The accessibility act explained

Since 28 June 2025 there are legal accessibility requirements for online stores, banking services, telecom and e-books, among others. Below is what the law covers, who it applies to and what is expected of you.

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.

The principle is simple: certain products and services aimed at consumers have to be usable by people with disabilities. That covers blind and partially sighted visitors, people who cannot operate a mouse, and people who are hard of hearing.

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. For products the requirements apply once they are placed on the market after 28 June 2025. For services they have applied since that date to everything provided to consumers.

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.

Arrangements that were already running get transitional periods.

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. Do not rely on it without legal advice.

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.

Two things in that definition are easily missed. If you sell exclusively to other businesses there is no consumer contract, so those sales are not covered. And it 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 things are excluded from the requirements for website and app content.

To work this out for your own situation, we go through the question step by step on the follow-up page Does my online store fall under it.

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

The best known exemption is the one for microenterprises, and it is the one most often summarised wrongly. A microenterprise has fewer than ten employees and an annual turnover or an annual balance sheet total of no more than two million euro. Both the staff test and the financial test apply, but for the financial test either figure is enough.

More importantly, the exemption does not mean the same thing for everyone. If you provide services, you are fully exempt from the accessibility requirements and from every obligation that comes with them. If you deal in products, that exemption does not apply and you have to meet the requirements.

Being exempt does not mean it has no consequences. A customer who cannot get through your checkout with a screen reader does not complete the order.

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	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, against the criteria in Annex VI to the directive. A set of obligations comes with it.

For a website or online store, keeping that file in order is often more work than fixing the issues an audit turns up.

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 prescribes no technology. That sits 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.

For the web part, EN 301 549 points to WCAG, the international web accessibility guidelines. The version published so far, EN 301 549 V3.2.1 from 2021, adopts WCAG 2.1 level AA. A revision adopting WCAG 2.2 is in preparation.

If you are building or rebuilding now, WCAG 2.2 level AA is the sensible target. Content that conforms to WCAG 2.2 also conforms to WCAG 2.1 and 2.0, according to the W3C. One success criterion from 2.1 was removed in 2.2 (4.1.1 Parsing). If you have to report formally against 2.1, you may still need to test and report that one separately.

Behind all those numbers sit four principles: perceivable, operable, understandable and robust. In practice that means enough contrast, everything reachable by keyboard, clear error messages in forms, alternative text on images, captions on video and a page structure a screen reader can follow.

Who enforces, and what you can do now

Supervision in the Netherlands is split across six regulators, each covering the sector it already knew. 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 starts with the problems that hit users hardest and approaches companies first; those that then fail to improve enough risk enforcement. In March 2026 the ACM examined around one hundred of the largest Dutch online stores. At 61 percent 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 that are easy to overlook. 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 the service runs. If the service does not comply, you take corrective measures immediately and notify the competent regulator.

This is an explanation, not legal advice. If you are unsure whether your situation is covered, put it to a lawyer. If you want to know where your site stands, we'll audit it and record what is wrong.

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 path that earns money: 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

From when does the accessibility act apply?

Since 28 June 2025. From that date the requirements apply to services provided to consumers and to products placed on the market afterwards. Transitional periods apply to contracts and equipment that were already in place.

Does the law apply to my online store?

If you sell online to consumers, that is an e-commerce service and the requirements apply, whatever you sell. If you sell exclusively to businesses, they do not. Microenterprises that provide services are exempt.

We have fewer than ten employees. Are we exempt?

If you provide services and your turnover or balance sheet total stays under two million euro, you are exempt. If you deal in products, that exemption does not apply and you have to meet the requirements.

Which standard does our website have to meet?

The European standard EN 301 549, which points to WCAG for websites and apps. The version published so far adopts WCAG 2.1 level AA; a revision adopting WCAG 2.2 is in preparation. 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?

Six regulators, split by sector. For online stores and electronic communications that is the ACM. It 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. As a service provider you renew it at least every five years. If you receive external funding to improve accessibility, that option falls away.

Do you help with fixing it as well?

Yes. We audit where your site stands, fix what is wrong in the site you already have, and record in a report what was checked and resolved.