The accessibility act explained

Since 28 June 2025, legal accessibility requirements have applied to online stores, banking services, telecom and e-books, among others.

Official name: Implementatiewet toegankelijkheidsvoorschriften producten en diensten; the Dutch transposition of Directive (EU) 2019/882, the European Accessibility Act
In force: since 28 June 2025; services to consumers and products placed on the market after that date
Applies to: online stores, banking, telecom, e-books, passenger transport and hardware; services to consumers and equipment intended for consumers
Exempt: microenterprises that provide services; fewer than 10 employees and no more than € 2 million turnover or balance sheet
Supervision: six regulators, split by sector; the ACM for online stores and electronic communications

What the accessibility act is

In the Netherlands the act is called the Implementatiewet toegankelijkheidsvoorschriften producten en diensten. It transposes the European accessibility directive, Directive (EU) 2019/882, known internationally as the European Accessibility Act. It has applied since 28 June 2025.

Certain products and services aimed at consumers have to be usable by people with disabilities, such as people who are blind, partially sighted or hard of hearing, or who cannot operate a mouse.

Public bodies have had rules like these for years. What is new is that they now apply to businesses as well, and that regulators check compliance. The Implementatiewet is an amending act: the requirements themselves sit in existing legislation, such as the Warenwet for products, the Civil Code for online sales, the Telecommunications Act and the Financial Supervision Act.

Which products and services fall under it

The act names the products and services it covers. If something is not on that list, it is not covered.

Specific elements of air, bus, rail and waterborne passenger transport are covered too: websites, mobile apps, electronic tickets, travel information and interactive self-service terminals. For urban, suburban and regional transport, only the self-service terminals are covered. Answering calls to the emergency number 112 falls under the act as well.

Transitional periods apply to situations that already existed when the act took effect.

Service providers may keep providing their services until 27 June 2030 using products they already used lawfully for similar services before then.
Service contracts concluded before 28 June 2025 may run on unchanged until they expire, and at the latest until five years after that date.
Self-service terminals lawfully in use before 28 June 2025 may stay in service until the end of their economic life, and no longer than twenty years after they were put into use.
That transitional provision does not cover e-commerce services. Those have their own provision in the Overgangswet nieuw Burgerlijk Wetboek, and it is open to more than one reading. Get legal advice before you rely on it.

Products and services covered by the accessibility act
Products	Services to consumers
Consumer computer hardware and its operating systems: desktops, laptops, smartphones and tablets	E-commerce services: selling to consumers through a website or app
Payment terminals, plus ATMs, ticketing machines, check-in machines and information kiosks used for services covered by the act	Consumer banking services
End-user equipment for electronic communications, such as modems and routers	Electronic communications services, such as calling, internet and messaging
Equipment for reaching audiovisual media services, such as smart TVs and set-top boxes	Services providing access to audiovisual media services, such as streaming
E-readers	E-books and the software dedicated to them

When your website or online store is covered

A company website is not automatically covered. What is covered is the e-commerce service: a service provided at a distance, through a website or app, by electronic means and at the individual request of a consumer, with a view to concluding a consumer contract.

If you sell exclusively to other businesses there is no consumer contract, so those sales are not covered. It also does not matter what you sell: the requirements apply to the online sale of any product or service, even when that product is not on the list above. An online store selling bicycle parts is covered just as much as one selling e-readers.

A few types of website and app content are excluded from the requirements.

Pre-recorded video and audio published before 28 June 2025.
Office file formats, such as PDFs and documents, published before 28 June 2025.
Online maps and mapping services, provided essential navigation information is offered in an accessible digital way.
Third-party content that you neither fund, develop nor control.
Archives: content that is no longer updated or edited after 28 June 2025.

The exemption for microenterprises

A microenterprise has fewer than ten employees and an annual turnover or an annual balance sheet total of no more than € 2 million. Both the staff test and the financial test apply, but for the financial test either figure is enough.

Even if you are exempt, a customer using a screen reader can only order from you if your checkout works with one.

What the microenterprise exemption means for services and for products
Microenterprise that	What applies
provides services, for example an online store, a travel service or a bank	fully exempt from the accessibility requirements and from the obligations that come with them
makes, imports or sells products listed in the act	has to meet the accessibility requirements, but does not have to document or notify a claim of disproportionate burden

Disproportionate burden and fundamental alteration

Besides the microenterprise exemption, the law has two exceptions that do not depend on your size. The accessibility requirements apply only insofar as compliance does not require a major change that alters the basic nature of the product or service, and only insofar as compliance does not impose a disproportionate burden on the economic operator.

If you invoke one of them, you assess that yourself; a disproportionate burden is assessed against the criteria in Annex VI to the directive. Relying on an exception carries the following obligations.

You document the assessment and keep the results for five years after the product was last made available or the service was last provided.
You inform the competent regulator that you are relying on the exception. Microenterprises do not have to give that notice.
You hand over the assessment as soon as the regulator asks for it.
As a service provider you renew the assessment when the service changes, at the regulator's request, and in any event at least every five years.
If you receive funding from outside your own resources to improve accessibility, public or private, you cannot rely on disproportionate burden.

Which standard applies: EN 301 549 and WCAG

The law itself sets no technical rules. Those are in the European standard EN 301 549, which sets out accessibility requirements for ICT: websites, apps, software, hardware and documents. Anyone meeting a harmonised standard whose reference is published in the Official Journal of the European Union is presumed to meet the legal requirements. No standard has been cited there for Directive (EU) 2019/882 yet, so you cannot rely on that rule for now.

For web content, EN 301 549 refers to WCAG, the international web accessibility guidelines. In practice the yardstick is version V3.2.1 from 2021, which adopts WCAG 2.1 level AA; the Official Journal cites that version only for public sector websites and apps, under Directive (EU) 2016/2102. Its successor V4.1.1, based on WCAG 2.2, came out in September 2026 and is not cited there yet.

If you are building or rebuilding now, WCAG 2.2 level AA is the sensible target; the article on WCAG 2.2 explains what the guidelines ask and how 2.1 and 2.2 differ.

Who enforces, and what you can do now

Supervision in the Netherlands is split across six regulators, each covering the sector it already supervised. The ACM supervises e-commerce and electronic communications services, the AFM consumer banking services, the Commissariaat voor de Media e-books and services providing access to audiovisual media, the RDI the products, the ILT passenger transport, and the Inspectie Justitie en Veiligheid the emergency number 112.

The ACM first approaches the largest companies that perform worst; those that then fail to improve enough risk enforcement. In March 2026 the ACM published the results of tests at around one hundred of the largest Dutch online stores. At 61 percent of them it was impossible to place an order with assistive technology, and another 33 percent had serious problems. Consumers can report an inaccessible website to the ACM.

Separately from supervision, a service provider has two obligations of its own. In your terms and conditions or an equivalent document you explain how your service meets the accessibility requirements, and you keep that information available for as long as you offer the service. If the service does not comply, you take corrective measures immediately and notify the competent regulator.

If you are unsure whether your situation is covered, ask a lawyer.

First establish whether you are covered: do you sell to consumers, and which service or product is it.
Have your site or app audited against WCAG 2.2 level AA, automatically and by hand. An automated scan finds only part of the issues.
Start with the parts customers use to order and get in touch: search, product page, cart, checkout and contact.
Fix the issues in the site you already have. An accessibility button or overlay does not fix the underlying errors.
Record what was tested and fixed, and publish the accessibility information on your site.

Sources

Frequently asked questions

When did the accessibility act take effect?

It has applied since 28 June 2025 to services provided to consumers and to products placed on the market after that date.

Does the law apply to my online store?

If you sell online to consumers, the requirements apply whatever you sell, unless you are a microenterprise.

We have fewer than ten employees. Are we exempt?

If you provide services and your turnover or balance sheet total is no more than € 2 million, you are exempt.

Which standard does our website have to meet?

The law itself names no standard; in practice the yardstick is EN 301 549 V3.2.1, which adopts WCAG 2.1 level AA for websites and apps. Content that meets WCAG 2.2 level AA also meets 2.1, according to the W3C.

Who checks this, and what happens if we do not comply?

For online stores and electronic communications it is the ACM, which approaches companies first; those that then fail to improve enough risk enforcement.

Can we rely on disproportionate burden?

You can, but you carry out the assessment yourself, document it, keep the results for five years and hand them to the regulator on request.

Can you also fix the errors in our site?

We audit your existing site and fix the issues the audit finds.