What the ACM has done so far
The accessibility act has applied since June 2025, and the question that followed was whether anyone would actually enforce it. That question now has an answer with dates on it.
- First check
- 24 March 2026: 61 percent of the largest Dutch online stores not accessible
- ACM
- One year in
- 22 June 2026: of a hundred stores tested, two comply fully
- NOS, based on ACM and Level Level
- What is running now
- The ACM visited the ten worst performers and tests again after three months
- ACM, June 2026
- Maximum fine
- 900,000 euros or one percent of annual turnover
- depending on severity and repetition
The timeline
The act took effect on 28 June 2025. The ACM was designated as the supervisor for e-commerce services, and in the run-up it called on companies to prepare.
On 24 March 2026 the ACM published the result of a large-scale check on the biggest Dutch online stores: 61 percent turned out not to be accessible to people with a disability. In practice that often meant somebody could not complete an order.
On 22 June 2026, almost a year after the act, the follow-up arrived: of a hundred stores tested, more than half had problems, and two were fully in order. The ACM visited the ten stores with the biggest problems and gave them three months, after which it tests again.
How the ACM works
The pattern in this first round is not that fines land immediately. The supervisor tests, points out the improvements to the worst performers, and gives them a period to fix it. Enforcement only comes into view if it is still not in order after that.
The instruments available then: a fine or an order subject to a penalty payment. The maximum fine under this act is 900,000 euros or one percent of annual turnover, depending on severity and whether it is a repeat.
What that means for a smaller company: the chance of being written to in the first round is small, because the ACM started with the largest stores. The obligation itself does not depend on your size, and the second round has not been announced as the last.
Why it stalls at most companies
The ACM gives a reason itself: many online stores have plans but lack time, budget or knowledge. That matches what we see. Accessibility is not a separate item you add at the end, which makes it hard to plan alongside the ordinary work.
The result is a lot of scanning and little fixing. A scan produces a list, and then half of that list turns out to sit in the code of the theme rather than in the content. That is where it stops.
What you can do now
Measure where you stand first, because without that every conversation about this is an estimate. An automated test is free and points out the first items; it does not find everything, because part of the requirements is about whether something can be operated rather than whether the code is right.
Then write down what you are going to fix and when. That document is what the ACM asks for if they come knocking, and it is also what a client or a municipality wants to see in a procurement process.
Sources
- ACM: most large online stores unusable for customers with a disability (24 March 2026, in Dutch)
- NOS: online stores more accessible for partially sighted users, but much still to do (22 June 2026, in Dutch)
- ACM calls on companies to prepare for the rules (in Dutch)
- Dutch implementing act on accessibility requirements for products and services (in Dutch)
Frequently asked questions
When does the ACM test again?
The three-month period ran from June 2026, so the retest falls in autumn 2026. The outcome is not known at the time of writing; we update this page as soon as it is.
We are a small online store. Will the ACM come to us?
Not in this round: the check covered the largest Dutch online stores. The obligation does not depend on your size, though, and no end to the supervision has been announced.
Do we get a warning before a fine?
That is how the ACM has worked so far: first the improvements and a deadline, then enforcement. It is not a guarantee, because the act does not put it that way.
Does an accessibility statement on our site help?
For a commercial company it is not required in the same form as for a public body, but information about the accessibility of the service does have to be available. Our page on the statement covers what belongs in it.
Two out of a hundred comply. Is the requirement not too strict?
That is not an argument the ACM accepts, and it is not what the figures show either: the stores that do have it in order show that it can be done. What the figures do show is that most companies started late.