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.

The largest group is e-commerce: 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.

The service itself gets no transition period. The products around it do: supporting products that do not yet comply, such as a modem supplied with an internet subscription, only have to be replaced by 28 June 2030 according to the ACM. The transitional rules for running service contracts and for self-service terminals sit in Article VIII of the Dutch implementing act, and that article expressly does not apply to 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 they need
• 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 it does not apply

The first thing that keeps you out of scope 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 euro. The ACM summarises this on its site without mentioning the balance sheet. If you fall between the two, go by the wording of the law and record what you based your position on.

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 the evidence runs through an EU declaration of conformity and CE marking, not through the statement this page is about.

The second 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.

A few parts of a site that is covered do not have to comply either. Name them in your statement and it is clear why they sit outside the testing.

• Video and audio you published before 28 June 2025
• Office files such as PDF and Word from before 28 June 2025
• Navigation maps, provided the route is also given in accessible text
• Archive pages you no longer update after 28 June 2025
• Third-party content you did not commission, do not pay for and do not control

What belongs in it

Start with the service, not with the standard. 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, with a keyboard alone, or with enlarged text.

Then add how you test and how you keep it accessible: who reviews a change, and against what. Annex V also asks for information showing that the delivery process and its monitoring keep the service accessible, not just the result of a single test.

The statement has to be easy to find and accessible itself. A link in the footer to a plain HTML page will do. A PDF usually won't. 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

The European standard is EN 301 549. It adopts the WCAG guidelines and extends them to hardware, documents and customer support, among other things. The version cited in the Official Journal of the EU is V3.2.1, and for websites and apps it points to WCAG 2.1 level AA. 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. WCAG 2.2 adds six success criteria at level A and AA: help in the same place on every page, data you do not have to enter twice, focus that is not hidden behind a bar, alternatives to dragging, the size of click targets, and signing in without a memory test. One criterion from 2.1 was dropped.

An audit or certification is not mandatory. The ACM says so plainly: no proof of inspection is required, and no certificate, label or seal either. An audit does give you the answer you need, which is what you can honestly put in the statement.

How it differs from the government statement

Search for an accessibility statement in Dutch and you almost always land on DigiToegankelijk. That is a different statement, from a different law, for public bodies: it follows from Directive (EU) 2016/2102, uses a fixed template, sits in the public register at toegankelijkheidsverklaring.nl and is given a status there.

For businesses that register does not exist. 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

The act allows two exceptions. Meeting a requirement would change your service so much that it becomes a different service (fundamental alteration), or the cost is out of proportion to the benefit for people with disabilities (disproportionate burden). You still have to meet every other requirement.

You have to substantiate the claim and record the assessment in a document, against the criteria in Annex VI of the directive. The ACM does not need to receive that reasoning up front, but it can ask for it, so keep it ready.

The directive also requires you to keep the results for five years, counted from the last time the service was provided, and to renew the assessment whenever the service changes, at the request of the supervisory authority, and in any case at least every five years. If you receive outside funding to improve accessibility, the disproportionate burden exception is off the table. A shortage of time or knowledge does not count, according to the ACM.

E-commerce and electronic communications services also carry a duty to report. Anything you cannot fix straight away goes 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. Other sectors have their own supervisory authorities: the AFM for banking and financial services, the Commissariaat voor de Media for e-books and audiovisual media services, the RDI for products, the ILT for passenger transport and the Inspectie JenV for the 112 emergency number.

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)