves the code underneath unchanged. A button without an accessible name is still a button without an accessible name. We tested the three best-known overlay tools and reached the same conclusion the ACM gave publicly in June 2026.

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Julia Tol Directeur
Phi Pham Projectmanager