The EAA in Belgium: what your online shop must do
In short
In Belgium, the European Accessibility Act is applied by the Law of 5 November 2023, which inserts it into the Code of Economic Law, in force since 28 June 2025. If you sell online to Belgian consumers — even from abroad — you are very likely covered. Key points:
- there is no standalone Belgian « accessibility law »: the obligation is embedded in the Code of Economic Law (obligations in Book VIII, penalties in Book XV);
- e-commerce is a federal service, supervised by the Economic Inspectorate of the FPS Economy;
- breaches carry a level 2 penalty (up to €80,000), raised to a level 3 (up to €200,000) in cases of bad faith;
- the technical target remains EN 301 549, which incorporates WCAG 2.1 level AA; you must also publish accessibility information about your service.
Belgium is a dense, bilingual e-commerce market and an immediate neighbour of France and the Netherlands: many foreign shops sell there without a second thought. Since 28 June 2025, accessibility is no longer optional. The Belgian particularity is not a loud new statute: it is the way the obligation was lodged inside the Code of Economic Law and split according to the country's federal structure — while remaining, for an online shop, remarkably simple to pin down. Here is what changes in practice.
Which law: the Code of Economic Law
The Belgian transposing text is the Law of 5 November 2023 (published in the Belgian Official Gazette on 28 November 2023), which applies Directive (EU) 2019/882, the European Accessibility Act, « as regards certain services ». In French it is the loi du 5 novembre 2023; in Dutch the wet van 5 november 2023 (often nicknamed Toegankelijkheidswet). It plays the same role in Belgium as Ordinance No 2023-859 does in France.
Its distinctive feature: it is a law that does not create a standalone accessibility code. Instead of a separate text you could search for, it amends the Code of Economic Law (CEL) to insert the accessibility requirements — the obligations in Book VIII (Articles VIII.59 et seq.) and the penalty regime in Book XV. So do not look for « the Belgian accessibility law »: the obligation that concerns you lives inside the Code of Economic Law.
The Belgian particularity: a fragmented transposition… except for e-commerce
Because the directive touches competences that, in Belgium, are shared between the federal State, the Regions and the Communities, its transposition was partial and spread across several texts and authorities. Each level of power transposes the part it is responsible for: the Communities for audiovisual media services, the Regions for certain self-service transport terminals, the FPS Interior for emergency communications (112), the BIPT for electronic communications.
Good news for an online shop: e-commerce is a purely federal competence. You do not have to work out which Region or Community supervises you — unlike the decentralised Spanish model. For an online shop there is a single, clear counterpart: the FPS Economy.
The technical standard: EN 301 549 / WCAG 2.1 AA
Belgium does not reinvent the technical criteria. As across the Union, a service's conformity is presumed when it meets the harmonised standards whose references are published in the Official Journal of the European Union. For web services, the relevant harmonised standard is EN 301 549, which incorporates the Web Content Accessibility Guidelines (WCAG) 2.1, level AA.
In practice, the requirements are the same as elsewhere in Europe: sufficient colour contrast, text alternatives for images, keyboard navigation, correctly labelled forms, a page structure readable by assistive technology. For e-commerce, the law further stresses the accessibility of the identification, security and payment functions. A site already designed for WCAG 2.1 AA satisfies the core of the law.
How much: the Code of Economic Law penalty regime
This is where the Belgian model stands out: it creates no bespoke « EAA fine » but attaches the breach to the existing penalty scale of Book XV of the Code of Economic Law. For services (including e-commerce), Article XV.101/1 punishes breaches of the accessibility obligations with a level 2 penalty, raised to level 3 in cases of bad faith. After the additional décimes (an ×8 multiplier specific to Belgian criminal law), that gives:
| Penalty level | Amount (cap) | When |
|---|---|---|
| Level 2 penalty | up to €80,000 | breach of the accessibility requirements (or, per the FPS, up to 4% of annual turnover) |
| Level 3 penalty | up to €200,000 | in cases of bad faith (or, per the FPS, up to 6% of annual turnover) |
Who enforces? The Economic Inspectorate (FPS Economy)
For e-commerce and consumer banking services, the competent regulator is the Economic Inspectorate of the FPS Economy (French: Inspection économique, SPF Économie; Dutch: Economische Inspectie, FOD Economie). It is a federal, single-level supervision: unlike Spain's autonomous-community model, no Region shares oversight of online shops.
An investigation can be triggered by a report — for example a disabled person unable to complete a purchase — via the public portal ConsumerConnect (consumerconnect.be), which forwards complaints to the Economic Inspectorate. The authority can also act on its own initiative and, beyond a fine, impose corrective measures to force compliance.
The mandatory document: accessibility information
Beyond technical accessibility, the service provider must provide information on the accessibility of its service, to be included in its general terms and conditions or an equivalent document, explaining how the service meets the applicable accessibility requirements. This obligation flows directly from the directive (Article 13 and Annex V) and is carried over into Belgian law. In Belgium it is published in Dutch or French, in an accessible format, and must be kept up to date for as long as the service is provided.
As in France, this document is immediately verifiable: an inspector does not need to audit dozens of technical criteria to note that it is missing. It is the easiest breach to establish.
The mistake to avoid: « one-click accessibility » overlays
Widgets such as accessiBe or UserWay promise automatic compliance via a single line of code. They do not make you compliant. Their real effectiveness is contested by disability organisations; in the US, the FTC fined accessiBe one million dollars in 2025 over compliance claims found to be misleading. Above all, an overlay does not fix your site's source code and does not produce the required accessibility information.
The defensible path is the opposite: audit the site, fix what can be fixed, and publish honest accessibility information documenting the actual state and the action plan.
How to comply, in practice
- Audit. An automated technical scan (WCAG 2.1 AA) detects part of the non-conformities — contrast, image alternatives, structure, forms. It does not replace a full manual audit, but it establishes a factual, quantified baseline.
- Fix the priority points — often few and inexpensive (colour contrast, form labels, keyboard navigation).
- Publish the accessibility information, with an accurate conformity status and contact channels.
- Keep it up to date: conformity degrades with every deployment. A periodic re-scan avoids drift.
Check your exposure in 2 minutes
DeclareAccess scans one page of your site (WCAG 2.1 AA), returns a quantified report of the non-conformities, then generates the ready-to-publish accessibility document — Belgian model (accessibility information NL/FR), French (RGAA), German (BFSG), Italian (Allegato IV), Spanish (Art. 13) or Dutch. Free audit, no credit card.
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Frequently asked questions
I sell into Belgium from abroad: am I covered?
Yes, very likely. The obligation follows the market targeted, not the country of the registered office. As soon as you offer products or services to consumers in Belgium, your activity falls under the Belgian regime from the Law of 5 November 2023 for that market. A multi-country shop accumulates the corresponding national regimes.
Why can't I find « the Belgian accessibility law »?
Because it does not exist as a standalone text. The Law of 5 November 2023 amends the Code of Economic Law to insert the obligations (Book VIII) and the penalties (Book XV). The obligation concerning your online shop lives inside the Code of Economic Law, not in a separate accessibility code.
Does Belgian law ask for anything different from WCAG?
Not on the technical substance. Conformity is presumed for a service that meets the European harmonised standards; for the web, the relevant standard is EN 301 549, which incorporates WCAG 2.1 level AA. The difference lies in the mandatory document (accessibility information), the regulator (the Economic Inspectorate) and the Code of Economic Law penalty regime.
Is my small online shop covered?
Belgium excludes from its scope, until 28 June 2030, micro-enterprises providing services with fewer than 10 people and annual turnover or balance sheet not exceeding €2M. If you exceed either threshold, you are covered now. The exemption works differently for products. When in doubt, an audit gives you a factual answer about your site's state, regardless of status.
How large is the fine in Belgium?
Breaches of the service accessibility obligations carry a level 2 penalty under the Code of Economic Law — up to €80,000 after additional décimes (or, per the FPS Economy, up to 4% of turnover) — raised to level 3 in cases of bad faith, i.e. up to €200,000 (or 6% of turnover). These caps target the most serious breaches and are not automatic; the Economic Inspectorate can also impose corrective measures.
Who enforces accessibility for my online shop in Belgium?
For e-commerce, it is the Economic Inspectorate of the FPS Economy (Inspection économique / Economische Inspectie), at federal level. Electronic communications fall under the BIPT and audiovisual media under the Communities, but for an online shop the single counterpart is the Economic Inspectorate. A consumer can report a non-compliant site via the ConsumerConnect portal.
Does an overlay (accessiBe, UserWay) make me compliant?
No. An overlay adds a widget whose effectiveness is contested, does not fix the source code and does not produce the required accessibility information. The compliant approach is to audit the site, fix the non-conformities and publish honest accessibility information.