Accessible website: what the European Accessibility Act and WCAG mean

Since 28 June 2025, accessibility requirements apply in the Netherlands to many online services, such as web shops and booking sites. The rules come from the European directive known as the European Accessibility Act (EAA) and are laid down in the Dutch Implementation Act on accessibility requirements for products and services. Not every business is covered, but an accessible website is a better website either way. This article is general information, not legal advice; check your own situation with the ACM or a lawyer.

What is the European Accessibility Act?

The EAA is a European directive that makes sure certain products and services are usable for people with disabilities, for example people who have difficulty seeing or hearing or who find it hard to move or concentrate. The Dutch law entered into force on 28 June 2025, as shown by the validity date in the national legislation database. For websites, the e-commerce services are the most relevant part.

What is an e-commerce service?

According to the Dutch Authority for Consumers and Markets (ACM), an e-commerce service is an online service through which consumers can conclude a contract over the internet. It covers websites and apps where a consumer can buy, rent, order, take out or reserve something. The ACM's examples include web shops, booking platforms and sites for taking out subscriptions. It also applies if you only offer products or services on part of your website, and if offers from other sellers appear on it.

A purely informational site, such as a business card page where customers only find contact details, is therefore not automatically an e-commerce service. If visitors can reserve an appointment, order something or take out a subscription, it often is.

Who does not have to comply?

The ACM names an important exception for the microenterprise: fewer than 10 employees and an annual turnover of at most 2 million euros. A microenterprise is not obliged to meet the legal accessibility requirements. If you have 10 or more employees, or turnover above 2 million euros, or both, your e-commerce service must be accessible. There is also an exception where adjustment would be a disproportionate burden or would fundamentally change the service; you then have to assess it, document it and notify the supervisor. The exact judgement about your business remains case-by-case.

Even if you are a microenterprise and not obliged: accessibility improves the user experience for everyone, including people with a temporary impairment, a small phone or bright sunlight on the screen. And larger customers increasingly ask about it.

You stay responsible

The ACM states that you as the provider are responsible for accessibility, even if you hire another company to build your site. So ask about accessibility when choosing an agency or platform.

What must your site meet?

The ACM names four basic principles: perceivable, operable, understandable and robust. These are the same four principles as in the W3C's WCAG. The law itself refers to technical standards; in practice the European standard EN 301 549 is used, which for web content is largely based on WCAG. Which version of the standard exactly counts as proof of conformity can change; WCAG 2.1 and 2.2 level AA are the common practical yardstick, and WCAG 2.2 extends 2.1. Check with the ACM which version applies now.

For e-commerce services there are additional rules, according to the ACM:

• Accessibility information: also provide information about the accessibility of the products or services offered, so consumers have it before they buy.
• Digital signing: if customers have to sign digitally, that must also be possible in an accessible way.
• Logging in and paying: identification and payment methods must be accessible. That includes emails or attachments you need for them.

What does not need to be changed?

The ACM lists some exceptions. These include videos and audio recordings that were on your site before 28 June 2025, office files (PDF, Word) from before that date, archives you do not modify afterwards, navigation maps (an accessible text route description is enough) and third-party content you do not control. Everything you publish from 28 June 2025 does have to comply.

Practical: a checklist for your website

These items come back in almost every WCAG assessment and can often be improved quickly:

1. Alternative text for images. Describe what the image means. Decorative images get an empty alt.
2. Sufficient contrast. WCAG level AA requires a contrast ratio of at least 4.5 to 1 for normal text.
3. Keyboard operation. You must be able to operate everything without a mouse, with a visible focus indicator.
4. Headings in logical order. Use real headings (H1, H2, H3) for structure, not just bigger text.
5. Forms with labels. Every field has a visible label and clear error messages, not just red colour.
6. Descriptive link text. “Read more about our services” instead of “click here”.
7. Large enough targets. WCAG 2.2 adds a minimum target size of 24 by 24 pixels at level AA, with exceptions.
8. Captions on video you newly publish.
9. No moving content that cannot be stopped, and nothing that flashes more than three times per second.
10. Page language set correctly, so screen readers use the right pronunciation.

Testing

Automated tools only find part of the problems. Combine them with manual checks:

• Walk through your most important pages with only the keyboard (Tab, Shift+Tab, Enter, Space, Escape).
• Zoom your browser to 200 percent and see whether anything gets cut off.
• Turn on a screen reader on an important page, such as the order process or contact form.
• If possible, have someone with a disability look along. This often yields the most valuable insights.

Supervision and enforcement

The ACM supervises compliance for e-commerce services and electronic communication services. If you do not comply, you must report it. What this means concretely for your business depends on your situation; do not wait for a complaint.

In conclusion

Accessibility is cheapest when it is included in design and build from the start. At CUBO Agency we build websites with semantic HTML, good contrast and keyboard operation as standard, and we can review an existing site. Want to know where you stand? Get in touch for a free intro call. Also read Core Web Vitals explained.

Sources

Reviewed on 28 October 2026 against the sources below. Rules and guidelines change; this article is general information, not legal or tax advice.

• Toegankelijkheid van e-handelsdiensten en elektronische communicatiediensten (ACM)
• Implementatiewet toegankelijkheidsvoorschriften producten en diensten (wetten.overheid.nl)
• Producten en diensten toegankelijker voor mensen met een beperking (Rijksoverheid)
• Accessibility of products and services, summary of the directive (EUR-Lex)
• Web Content Accessibility Guidelines (WCAG) 2.2 (W3C)
• WCAG overview (W3C Web Accessibility Initiative)

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