Does it apply to you?
Since 28 June 2025 the rules of the European Accessibility Act apply in the Netherlands. The Authority for Consumers and Markets (ACM) supervises e-commerce services: websites and apps where consumers buy, book or enter into an agreement. Chat and video calling are supervised too.
Small businesses are exempt. If you have fewer than 10 people on staff and an annual turnover of at most 2 million euros, these obligations do not apply. If you are above that, or growing towards it, accessibility belongs on the plan.
- Webshops and booking sites for consumers
- Signing up for subscriptions or services online
- Chat and (video) calls with customers
- Not required: under 10 staff and at most 2 million euros turnover
What the regulator expects
The ACM assesses against WCAG 2.1 at level AA. According to the ACM, WCAG 2.2 AA becomes the new standard during 2026, and it advises building to it already.
It covers the whole customer journey: paying, identification, digital signing and the emails and attachments that come with an order. You also need an accessibility statement on the website and in the app that is easy to find and accessible itself.
A certificate or quality mark is not required. Video, audio and office documents from before 28 June 2025 and archives are exempt.
Where it goes wrong today
In March 2026 the ACM reported that 61 percent of roughly one hundred of the largest Dutch webshops were not digitally accessible. In those shops, ordering with assistive technology failed, for example because of an order button that does not work with the keyboard or an inaccessible CAPTCHA.
These are not edge cases. Unreachable buttons, unclear forms and error messages without explanation hinder every visitor, so they simply cost revenue too.
Checklist for your order journey
Start with the journey that makes money: search, choose a product, add to cart, check out and the confirmation. Walk through those five steps with these questions.
- Can you reach and use everything with only Tab, Enter and the arrow keys?
- Can you always see where the focus is?
- Do buttons, links and fields have a clear name for screen readers?
- Is the contrast of text and buttons sufficient, also on photos?
- Do error messages explain what is wrong and how to fix it?
- Does the page work at 200% zoom without anything disappearing?
- Are payment and the confirmation email accessible too?
If it does not comply (yet)
If your service does not comply yet, the ACM expects a report with a plan. Critical and serious problems are reported within a week, smaller ones within a month, unless you fix them within that period.
Decide who is responsible, publish the accessibility statement and plan the improvements. Accessibility is cheapest when it is part of the design from the start: colours, components and forms that are right from day one. A redesign or rebrand is the ideal moment.
Primary sources
The factual and technical claims in this article were checked against these sources.

