Digital Accessibility · Legislation
Which accessibility rules apply to your website?
Do you sell online to consumers, in the Netherlands or in other EU countries? Then you are subject to the European Accessibility Act, and to the way each country has implemented it. On this page, we compare the rules: Europe, the Netherlands, Belgium, Germany and other countries, the government, the United Kingdom, and the United States.
In this article
- Do the rules apply to you? Five questions
- The European Accessibility Act in brief
- Do you also sell outside the Netherlands? Here’s what changes
- What the ACM expects from your webshop
- WCAG 2.1 or WCAG 2.2: which version applies?
- Rules for government organisations
- United Kingdom and United States
- What you can do now
What the rules mean for a Dutch webshopWebshop A website where visitors can view, order, and pay for products. is extensively covered on our page about digital accessibility. This article provides an overview, focusing on what changes when you sell across borders.
Quick check
Do the rules apply to you? Five questions
- Are you a government organisation? Then government rules apply, including a mandatory accessibility statement. See the section on government.
- Do you sell to consumers via your website or app? If you only sell to businesses, you do not fall under the e-commerce rules according to the text of the directive.
- Do you have fewer than 10 employees and an annual turnover or balance sheet total of a maximum of 2 million euros? Then you are exempt in the Netherlands and Germany. Not in Belgium: there you get a postponement until 28 June 2030.
- Do you also sell to consumers in other EU countries? Then each of those countries can exercise supervision. See the section on selling outside the Netherlands.
- Are you a bank, carrier, telecom company, or e-book seller? Then the same European rules apply, with a different supervisory authority.
Europe
The European Accessibility Act in brief
The European Accessibility Act (EAA) is Directive (EU) 2019/882. The rules have applied to services for consumers since 28 June 2025. Each EU country has transposed the directive into its own law. The requirements are the same in all countries, but enforcement differs.
For whom
Webshops and other online sales to consumers, banking services for consumers, websites, apps and e-tickets for air, bus, train or water transport, telecom services, e-books and access to audiovisual media.
What is required
Your website and app must be perceivable, operable, understandable, and robust. For webshops, this also applies to logging in, paying, and signing. Also display the accessibility information you receive about your products.
What you must disclose
A description of your service and how you meet the requirements. This should be included in your general terms and conditions or a similar document, in written and oral form, and itself accessible. In practice, this is often called an accessibility statement.
What falls outside the rules
Videos and office files from before 28 June 2025, maps if important information is also accessible in another way, content from others that you do not pay for or manage, and archives that you no longer update.
Exceptions and transitional rules
If adaptation constitutes a disproportionate burden, or changes the nature of your service, you may invoke an exception. This assessment must be documented, reassessed at least every five years, and reported to the supervisory authority. Lack of time or knowledge does not count as a disproportionate burden according to the ACM. Contracts concluded before 28 June 2025 may continue unchanged until 28 June 2030 at the latest.
Selling in the EU
Do you also sell outside the Netherlands? Here’s what changes
The directive considers where you sell, not just where your company is located. A provider is anyone who offers a service to consumers in the EU. If you also sell to Belgians, Germans, or French, then in principle the law of those countries also applies, in addition to Dutch law.
One technical standard for the entire EU
All countries use the same requirements from the directive and the same European standard, EN 301 549. If your webshop complies with WCAGWCAG The international guidelines that define when a website is accessible to everyone, including people with disabilities. 2.1 level AA, and soon WCAG 2.2, it will be technically compliant in every EU country. The differences lie in procedures, supervision, and penalties.
Each country can supervise
The ACM writes: “Are you active in multiple EU countries? Then you must report to the supervisory authority of each country where you are active.” If your webshop is not compliant, you must report this in every country where you sell. The supervisory authorities cooperate.
Small webshop? Pay attention to Belgium
In the Netherlands and Germany, micro-enterprises are exempt. Belgium has regulated this differently: there, they only get extra time, until 28 June 2030. If you sell to Belgians as a small webshop, keep this in mind.
In your customer’s language
The directive does not prescribe a language. Accessibility information that your customer cannot read is not helpful to them. Therefore, provide the statement in the language of each market and link it from the general terms and conditions of each language version.
The differences per country
| Country | Law | Webshop supervision | Maximum fine | Micro-enterprises |
|---|---|---|---|---|
| Netherlands | Implementation Act on Accessibility Requirements (BW 6:230fa to 230fd) | ACM | Penalty payment or fine | Exempt |
| Belgium | Law of 5 November 2023 (Code of Economic Law, Book VIII) | FPS Economy, Economic Inspection | €100,000 or 4% of annual turnover; in case of bad faith €250,000 or 6% | Not exempt, postponement until 28 June 2030 |
| Germany | Barrierefreiheitsstärkungsgesetz (BFSG) | MLBF in Magdeburg | €100,000 | Exempt |
| France | Loi 2023-171 and Code de la consommation | DGCCRF | €7,500 per infringement, per service and per obligation, plus penalty payment | Exempt |
| Austria | Barrierefreiheitsgesetz (BaFG) | Sozialministeriumservice | €80,000 | Exempt |
Germany: competitors can also send you warnings
In Germany, since July 2025, lawyers have been sending warning letters, an Abmahnung, on behalf of competitors to webshops that are not accessible. Whether this holds up legally has not yet been decided by a court. If you sell a lot in Germany, this is practically the biggest risk. German law requires accessibility information in your general terms and conditions or another clearly visible place.
What is not yet certain
According to the European e-commerce directive, online services are in principle subject to the rules of the country where the company is located. Whether this limits enforcement by other countries regarding accessibility has not yet been decided. No supervisory authority or court has ruled on this. Therefore, assume for now that every country where you sell can take action.
Netherlands
What the ACM expects from your webshop
The Netherlands has implemented the directive with the Implementation Act on Accessibility Requirements for Products and Services. The rules for webshops are laid down in the Civil Code. The ACM supervises and actively checks: among approximately 100 of the largest Dutch online shops, 61 percent proved not to be digitally accessible.
- Your website and app comply with WCAG level AA. The ACM already advises WCAG 2.2.
- An independent auditAudit A thorough check of your website for errors and opportunities., certificate, or quality mark is not mandatory.
- Your accessibility statement is easy to find, accessible itself, and also available orally, for example as an audio fragment.
- Your customer service also provides accessibility information in an accessible way.
- You remain responsible, even if another company builds your website.
The reporting obligation that few webshops know about
If your webshop is not compliant, you must report this to the ACM, along with a plan to resolve it. For a critical or serious problem, within a week; for a moderate or minor problem, within a month. If you resolve it within that period, you do not need to report. If you invoke an exception, you also report that.
In addition to these rules, all companies are subject to the Equal Treatment Act on the grounds of disability or chronic illness. This requires effective adjustments and gradual provision for general accessibility, even if you fall under an exemption.
The standard
WCAG 2.1 or WCAG 2.2: which version applies?
The law does not specify a WCAG version. You comply with the law if you comply with the European standard EN 301 549 published in the Official Journal of the EU. This is currently version 3.2.1, which uses WCAG 2.1 level AA.
Version 4.1.1, with WCAG 2.2 level AA, was published in September 2026. This will become the benchmarkBenchmark A comparative figure, such as the average within your industry. as soon as the European Commission includes it in the Official Journal. A date is not yet known. The ACM expects WCAG 2.2 to become the new standard during 2026.
Our advice: build and test now for WCAG 2.2. This version includes everything from WCAG 2.1, plus six additional requirements at level A and AA: larger click areas, focus that does not disappear behind a fixed header, an alternative to dragging, help in a fixed location, no duplicate input, and logging in without a puzzle. Those who incorporate this now will not have to redo anything later.
Government
Rules for government organisations
For the government, a separate European directive applies, implemented in the Netherlands in the Temporary Decree on Digital Accessibility for Government. Websites and apps must comply with EN 301 549, i.e., WCAG 2.1 level A and AA: 50 requirements. Each organisation publishes an accessibility statement in the register on toegankelijkheidsverklaring.nl, with a status.
| Status | Meaning | Complies with the law? |
|---|---|---|
| A | Complies with all 50 requirements, research no older than 3 years | Yes |
| B | Research no older than 3 years, complies with fewer than 50 requirements | Yes, if measures are described and there is annual improvement |
| C | No good research yet, but planned within 6 months | Yes, maximum 6 months |
| D | Statement without research or plan | No |
| E | No statement | No |
Outside the EU
United Kingdom and United States
United Kingdom
The EAA does not apply in Great Britain. The British government must comply with WCAG 2.2 level AA. For businesses, the Equality Act 2010 applies: no fixed WCAG requirement, but an obligation to proactively remove barriers for people with disabilities. The risk is a discrimination claim. If a British company sells to consumers in the EU, the EAA does apply.
United States
According to the US Department of Justice, the ADA also applies to company websites, but no technical standard has been set. For states and municipalities, WCAG 2.1 level AA applies, with deadlines in April 2027 and April 2028. Federal agencies follow WCAG 2.0 level AA.
Getting started
What you can do now
- Determine which countries you sell to consumers in, and whether you are a micro-enterprise.
- Have your website measured against WCAG 2.2 level AA, including login, shopping cart, and payment.
- Address the biggest problems first. What you cannot resolve within a week or a month, report to the supervisory authority of each country where you sell.
- Publish your accessibility statement in the language of each market, and link it from your general terms and conditions and your footerFooter The fixed bottom section of every page, featuring contact details, important links, and social media..
- Remasure after every major change, and at least once a year.
This explanation reflects the situation as of 13 October 2026. Consider it as guidance; it is not legal advice. Laws and standards are still changing: in January 2026, the European Commission asked several countries, including the Netherlands, to supplement their laws. If you are unsure whether the rules apply to you, consult a lawyer.
Sources: Directive (EU) 2019/882 and (EU) 2016/2102 on EUR-Lex; Staatsblad 2024, 87 and 2024, 341; Civil Code articles 6:230fa to 6:230fd; ACM; digitoegankelijk.nl; FOD Economie; BFSG; BaFG; Code de la consommation; AccessibleEU; legislation.gov.uk; Federal Register.
Know where your webshop stands
The free website scan shows where your webshop currently stands. If you first want to discuss whether the rules apply to you, that is also possible.
