What the ACM has done so far
The accessibility act has applied since June 2025. Since then the ACM has tested the largest online stores and visited the ten worst performers.
- First check
- 24 March 2026: 61 percent of the largest Dutch online stores not accessible
- ACM
- One year in
- 22 June 2026: of the 300 largest online stores, two have their site and app fully accessible to partially sighted customers
- NOS, based on Level Level
- Retest
- The ACM visited the ten worst performers and tests again after three months
- NOS, 22 June 2026
- Maximum fine
- 900,000 euros or, if higher, one percent of annual turnover
- article 2.15 of the Dutch Consumer Protection Enforcement Act
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 check on around a hundred of the biggest Dutch online stores: at 61 percent, a customer with a visual impairment could not place an order.
On 22 June 2026 the NOS reported that the ACM had visited the ten stores with the biggest problems and would test again after three months.
How the ACM works
In this first round the ACM tested and showed the worst performers what they need to improve. Companies that then fail to improve enough risk enforcement.
The ACM can then impose a fine or an order subject to a penalty payment.
Why most companies do not comply yet
According to the ACM, companies often cite a lack of time, money or technical knowledge, and uncertainty about what the rules require.
An automated scan produces a list of errors. Part of that list is often in the code of the theme rather than in the content, and fixing those errors takes a developer.
What you can do now
First establish to what extent your site meets the requirements. An automated test is free and finds the first errors. Some of the requirements concern whether the site can be operated, and you test those by hand.
Then write down what you are going to fix and when.
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?
On 22 June 2026 the NOS reported that the ACM would test again after three months. As of 30 September 2026 the ACM had not published the outcome.
We are a small online store. Can the ACM check us as well?
The checks so far covered the largest Dutch online stores. The obligation does apply to a small online store, unless it is a microenterprise.
Do we get a warning before a fine?
So far the ACM has first told companies what to improve and given them a deadline; those that then fail to improve risk enforcement. The act does not prescribe that order.
Does the ACM also look at an accessibility statement?
For a company covered by the act it is required: the ACM asks for a statement on your website and in your app explaining how your service meets the requirements. Our page on the statement covers what belongs in it.
Two of the 300 largest online stores comply. Is the requirement not too strict?
If compliance would impose a disproportionate burden, the act allows an exception, but a company relying on it has to assess and document that itself.