The European Accessibility Act (EAA) has applied since 28 June 2025 to online shops and other e-commerce services that businesses offer to consumers. Those services must work for people with disabilities, for example with a screen reader or only a keyboard. According to the Dutch statutory text, businesses with fewer than 10 employees and an annual turnover or balance sheet total of no more than 2 million euros are exempt.
This article explains the rules as they appear in the official sources, with a focus on the Netherlands, where Outseen is based. It is not legal advice. If you are unsure whether the law applies to your business, ask a lawyer or the Dutch consumer authority, the ACM.
What is the European Accessibility Act?
The EAA is Directive (EU) 2019/882 of 17 April 2019 (link to the Dutch-language text). Each EU member state has to transpose a directive into its own legislation. The Netherlands did so with the act implementing accessibility requirements for products and services (Implementatiewet toegankelijkheidsvoorschriften producten en diensten), published in the Dutch Official Gazette as Staatsblad 2024, 87. That act amends, among others, the Dutch Commodities Act, the Telecommunications Act and the Civil Code.
The rules for online shops are in the Dutch Civil Code, Book 6, Articles 230fa to 230fd (in Dutch). According to the directive, member states apply the rules from 28 June 2025, and the Dutch government (page in Dutch) gives the same date.
Does your website fall under it?
The law refers to e-commerce services. Article 6:230fa of the Civil Code describes them as services provided at a distance, through websites and apps, at the request of a consumer, with a view to concluding a contract. The ACM sums this up as websites and apps where you buy, take out or reserve something.
| Situation | Covered by the rules for e-commerce services? |
|---|---|
| Online shop selling to consumers | Yes, unless you fall under the exemption for small businesses |
| Website or app where consumers book or reserve something | According to the ACM, yes, unless you fall under the exemption |
| Online shop that only sells to businesses | The statutory text concerns services to consumers; have your situation assessed |
| Website without an ordering, booking or sign-up function | Does not automatically fit the description; if in doubt, have it assessed |
Besides online shops, the EAA also covers online banking, e-books and certain electronic products, among other things. Those have their own rules and regulators. This article is about websites and online shops.
Does it apply to older content too?
Not to everything. Article 2(4) of the directive excludes, among other things:
- pre-recorded video and audio published before 28 June 2025;
- office files, such as PDFs, published before 28 June 2025;
- third-party content that you do not fund, develop or control;
- archives whose content is no longer updated after 28 June 2025.
Your product pages, basket and checkout do not fall under these exclusions, because you keep updating them.
Which businesses are exempt?
Here the official sources word things differently. The difference is small, but it can matter for your business.
| Source | Wording |
|---|---|
| Statutory text, Article 6:230fc Civil Code | The rules do not apply to businesses with fewer than 10 employees and an annual turnover or annual balance sheet total of no more than 2 million euros |
| Dutch government | Small businesses with fewer than 10 people on the payroll and an annual turnover of at most two million euros do not have to make their services accessible |
| ACM (June 2025, Dutch version) | The obligations apply to businesses with 10 or more people on the payroll and/or an annual turnover of more than 2 million euros |
The Dutch government and the ACM mention only annual turnover. The statutory text mentions annual turnover or balance sheet total, as does the definition of a microenterprise in the European directive. For most businesses the result is the same. The difference only counts if you have fewer than 10 employees, a turnover above 2 million euros and a balance sheet total of 2 million euros or less. The statutory text on wetten.overheid.nl takes precedence. If you are in that situation, have a lawyer assess whether the exemption applies to you.
Does the small business exemption apply?
- ConsumersDo you offer consumers a service through a website or app that lets them buy, book or sign up for something? If not, have your situation assessed.
- EmployeesDo you have fewer than 10 employees? If not, the exemption does not apply.
- Turnover or balance sheetIs your annual turnover or your annual balance sheet total no more than 2 million euros? If so, the statutory text exempts you.
- DoubtIf you are close to a threshold or your situation is different, ask a lawyer to take a look.
The law also has two exceptions per requirement. You do not have to apply a requirement if it would fundamentally alter your service or impose a disproportionate burden. According to Article 6:230fc(3) of the Civil Code, you cannot rely on that second exception if you receive outside funding to improve accessibility.
What do you need to do if the law applies to you?
Article 6:230fb of the Civil Code requires you to design and provide your e-commerce service according to the requirements in the annexes to the directive. For online shops, these include:
- information about the accessibility of the products and services you sell, where the responsible party provides that information;
- identification, security and payment functions that people can perceive, operate and understand, and that hold up with assistive technology;
- an explanation of how your service meets the requirements, in your general terms and conditions or an equivalent document;
- procedures that keep your service compliant, including when your website or the standards change;
- immediate correction if your service no longer complies.
The government portal Business.gov.nl calls that explanation an accessibility statement and says your users must be able to find it easily.
Which standard do you test against?
The law names no version of a standard. Article 6:230fd of the Civil Code provides that your service is presumed to comply if you follow the harmonised European standards published in the Official Journal of the EU.
In practice, according to the W3C (2026), most organisations use WCAG and the European standard EN 301 549. WCAG stands for Web Content Accessibility Guidelines, the W3C’s international guidelines for accessible web content. They have three levels: A, AA and AAA. The W3C writes that the 2026 version of EN 301 549 uses WCAG 2.2. Check which version of the standard applies as the harmonised standard at the time of your project.
Who enforces the rules?
In the Netherlands, the ACM supervises online shops and other e-commerce services. According to the ACM (June 2025), it focuses at first mainly on serious problems with a large impact on people with disabilities, and consumers can file reports through ConsuWijzer, its consumer information portal. For banking services, the regulator is the Dutch Authority for the Financial Markets (AFM).
Where do you start?
First establish whether the law applies to you, using the statutory text as your starting point. Then walk through the route a customer takes: find a product, add it to the basket, create an account or log in, pay. Do it once with only a keyboard and once with a screen reader. That is where you find the barriers that weigh most.
A first check of your online shop
- You can complete the whole ordering route with only a keyboard
- You can always see where the focus is as you Tab through the page
- A screen reader announces buttons, fields and checkout steps in a way that makes sense
- Product images have alt text that says what is shown
- Text and buttons have enough contrast with the background
- Form error messages say what is wrong and how to fix it
- Headings are in a logical order
- You know which themes, apps and plugins cause barriers
- Your accessibility statement is easy to find and someone keeps it up to date
Error messages are a good example of a small change with a large effect. A message that only shows a red border or a vague word does not help anyone who cannot see the field or does not understand the error:
Error message on the email field
VoorInvalid input.
NaEnter your email address in the format name@example.com.
More on alt text and headings is in the glossary. For a new website or online shop, accessibility is one of the factors that determine the work; see how much does a website cost?
Atlas, Outseen’s research engine, examines public code such as the language setting, headings and link text of fetched pages. Those signals touch on accessibility, but an Atlas check is not an accessibility audit and does not say whether you comply with the law. For the technical basics of search visibility, see the technical SEO checklist; more about website projects is on website development.
What does this mean for your business?
If you sell online to consumers and the exemption does not apply to you, the rules already apply now. Start with the ordering route and the payment step, because that is where a barrier hits a customer hardest. Record what you tested, what you changed and what is still open. You need that overview for your accessibility statement as well.
If the exemption does apply, there is no legal duty. Still take accessibility into account when you choose a new theme, a new checkout or a redesign. Fixing things afterwards is often more work than including them from the start, and your business may grow past the threshold.