EAA in the Netherlands: what your online shop must do
In short
In the Netherlands the European Accessibility Act is applied through the Implementatiewet toegankelijkheidsvoorschriften producten en diensten (Implementation Act on accessibility requirements for products and services), in force since 28 June 2025. If you sell online to Dutch consumers — even from abroad — you are very likely covered. Key points:
- there is no single Dutch accessibility law: the implementation act grafts the duty onto existing statutes (Commodities Act, Civil Code, Telecommunications Act);
- e-commerce is a covered service, supervised by the ACM (Netherlands Authority for Consumers and Markets);
- the ACM can impose administrative fines up to a general ceiling of €900,000 (or, if higher, a percentage of turnover);
- the technical target remains EN 301 549, which incorporates WCAG 2.1 level AA; you must also publish accessibility information about your service.
The Netherlands is one of Europe's most mature e-commerce markets — and one where buyers routinely shop in English. If you sell here, accessibility is no longer optional. The Dutch quirk: unlike Spain (Ley 11/2023) or Italy (D.Lgs. 82/2022), there is no single text you can search for. The obligation lives inside existing sector laws. Here is what actually changes.
Which law: the Implementatiewet
The Dutch transposing law is the Implementatiewet toegankelijkheidsvoorschriften producten en diensten. It applies Directive (EU) 2019/882, the European Accessibility Act, in the same way France's Ordonnance n° 2023-859 does. The Eerste Kamer (Dutch Senate) adopted it on 2 April 2024 and it entered into force on 28 June 2025, in line with the EU timetable.
Its distinctive feature: it is a framework act that does not create its own accessibility code. Instead of a standalone text, it amends existing laws to insert the accessibility requirements: the Warenwet (Commodities Act) for products, the Telecommunicatiewet for telecoms, and the Burgerlijk Wetboek (Civil Code) for services supplied to consumers, including e-commerce. So don't look for "the Dutch accessibility law": the duty that concerns you sits in the Civil Code and the regulations made under it.
The technical standard: EN 301 549 / WCAG 2.1 AA
The Netherlands does not reinvent the technical criteria. As everywhere in the Union, a service is presumed conformant when it meets the harmonised standards whose references are published in the EU Official Journal. For web services the relevant harmonised standard is EN 301 549, which incorporates the Web Content Accessibility Guidelines (WCAG) 2.1, level AA.
Concretely, the requirements are the same as elsewhere in Europe: sufficient colour contrast, text alternatives for images, keyboard navigation, properly labelled forms, a page structure readable by assistive technology. For e-commerce, the law places extra emphasis on the accessibility of identification, security and payment functions. A site already built for WCAG 2.1 AA meets the heart of the law.
How much: the penalty regime (ACM enforcement)
This is where the Dutch model stands out. Supervising the accessibility of e-commerce services falls to the Authority for Consumers and Markets (ACM) — a single administrative regulator with a strong track record of enforcing online conduct. The ACM holds an administrative sanction power whose general ceiling, set by Dutch law, is:
| ACM measure | Amount (ceiling) | Nature |
|---|---|---|
| Administrative fine (bestuurlijke boete) | up to €900,000 | or, if higher, a percentage of turnover |
| Order under penalty (last onder dwangsom) | amount per day of delay | compels a fix; the penalty runs until you comply |
Who supervises? The ACM (and sector regulators)
For e-commerce, the competent regulator is the ACM. The Dutch landscape splits supervision by sector: banking and financial services to consumers fall under the AFM (Netherlands Authority for the Financial Markets), electronic communications under the telecoms regulator (RDI). This is clearer than Spain's decentralised, region-by-region model: for an online shop the point of contact is unambiguous — it is the ACM.
Supervision can be triggered by a complaint — for example a disabled person who cannot complete a purchase — as much as by the regulator's own initiative.
The mandatory document: the accessibility information
Beyond technical accessibility, the service provider must supply accessibility information about the service, to be included in its general terms or an equivalent document, explaining how the service meets the applicable accessibility requirements. This duty comes straight from the directive (Annex V) and is carried into Dutch law. It must be kept up to date for as long as the service is offered.
As elsewhere, this document is immediately checkable: an inspector doesn't 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 like accessiBe or UserWay promise automatic compliance from a single line of code. They do not make you compliant. Their real effectiveness is disputed by disability organisations; in the United States the FTC fined accessiBe one million dollars in 2025 over compliance claims found to be deceptive. 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 real state and the action plan.
How to comply, concretely
- Audit. An automated technical scan (WCAG 2.1 AA) catches part of the non-conformities — contrast, image alternatives, structure, forms. It doesn't replace a full manual audit, but it gives a factual, quantified baseline.
- Fix the priorities — often few and inexpensive (colour contrast, form labels, keyboard navigation).
- Publish the accessibility information, with an accurate conformance status and contact details.
- Keep it current: conformance degrades with every release. A periodic re-scan prevents drift.
Check your exposure in 2 minutes
DeclareAccess scans a page of your site (WCAG 2.1 AA), returns a quantified report of the non-conformities, then generates the ready-to-publish accessibility document — French (RGAA), German (BFSG), Italian (Allegato IV), Spanish (art. 13) or Dutch (toegankelijkheidsinformatie) model. Free audit, no credit card.
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Frequently asked questions
I sell into the Netherlands from abroad: am I covered?
Yes, very likely. The obligation follows the market you target, not where you are based. As soon as you offer products or services to consumers in the Netherlands, your activity falls under the Dutch regime of the Implementatiewet for that market. A multi-country shop stacks the corresponding national regimes.
Why can't I find "the Dutch accessibility law"?
Because it doesn't exist as a single text. The Implementatiewet toegankelijkheidsvoorschriften producten en diensten is a framework act that amends existing laws (the Commodities Act for products, the Civil Code for e-commerce services, the Telecommunications Act). The duty that concerns your shop sits in the Civil Code, not in a standalone accessibility code.
Does Dutch law require anything different from WCAG?
Not technically. Conformance is presumed for a service meeting the European harmonised standards; for the web that is EN 301 549, which incorporates WCAG 2.1 level AA. The difference lies in the mandatory document (accessibility information), the regulator (the ACM) and the Dutch penalty regime.
Is my small online shop covered?
If you have 10 people or more, or over €2 million in annual turnover or balance-sheet total, yes. Micro-enterprises below both thresholds that provide services are exempt from the accessibility requirements, but the exemption works differently for products. If in doubt, an audit gives you a factual answer about your site's state, regardless of status.
How large is the fine in the Netherlands?
The ACM can impose an administrative fine up to a general ceiling of €900,000 — or, if higher, a percentage of turnover. That ceiling targets the most serious breaches and is not automatic. For an online shop the most common lever is the order under penalty (last onder dwangsom): a sum per day for as long as the site is not fixed.
Who checks my online shop's accessibility in the Netherlands?
For e-commerce it is the ACM (Authority for Consumers and Markets). Financial services fall under the AFM and electronic communications under the telecoms regulator (RDI). Unlike Spain, there is no decentralised, region-by-region supervision: for an online shop the point of contact is the ACM.
Does an overlay (accessiBe, UserWay) make me compliant?
No. An overlay adds a widget whose effectiveness is disputed, 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.