EAA: what the European Accessibility Act means

The European Accessibility Act is EU legislation that aims to make products and services more accessible for people with impairments. The Dutch government summarises that consumers must be able to use websites and apps to buy, book or sign up for a service, including when they need a screen reader, keyboard or other assistive technology.

For websites this mainly means e-commerce services: web shops, booking platforms, reservation systems and online sign-up flows. If a visitor can buy or lock in a product or service on your site, that service is in scope. A purely informational brochure site without a transaction usually is not, but the line is the function, not the industry.

The EAA is not a Dutch invention. The Netherlands transposed the directive; supervision of e-commerce and electronic communication services sits with the Netherlands Authority for Consumers and Markets (ACM). For the broader context (government versus business, statements, practical approach), see our page on digital accessibility.

According to the ACM guidance, the accessibility duty applies to providers of e-commerce and electronic communication services with 10 or more employees, or with annual turnover above 2 million euros. Micro-enterprises below both thresholds are exempt. Count staff and turnover at group level when that is relevant for your organisation; the ACM looks at the business that offers the service.

Public bodies are not covered by the EAA as an extra layer. They have long been obliged under the government accessibility decree. Digitoegankelijk explains who that public duty covers: central government, provinces, municipalities, water boards and public-law bodies. In short: government via Digitoegankelijk, companies via the EAA.

Unsure whether your service is an e-commerce service? Look at the consumer task: can someone buy, book, reserve or enter into an agreement online? Then you are likely in scope. A portfolio without checkout is not. When in doubt, the ACM page on e-commerce services is the most concrete Dutch explanation.

The technical yardstick is WCAG level AA. In Europe, legislation refers to those criteria through EN 301 549. EN 301 549 is the broader European ICT standard (websites, apps, documents, hardware); for web content the WCAG success criteria are the relevant part. If you meet WCAG AA, you cover the part of EN 301 549 that matters for your website.

The ACM uses WCAG AA as the practical reading of the requirements for e-commerce services and advises working with WCAG 2.2 straight away. The differences with 2.1 are limited, but 2.2 adds criteria on focus, drag movements and touch targets that weigh heavily on phones. If you are building or rebuilding now, test against 2.2 AA; see also our explanation of WCAG.

Level AAA is not the legal default. AA is the practical norm. AAA sometimes asks for requirements that are unachievable across an entire site (for example sign language on all video). Only promise AAA for parts you can truly deliver.

The law requires your e-commerce service to be accessible and for you to document that. An accessibility statement explains how your service meets the rules, which parts still fall short, and how you handle feedback or reports. Place the statement somewhere easy to find, for example in the footer or a fixed link in the account menu.

A quality mark or external audit is not legally required. The ACM and Digitoegankelijk distinguish the legal duty (be accessible and declare) from voluntary quality labels. A sticker does not replace real accessibility; conversely, a label only shows that you met a test framework at a point in time.

In practice: publish an honest statement, measure the core tasks (search, product page, cart, checkout, account), fix blockers first, and re-test after releases. The statement documents status; it does not replace remediation work.

WebYes is not a legal auditor and does not replace a manual WCAG audit. What we do: automated checks against WCAG 2.2 AA within the accessibility pillar, alongside speed, security and mobile. Automated checks do not catch everything; roughly 30 to 50 percent of the criteria can be tested by a machine. They do find the failures visitors and regulators notice first: missing alt texts, low contrast, empty buttons, missing form labels.

The scan covers up to six pages per run. Choose the pages that matter most under the EAA: homepage, category, product detail, cart and checkout. The quality mark requires an average score of at least 80 and at least 60 per pillar. A site that drops below 60 on accessibility does not get GEKEURD status, even if the other pillars score high.

Use the scan as a starting point: measure where you stand, fix the blockers, then plan a manual check of checkout with keyboard and screen reader. That ties the EAA duty to concrete maintenance, not a one-off project week.