Does my website have until 2030?
The act names 28 June 2030, and that date is sometimes cited as a reason to put off changes. According to the ACM, the service itself has no transition period.
- The service itself
- Has had to comply since 28 June 2025, with no transition period
- ACM, accessibility of e-commerce services
- What 2030 covers
- Contracts concluded before 28 June 2025, and products already in use at that point
- Article VIII of the implementing act
What the act says about the service
The accessibility requirements apply to services provided to consumers, and they have applied since 28 June 2025. The implementing act includes no transition period for the service itself, and according to the ACM an online store that currently sells to consumers already has to meet the requirements.
What 28 June 2030 is about
The transitional provision covers two situations that already existed when the act took effect. First, service contracts concluded before 28 June 2025 may run on unchanged until they expire, and at the latest until 28 June 2030. That rule concerns the contract and does not extend to the website on which it was concluded.
Second, a service provider may keep using, until 27 June 2030, products it lawfully used before then for comparable services, such as a payment terminal or a modem supplied with a subscription.
The transitional provision for e-commerce services
The Dutch transitional provision for e-commerce services sits in the Overgangswet nieuw Burgerlijk Wetboek and is open to more than one reading. We consider the reading without extra time the most likely one, and it is also the position of the ACM.
If someone tells you that you have more time, ask which provision that rests on and get legal advice on it.
Where the 2028 date comes from
The year 2028 is also cited, but it has a different origin. Public bodies have been under accessibility rules for longer, with their own obligations around a published accessibility statement and their own dates. That regime does not apply to a commercial company.
If a page says existing websites have until 2028, ask for the source and check it against the legislation.
Does your company fall under the act?
If your company falls under the act, the question is to what extent your site already meets the requirements, and that can be measured.
If your company does not fall under it, that may be because you are a microenterprise providing services: fewer than ten employees and an annual turnover or balance sheet total of at most two million euros. That exemption covers services and not products, and you only lose it once you cross a limit in two consecutive financial years.
Sources
Frequently asked questions
Our site predates 28 June 2025. Does the requirement still apply?
According to the ACM, the requirement applies to the service you offer now, whenever the site was built. Some content does not have to be adapted, such as pre-recorded video and office files you put online before 28 June 2025.
We signed a contract with a web developer in 2024. Does that give us more time?
That contract does not fall under the transitional provision, which covers agreements with your customers rather than your own purchasing. You can change the agreement with your developer so that it covers accessibility.
Which regulator checks this?
The ACM supervises e-commerce services.
What is the maximum fine?
For this act it is 900,000 euros or, if higher, one percent of annual turnover.
Can we check this ourselves?
Start with an automated test: it costs nothing and points out the first problems. The remaining requirements need someone to go through the site with a keyboard and a screen reader.