Does the European Accessibility Act Apply to Your Business?

The European Accessibility Act (EAA) became enforceable on 28 June 2025. It requires that certain products and services sold in the EU are accessible to people with disabilities. If you sell products or services through a website, this law might apply to you.

The tricky part: the rules aren't obvious. Some small businesses are exempt. Some aren't. And the penalties are real.

What the EAA actually is

The EAA (Directive 2019/882) is an EU-wide law that sets accessibility requirements for products and services. Each EU country had to write it into national law by June 2022 and start enforcing it by June 2025.

In the Netherlands, the EAA was implemented through the "Wet implementatie richtlijn toegankelijkheidsvoorschriften producten en diensten." It's a mouthful. The short version: if you provide covered services through a website or app, that website or app needs to be accessible.

"Accessible" means people with visual, hearing, motor or cognitive disabilities can use it. In practice, that means following the WCAG 2.1 AA standard, the same guidelines that government websites have followed for years.

Which services are covered

The EAA doesn't apply to everything. It targets specific categories of services:

E-commerce. If you sell products online, your webshop falls under the EAA. This is the big one for small businesses. Product pages, shopping carts, checkout flows, order confirmations. All of it needs to be accessible.

Banking and financial services. Online banking, payment apps, ATMs. If you run a fintech startup or offer financial services through a website, you're covered.

Telecommunications. Phone services, messaging apps, internet access providers.

Transport services. Ticketing systems, real-time travel info, check-in machines for airlines, buses, trains and ferries.

E-books and e-readers. Digital publications and the devices used to read them.

Audio-visual media services. Streaming platforms, video-on-demand services.

If your business doesn't fall into these categories, the EAA may not apply to your website directly. A restaurant website with an online reservation form is probably not "e-commerce" under the EAA. But a restaurant that sells gift cards, merchandise or meal boxes through its website could be.

The line isn't always clear. When in doubt, making your website accessible is the safer bet. It's also just good business practice.

The microenterprise exemption

Here's the part most small business owners want to know about. The EAA includes an exemption for microenterprises that provide services.

A microenterprise is defined as a business with:

• Fewer than 10 employees, AND
• Annual turnover or balance sheet total of no more than €2 million

If your business meets both criteria, you are exempt from the EAA's service requirements. That means your website doesn't need to comply with the EAA specifically.

But there are two caveats.

First: the exemption only applies to services, not products. If you manufacture or sell physical products covered by the EAA (like e-readers or self-service terminals), the product requirements apply regardless of company size.

Second: the GDPR and the Dutch equal treatment laws still apply. Even if the EAA doesn't cover you, discriminating against people with disabilities through an inaccessible website can still create legal exposure. The EAA exemption doesn't give you a free pass to ignore accessibility entirely.

What "accessible" means in practice

The EAA refers to the EN 301 549 standard, which in turn points to WCAG 2.1 level AA for web content. Here is what that looks like for a real business website.

Text and readability. Text must have sufficient contrast against the background. A minimum contrast ratio of 4.5:1 for body text and 3:1 for large text. Light grey text on a white background fails this. Dark text on a light background usually passes.

Images need alt text. Every meaningful image needs a text description that screen readers can read aloud. Decorative images should be marked so screen readers skip them.

Keyboard navigation. Everything a mouse user can do, a keyboard user should be able to do too. Tab through links, activate buttons with Enter, navigate dropdown menus with arrow keys. Many websites break keyboard navigation without realizing it.

Form labels. Every form field needs a visible label connected in the code. Placeholder text that disappears when you start typing isn't a label. If your contact form or checkout form relies on placeholder text alone, that's a failure.

Video captions. If your website has video content, it needs captions. Auto-generated captions are a start but often need manual correction.

Headings in the right order. The heading structure (H1, H2, H3) should follow a logical hierarchy. Screen readers use headings to navigate the page. Skipping from H1 to H4 makes the page confusing for people who can't see the visual layout.

Error messages that make sense. If someone fills out a form incorrectly, the error message should explain what went wrong and where. "Error" or a red border without text doesn't help anyone, especially someone using a screen reader.

No auto-playing media. Audio or video that plays automatically without the user's action is an accessibility problem. It interferes with screen readers and can disorient users.

Who enforces the EAA in the Netherlands

In the Netherlands, the Autoriteit Consument & Markt (ACM) is responsible for enforcing the EAA. They're the same authority that handles consumer protection and market regulation.

The ACM can investigate complaints from consumers, conduct market surveillance and take enforcement action against businesses that don't comply.

For products imported into the EU, customs authorities also play a role. Non-compliant products can be blocked at the border.

What the penalties look like

Each EU member state sets its own penalty structure for EAA violations. In the Netherlands, the ACM can impose:

• Orders to correct the violation within a deadline
• Penalty payments (dwangsommen) for ongoing non-compliance
• Administrative fines

The exact fine amounts depend on the nature and severity of the violation, whether it's a first offense and how many people are affected. The ACM's general fining authority allows fines up to €900,000 or 1% of annual turnover, though the specific amounts for EAA violations will depend on how enforcement develops.

For a deeper look at penalties across EU countries, read our guide to EAA penalties.

Deadlines you should know

The key dates:

• June 2019: EAA adopted as EU Directive 2019/882
• June 2022: Deadline for EU countries to transpose into national law
• June 2025: Enforcement starts. All covered services and products placed on the market must comply
• June 2030: Transition period ends for services that were already in use before June 2025. After this date, no exceptions

If your website existed before June 2025 and provides a covered service, you technically have until June 2030 to comply under the transition provision. But this applies to the exact service as it was. Any significant changes to your website after June 2025 trigger immediate compliance obligations for the changed parts.

Starting now is better than waiting until 2029 and scrambling.

What to do if the EAA applies to you

Step 1: Run an accessibility check. Scan your website for accessibility issues to get a baseline. Automated tools catch about 30-40% of accessibility problems. They'll find missing alt text, contrast failures, missing form labels and broken heading structures.

Step 2: Fix the automated findings first. These are usually the easiest wins. Adding alt text, fixing contrast ratios, adding form labels. A developer can often handle these in a day or two.

Step 3: Do manual testing. Try navigating your website using only a keyboard. Tab through the page. Can you reach every link and button? Can you complete your checkout flow? Try your site with a screen reader (VoiceOver on Mac, NVDA on Windows). This reveals problems automated tools miss.

Step 4: Write an accessibility statement. The EAA requires you to publish a statement explaining how your website meets accessibility requirements and how people can report issues. This goes on your website, usually linked from the footer.

Step 5: Set up a feedback mechanism. People need a way to tell you when they encounter accessibility barriers on your site. An email address or contact form works. Respond to reports and fix reported issues.

What if you're exempt

Even if the microenterprise exemption applies to you, consider fixing the easy stuff anyway. About 16% of the world's population has a significant disability. In the Netherlands, an estimated 4.5 million people have some form of disability. Those are potential customers you might be turning away with an inaccessible website.

Good accessibility also helps people with temporary limitations like a broken arm, bright sunlight on a phone screen or slow internet. It helps older users who may have reduced vision or motor control too.

The quick wins cost very little. Adding alt text to images, fixing contrast, adding form labels. These changes take hours, not weeks.

---

Check your website now. Run a free accessibility scan to see where you stand. It takes 2 minutes and catches the most common issues.

---

Frequently asked questions

My business has 8 employees and €1.5 million turnover. Am I exempt from the EAA?

Yes, if you provide services (not products). A microenterprise is defined as fewer than 10 employees and under €2 million turnover or balance sheet total. You meet both criteria. But other accessibility obligations under Dutch equal treatment law may still apply.

I run a webshop but only sell within the Netherlands. Does the EAA still apply?

Yes. The EAA applies to services placed on the internal market, which includes domestic sales within any EU member state. Selling only in the Netherlands doesn't exempt you if your business exceeds the microenterprise threshold.

What's the difference between the EAA and WCAG?

The EAA is a law that says what must be accessible. WCAG 2.1 AA is the technical standard that defines how to make web content accessible. The EAA references WCAG through the EN 301 549 European standard. Think of the EAA as the rule and WCAG as the rulebook for meeting it.

Do I need to hire an accessibility consultant?

Not necessarily. Many common accessibility issues (missing alt text, low contrast, missing form labels) can be identified with automated scanning tools and fixed by your existing web developer. For complex issues like custom interactive components or full WCAG audits, a specialist can help. Start with the automated checks and see how far you get.

Does making my website accessible break my current design?

Rarely. Most accessibility fixes are invisible to other users. Better contrast might mean slightly darker text. Alt text doesn't show on screen. Form labels can match your existing design. The biggest visual change might be making buttons and links slightly larger, which usually improves usability for everyone.