Does my online store fall under the accessibility act?

Question 1: do you sell online to consumers?

The act calls your store an e-commerce service: a service provided at a distance, through a website or a mobile app, by electronic means and at the individual request of a consumer, with a view to concluding a contract. A booking or a subscription taken out online counts just as much as a shopping basket does.

Consumer here means a natural person buying the service for purposes outside their trade, business, craft or profession. If you sell to business customers only, you do not provide an e-commerce service to a consumer and article 6:230fb does not apply. If you sell to both, the consumer side counts and your store falls under the act.

What you sell makes no difference to this question. The directive states explicitly that the requirements for e-commerce services apply to the online sale of any product or service.

A website with no way to order is not an e-commerce service. If you do provide one of the other services listed in the act, separate rules apply to it, online store or not.

Question 2: are you a microenterprise?

The exemption sits in article 6:230fc(1) of the Dutch Civil Code: article 230fb does not apply to enterprises with fewer than 10 employees and an annual turnover or an annual balance sheet total of no more than € 2 million. If you stay below those limits, the act sets no requirements for your store and you have nothing to document or report.

Note how this differs from the rule of thumb the ACM publishes, which mentions turnover only: according to the regulator the obligations apply once you have ten or more staff and/or an annual turnover above € 2 million. The legislation says turnover or balance sheet total. If you are near the limit, get legal advice on your situation.

The act itself does not say how to count. Recital 53 of the directive points to Recommendation 2003/361/EC, the European definition of small and medium-sized enterprises. Four counting rules follow from it.

• You use the last closed financial year.
• People are counted in annual work units: two half-time jobs make one. Owner-managers count, apprentices and students on a training contract do not.
• If another enterprise holds 25 percent or more of your capital or voting rights, its figures count pro rata. Where there is control, such as a majority of the votes, they count in full.
• You only lose microenterprise status once you cross a limit in two consecutive financial years.

Question 3: do you also sell products the act lists?

Article 4(5) of the directive exempts microenterprises providing services from the accessibility requirements and from any obligation relating to compliance with them. The directive has no such provision for microenterprises dealing with products. They only get lighter administrative rules.

Your online store is a service. What you sell may be a product the act lists: general purpose computer hardware for consumers and its operating systems, including desktops, laptops, smartphones and tablets; e-readers; payment terminals, cash machines, ticketing machines, check-in machines and interactive information kiosks; consumer terminal equipment for electronic communications such as modems and routers; and equipment for accessing audiovisual media services, such as smart TVs and set-top boxes.

If you sell such devices, you are a distributor. You check that the product carries the CE marking, that the required documents are included and that the instructions and safety information are in Dutch. If you suspect a product does not conform, you hold it back until it does, and you inform the manufacturer or importer and the authorities. Those duties concern the device itself and place no requirements on your website.

They also apply only to products placed on the market after 28 June 2025; older stock falls outside them.

Question 4: do you provide another service from the act?

The act covers six kinds of service. If you provide more than one, it applies per service and the supervisory authority may differ.

The microenterprise exemption covers all of them.

• E-commerce services: selling online to consumers
• Consumer banking services
• Electronic communications services, such as internet, telephony, email and chat
• Services providing access to audiovisual media services
• E-books and the software dedicated to them
• Air, bus, rail and waterborne passenger transport: websites, apps, electronic tickets, travel information and interactive self-service terminals

What the act then asks of your store

If your store falls under the act, you design and provide the service in line with Annex I, sections III and IV(g), and Annex V of the directive. For e-commerce this adds two specific requirements: passing on information about the accessibility of what you sell where the responsible manufacturer or supplier provides it, and making identification, security, electronic signature and payment perceivable, operable, understandable and robust.

Part of your site stays outside the requirements, such as pre-recorded video and office files from before 28 June 2025; the full list is in the article on the accessibility act.

On top of that you explain, in your terms and conditions or an equivalent document, how the service meets those requirements. That is Annex V, and it is a separate obligation even when your site is technically sound. If your service is not fully accessible yet, the ACM asks you to report that to it, with a plan attached.

The act names no WCAG version. In practice the yardstick is EN 301 549, the European standard for accessible ICT. Version V3.2.1 from 2021 adopts WCAG 2.1 level AA for websites and apps, and the ACM points to that level itself. The successor V4.1.1, based on WCAG 2.2, came out in September 2026; for this act neither version is cited in the Official Journal yet.

According to the ACM there is no transition period for the service itself. The article on whether you have until 2030 explains what the date 28 June 2030 in the act does cover.

Exceptions and supervision

The act makes an exception where meeting the requirements would alter the basic nature of the service or impose a disproportionate burden. That exception applies per element; a disproportionate burden is argued against the criteria in Annex VI of the directive. You still meet the rest of the requirements.

If you rely on it, you report that to the ACM; what you also have to record and keep is set out in the article on the accessibility act. Microenterprises go through none of this: they are already exempt.

The ACM supervises online stores; the same article lists the regulators for the other sectors. Consumers can report an accessibility problem with an online store to the ACM.

In the tests the ACM published in March 2026, placing an order with assistive technology proved impossible at 61 percent of around one hundred large online stores; the article on what the ACM has done so far covers what happened next.

Sources

• Articles 6:230fa to 6:230fd of the Dutch Civil Code (wetten.overheid.nl, Dutch)
• Directive (EU) 2019/882 on the accessibility requirements for products and services (EUR-Lex)
• Recommendation 2003/361/EC: the European definition of a microenterprise (EUR-Lex)
• ACM: accessibility of e-commerce services and electronic communications services
• ACM: most large online stores are out of reach for customers with a disability (March 2026, Dutch)
• Dutch Equal Treatment on the Grounds of Disability or Chronic Illness Act (Dutch)