Writing an accessibility statement for a business

When your business needs one

The act lists the services it covers. If you provide one of them to consumers and you are not a microenterprise, the obligation has applied since 28 June 2025.

E-commerce covers any website or app where a consumer can buy, rent, order, book or sign up for something. It counts even if only part of your site works that way, if the offering comes from other sellers, or if the consumer pays with data rather than money.

The obligation is yours as the provider, even when another agency built the site.

According to the ACM, the service itself gets no transition period. The article on whether you have until 2030 explains what the date 28 June 2030 in Article VIII of the Dutch implementing act does cover. Article VIII itself expressly excludes e-commerce services.

• E-commerce services: online stores, booking platforms, ordering and reservation apps, signing up for subscriptions
• Electronic communications services: internet, telephony, email, chat and video calling
• Consumer banking services and financial e-commerce services
• E-books and the software dedicated to them
• Services providing access to audiovisual media services
• Parts of air, bus, rail and waterborne passenger transport: websites, apps, e-tickets and travel information. For urban, suburban and regional transport only the self-service terminals count

When you do not need one

The first criterion is the size of your business. For e-commerce services, Article 6:230fc of the Dutch Civil Code states that the obligation does not apply to enterprises with fewer than 10 employees and an annual turnover or annual balance sheet total of at most € 2 million. How to count staff and turnover is explained in the article on whether your online store falls under the act.

That exemption covers services only. If you manufacture, import or sell products covered by the act, such as e-readers, payment terminals or consumer terminal equipment for internet and television, it does not apply. For products, compliance is shown with an EU declaration of conformity and CE marking. The statement this page is about applies to services only.

The second criterion is the nature of the service. A site that only presents your company and your work, with nothing a visitor can sign up for, is not an e-commerce service. The same goes for services you supply exclusively to other businesses: the act covers services provided to consumers. Outside the act you may still publish a statement.

Even on a site that is covered, a few parts are excluded, such as pre-recorded video and office files from before 28 June 2025. Name them in your statement and it is clear why they sit outside the testing; the full list is in the article on the accessibility act.

What belongs in it

First describe what someone does on your site, from searching and choosing to signing in, signing and paying, and for each step how that works with a screen reader or with a keyboard alone.

Then add how you test and how you keep it accessible: who reviews a change, and against what.

The statement has to be easy to find and accessible itself. A link in the footer to a plain HTML page will do. The Dutch regulator ACM adds that you also offer the information orally, for instance as an audio recording of the text, and that your customer service must be able to answer questions about accessibility.

• Which parts do and do not comply, named as parts rather than as a score
• Where someone can report a problem and what you do with it
• The date on which you last reviewed the statement
• Any exception you rely on, and the parts it applies to

The standard you test against

In practice the yardstick is the European standard EN 301 549, version V3.2.1, which points to WCAG 2.1 level AA for websites and apps. The ACM applies that same requirement and states that WCAG 2.2 level AA becomes the new standard during 2026.

Anyone building or rebuilding now can allow for that; the article on WCAG 2.2 covers what it adds.

According to the ACM, no proof of inspection is required, and no certificate, label or seal either. An audit does show what you can put in the statement.

How it differs from the government statement

Search for an accessibility statement in Dutch and you soon land on DigiToegankelijk. That is a different statement, for public bodies.

Adopt the government template and your statement will point to a status from a register you are not in, and to a law that does not apply to you.

If you rely on an exception

What fundamental alteration and disproportionate burden mean, and what you record and keep when you rely on them, is set out in the article on the accessibility act. According to the ACM, a shortage of time or knowledge does not count.

E-commerce and electronic communications services also carry a duty to report. You report anything you cannot fix straight away to the ACM: within one week for critical and serious problems, within one month for moderate and minor ones, with a plan attached. Reliance on an exception is reported as well.

Sources

• Directive (EU) 2019/882, Article 13 and Annex V
• Dutch Civil Code Book 6, section 2ab on e-commerce services (in Dutch)
• Dutch implementing act, Article VIII on transitional measures (in Dutch)
• ACM: accessibility of e-commerce and electronic communications services
• DigiToegankelijk: the accessibility statement for public bodies (in Dutch)