EAA: what the European Accessibility Act requires of your website

The European Accessibility Act (EAA) has applied since 28 June 2025. In the Netherlands the directive was transposed through the Implementatiewet toegankelijkheidsvoorschriften producten en diensten (implementation act), which entered into force on the same date. For websites and apps the EAA mainly affects e-commerce services: anything a consumer uses online to buy, order, rent, book or sign up for something. If your business has 10 or more employees or annual turnover above € 2 million, that service must be accessible. The ACM supervises. The technical yardstick right now is WCAG 2.1 level AA; the ACM expects WCAG 2.2 AA to become the new standard during 2026 and advises working with 2.2 already. A quality mark is not required; an accessibility statement is.

The term e-commerce service is broad. The ACM counts web shops, booking platforms, apps for meals or taxis and subscription websites. The duty also applies when only part of the site contains an offer, and to platforms with offers from other sellers. Even free offers count when consumers pay with personal data. You remain responsible, also when another company built your site or app. A site that only informs, with nothing to buy, book or sign up for, is usually outside scope.

The EAA is not a Dutch invention. The Netherlands transposed the directive; supervision of e-commerce and electronic communication services sits with the ACM. The Dutch government names web shops and websites for taking out a phone or internet subscription among its examples, and states that the accessibility requirements took effect on 28 June 2025. For the broader context (government versus business, statements, practical approach), see our page on digital accessibility. Want to know where you stand first? Scan up to six pages for free.

For services there is no transition period: the requirements have applied since 28 June 2025. What still follows is a new technical standard. This overview puts the dates and their status side by side.

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. A micro-enterprise, with fewer than 10 employees and annual turnover of at most 2 million euros, does not have to meet the legal requirements. For counting employees, for example with part-time or seasonal work, the ACM refers to the European Commission user guide.

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 requirements follow from the European standard EN 301 549. For websites and apps it refers to WCAG, and in the currently published version of the standard that is WCAG 2.1. The ACM therefore names WCAG 2.1 level AA as the standard your website and app must meet now: all criteria of level A and AA.

At the same time the ACM announces that WCAG 2.2 AA becomes the new standard during 2026, and Digitoegankelijk expects a new version of EN 301 549 referring to WCAG 2.2 at the end of 2026. The W3C itself states that content that conforms to WCAG 2.2 also conforms to 2.1, with one caveat: criterion 4.1.1 (Parsing) was removed in 2.2, while a 2.1 report may still ask for it. Practical advice: build and test against 2.2 AA now, and state in your statement that this also covers 2.1 AA. More on the differences on our page about WCAG 2.1 and 2.2.

WebYes tests automatically against WCAG 2.2 AA in the accessibility pillar, and with that also the criteria of WCAG 2.1 AA, the version the law refers to now (except for the removed 4.1.1). An automated scan cannot assess every success criterion; things like understandable error messages or a logical reading order need a human check.

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.

If (part of) your e-commerce service is not accessible, you must fix it first. If that is not possible right away, you must report it to the ACM, with a plan of action. The deadline depends on the impact on the consumer:

Critical or serious (the service is wholly or partly unusable for someone with a disability): report within 1 week, unless already fixed. Moderate or minor (the service is hard to use but not unusable, or the problem is easy to work around): report within 1 month, unless already fixed.

If you rely on an exception (fundamental alteration or disproportionate burden), you report that too and record your justification; the ACM can ask for it. Lack of time or knowledge does not count as a disproportionate burden. If you operate in several EU countries, you report to the supervisor of each country. If the expected date of full accessibility shifts, or a more serious problem comes up, you report again.

According to the ACM, these parts do not have to meet the requirements: videos, audio and animations placed before 28 June 2025; office documents (such as pdf and Word) from before that date; navigation maps, as long as there is an accessible route description in text; archives that are no longer updated after 28 June 2025; and third-party content that you did not have made yourself, did not pay for and have no control over. Everything you publish from 28 June 2025 must be accessible.

The law requires your e-commerce service to be accessible and for you to document that. In the accessibility statement you explain how your service works, how it works with assistive technology and in what way you meet the accessibility rules. Place the statement somewhere easy to find, for example in the footer or a fixed link in the account menu.

The ACM asks for more than a web page: the statement must be easy to find and itself accessible, and you must also offer it orally, for example as a read-aloud audio clip. Your customer service must also be able to give information about the accessibility of the service, in an accessible way. Web shops must also give information about the accessibility of the products and services they sell; your supplier or manufacturer has to provide that information. What belongs in it is worked out on our page on the accessibility statement.

A quality mark or external audit is not legally required. The ACM states that an independent WCAG audit or assessment is not mandatory, and a certificate, label or quality mark is not needed either. 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. Our EAA checklist for web shops in 10 steps walks through the buying process step by step. WebYes also publishes its own accessibility statement.

After a first scan and a round of remediation you can fix the biggest automated failures (alt texts, contrast, labels) and draft a first statement. What you cannot claim on that basis: full AA on every flow, or that a WebYes score above 80 equals Digitoegankelijk status A. Keep those boundaries clear for management.

Use the scan (free up to six pages, full audit up to fifteen) as input for the statement: note which URLs were tested, which fails remain open, and when re-audit follows. That keeps the text traceable instead of marketing language without evidence.

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; not all criteria can be assessed by a machine. They do find the failures visitors and regulators notice first: missing alt texts, low contrast, empty buttons, missing form labels. How the score comes about is explained in our method.

The scan covers up to six pages per free run; a full audit up to fifteen, sitemap-led. 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. Record in the accessibility statement what the scan found and what you still need to prove manually; that is more honest than a sticker without a backlog. Start the free scan, or request a human WCAG audit for the parts a machine does not assess.