European Accessibility Act for Dutch webshops: what the ACM checks from 28 June 2025

Updated October 28, 2026. By All the Possibles.

The Dutch law is in force, the regulator has named itself and opened a complaint desk. This page covers what that means for a webshop, with the sources, and ends with a free check you can run on your own site.

The law in the Netherlands

The European Accessibility Act is Directive (EU) 2019/882. The Netherlands transposed it with the Implementatiewet toegankelijkheidsvoorschriften producten en diensten, and the obligations apply from 28 June 2025, the date set by Article 31 of the Directive. For a webshop the relevant service is e-commerce: a service sold to consumers at a distance through a website or app. If your customers are companies only, the e-commerce provisions do not obviously reach you, but that reading is mine and not a lawyer's.

Who checks, and what they look at first

The Autoriteit Consument en Markt announced on 5 June 2025 that from 28 June 2025 it supervises the digital accessibility of webshops and of electronic communications services. Consumers can report an inaccessible website or app to ACM ConsuWijzer. The ACM said it will start with critical accessibility problems that have a large negative impact on people with disabilities, and that it will take into account what a company has done to comply. That is a sensible order for you too: the blocking problems first, the polish later.

Other sectors have other supervisors. Industry sources list the AFM for consumer banking, the ILT for passenger transport and the RDI for devices such as payment terminals; I have not confirmed each of those against the implementing law, so treat them as a map rather than a citation. I am also not quoting fine amounts. The figures circulating online come from trade press and I could not verify them against the law.

Who is exempt

Article 4(5) of the Directive exempts microenterprises that provide services from the service requirements. Article 3(23) defines a microenterprise as fewer than 10 people and either annual turnover or an annual balance sheet total of no more than EUR 2 million. The ACM's publication phrases the duty the other way round, as applying to companies with 10 or more staff and/or a turnover above EUR 2 million. The two readings agree for most shops and differ at the edges, so if you are near the line, read the Dutch text or ask the ACM. A microenterprise that sells covered products, for example e-readers or computers, does not get the service exemption for the products themselves.

Article 14 adds the disproportionate burden route for anyone, with an assessment against Annex VI that you must document and keep. Contracts agreed before 28 June 2025 may run unchanged for up to five years under Article 32, which does nothing for new customers arriving at your shop today.

What a Dutch webshop has to publish

Article 13 and Annex V require a service provider to explain, in its terms and conditions or a similar document, how the service meets the accessibility requirements, in accessible formats. Annex I Section III asks that websites and apps be accessible in a consistent and adequate way, and Section IV covers identification, security and payment in e-commerce. A plain page in Dutch and in any other language you sell in, linked from the footer and the terms, with a working way to report a barrier, is the practical form of this. The standard people use to show conformity is EN 301 549, which builds on WCAG; confirm which version is currently cited before you print "WCAG 2.2 AA compliant" anywhere.

What to fix first, in the order the ACM is likely to look

1. Checkout and account sign-in by keyboard only, start to finish. A customer who cannot pay is the critical case the ACM described.
2. Names on icon buttons and image links: the cart, the search, the menu toggle, the product thumbnails. Missing names stop a screen reader user before the first product.
3. Form labels and error messages on the address and payment forms, so an error can be found and understood.
4. Page language set to nl (and the right language on each translated page), document titles, a visible skip link, one h1 per page.
5. Contrast on prices, badges and buttons against the real backgrounds, and target size on mobile.
6. Alt text on product images that says what the product is, and empty alt on decoration.
7. The accessibility information in your terms, in Dutch, dated, with a contact route that works.

Run the free check below on your busiest product page first, then on checkout. The Designers page audit does the same thing inside an agent session, and the Accessibility Readiness Report covers up to ten pages for $149 once, with a fix list in the order to do it and a draft of the statement for your terms.

Sources

• ACM, "ACM roept bedrijven op zich voor te bereiden op regels toegankelijkheid websites en apps", 5 June 2025: supervision from 28 June 2025, the ConsuWijzer route, the first focus, and the ACM's wording of the size threshold.
• Directive (EU) 2019/882 on EUR-Lex: Articles 2, 3, 4, 13, 14, 31, 32 and Annexes I, V and VI.
• Our general guide to the Directive, which the Dutch page builds on.

This is a reading of public texts by a tool builder, not legal advice.

Questions people ask

Who enforces the European Accessibility Act for webshops in the Netherlands?

The Autoriteit Consument en Markt (ACM). Its publication of 5 June 2025 says that from 28 June 2025 it supervises the digital accessibility of webshops and of electronic communications services such as chat and calling. Other Dutch regulators cover other sectors, for example banking and passenger transport.

Is my Dutch webshop exempt as a small business?

The Directive exempts microenterprises that provide services: fewer than 10 people and either annual turnover or balance sheet total of EUR 2 million or less. The ACM describes the obligation as applying to companies with 10 or more staff and/or more than EUR 2 million in annual turnover. The wording differs slightly, so check the Dutch law or ask the ACM if you sit near the line, and remember that the exemption covers services, not products you place on the market.

Can a customer report my webshop?

Yes. Since 28 June 2025 consumers can report a website or app that is not digitally accessible to ACM ConsuWijzer. The ACM has said it will focus first on critical accessibility problems with a large negative impact on people with disabilities, and that it will weigh the effort a company has made.