Digital accessibility for businesses

The European Accessibility Act (EAA)

What is the EAA?

The European Accessibility Act (Directive (EU) 2019/882) sets accessibility requirements for products and services that consumers in the EU use every day, from webshops and banking apps to e-books and ticket machines. It has applied since 28 June 2025. In the Netherlands it is implemented through the Implementatiewet toegankelijkheidsvoorschriften producten en diensten, which amends among others the Warenwet, the Wft, the Burgerlijk Wetboek and the Telecommunicatiewet.

Why is the EAA important?

In an increasingly digital world, accessibility is not a luxury but a necessity. The EAA ensures that essential digital services and products are accessible to all EU citizens, regardless of their physical or cognitive capabilities. This not only promotes social inclusion but also creates equal opportunities in education, employment, and daily life.

Which organizations must comply with the EAA?

The EAA applies to businesses that offer these products or services to consumers in the EU. Microenterprises that provide services (fewer than 10 persons and an annual turnover or balance sheet total not exceeding €2 million) are exempt; microenterprise manufacturers of products are not.

• E-commerce: webshops and online ordering
• Consumer banking and financial services (supervised by the AFM)
• Electronic communications and telecom services (ACM)
• Passenger transport services by air, bus, rail and water (ILT)
• E-books, audiovisual media services (Commissariaat voor de Media) and computers, e-readers and self-service terminals (RDI)

Which services and products fall under the EAA?

The legislation covers a broad spectrum of digital services and products:

• Banking and financial services
• E-commerce platforms and webshops
• Payment terminals and digital payment systems
• Mobile devices and smartphones
• Digital reading devices and e-books
• Television services and digital reception equipment
• Streaming services (such as video and music platforms)
• Mobility equipment and transport-related services
• Telecommunications

How to comply with the EAA?

For websites and apps the cited standard today is EN 301 549 V3.2.1, which references WCAG 2.1 level AA. V4.1.1, based on WCAG 2.2, was published in September 2026 and will replace it once cited in the Official Journal of the EU. We audit against WCAG 2.2 AA, which covers 2.1, so you do not redo the work. A WCAG-EM audit shows where your service stands today and which fixes are needed. Service providers must also publish, in an accessible way, how their service meets the requirements.

Planning and implementation

The requirements have applied since 28 June 2025. There is no transitional period for services themselves: only products lawfully in use before that date may continue to be used until 28 June 2030, service contracts signed before 28 June 2025 may run unchanged for at most five years, and self-service terminals for up to 20 years. In the Netherlands the Implementatiewet toegankelijkheidsvoorschriften producten en diensten entered into force on 28 June 2025 (royal decree of 9 November 2024, Stb. 2024, 341).

Supervision and enforcement in the Netherlands

The ACM supervises e-commerce and electronic communications, the AFM supervises banks and other financial firms, and the RDI, the Commissariaat voor de Media and the ILT cover products, e-books and audiovisual media, and passenger transport. Non-conformities must be reported to the supervisor: within one week when the impact is critical or serious, within one month when it is moderate or minor, unless they have already been fixed.

On 24 March 2026 the ACM published a study of about 100 of the largest webshops and telecom and energy sites: 61% were not accessible and 33% had serious problems. The ACM said it will approach the under-performers and enforce. The AFM announced a compliance investigation in April 2026. Under the Wet handhaving consumentenbescherming, fines can run into the hundreds of thousands of euros.