ACM Enforcement: Digital Accessibility Is Now Mandatory

The European Accessibility Act (EAA) came into force on 28 June 2025. If you run an online shop, booking platform or digital service in the Netherlands, the ACM is the agency that checks whether your website meets the new requirements.

This isn't a future concern. The ACM is already active.

What the ACM is and why it matters now

The Autoriteit Consument & Markt (ACM) is the Dutch market authority. It already enforces consumer protection and competition law. Since June 2025, it also enforces digital accessibility under the EAA (implemented in Dutch law as the Wet toegankelijkheid goederen en diensten).

The ACM can investigate complaints, run its own inspections and issue fines. For small businesses, this means accessibility isn't optional anymore. It's a legal requirement with real enforcement behind it.

Which businesses are affected

The EAA applies to businesses that sell products or services to consumers through digital channels. That includes:

• Online shops and e-commerce platforms
• Booking and reservation systems
• Banking and payment services
• Telecom and streaming services
• Transport ticketing websites

Micro-enterprises (fewer than 10 employees and under 2 million euros annual turnover) are exempt from the EAA. But if you're above that threshold, even slightly, the rules apply to you.

One important detail: the exemption is based on your entire company, not just the digital part. A restaurant chain with 15 employees and an online reservation system still falls under the EAA, even if the website is a small part of the business.

What the ACM checks

The ACM evaluates websites against the WCAG 2.1 Level AA standard. That's the same standard that public sector websites have followed since 2018. Here's what that means in practice.

Keyboard navigation. Can someone use your entire website without a mouse? Every menu, form, button and link needs to be reachable and usable with just a keyboard.

Screen reader compatibility. Images need descriptive alt text. Form fields need proper labels. Headings need to follow a logical hierarchy (H1, then H2, then H3). Dynamic content like pop-ups and shopping carts needs to announce itself to assistive technology.

Color contrast. Text must have a contrast ratio of at least 4.5:1 against its background. Large text (18px bold or 24px regular) needs at least 3:1. Your designer might not like hearing this, but light grey text on a white background fails this test.

Text resizing. Your site should work when a visitor zooms to 200%. No content should get cut off or overlap.

Error handling in forms. When a visitor makes an error in a form, the error message should clearly identify the problem and suggest how to fix it. "Invalid input" is not good enough. "Please enter a valid email address" is.

You can check your website's accessibility score for free to see where you stand right now.

How ACM enforcement works

The ACM doesn't send inspectors to your office. Enforcement is complaint-driven and risk-based.

Complaint-driven. Anyone can file a complaint with the ACM. A visitor who can't complete a purchase on your website because it doesn't work with their screen reader can report you. Competitors can too.

Risk-based monitoring. The ACM also runs its own market scans. It picks sectors and runs automated and manual accessibility tests on a sample of websites. If your sector gets selected, you could be tested without warning.

The typical enforcement process looks like this:

1. The ACM identifies a potential violation (through complaint or market scan)
2. They contact you and ask you to fix the issues within a set deadline
3. If you don't fix the issues, they can impose a penalty
4. For repeated or serious violations, they can issue fines without a warning period

The ACM has said publicly that it will focus on education and guidance first. But that grace period won't last forever. The pattern from GDPR enforcement is clear: warnings come first, then fines follow.

Penalty framework

The ACM can impose two types of penalties:

Orders subject to a periodic penalty. They tell you to fix the issue by a deadline. If you don't, you pay a daily or weekly fine until you comply. These penalties typically range from 1,000 to 10,000 euros per violation per week.

Administrative fines. For serious or repeated violations, the ACM can skip the warning and go straight to a fine. Under the general consumer law framework that the ACM uses, fines can reach up to 900,000 euros or 1% of annual turnover. For small businesses, fines in practice are much lower, but even a 5,000 euro fine hurts when it's avoidable.

The ACM publishes its enforcement decisions. That means a fine also comes with public naming. Your business name appears on the ACM website alongside the violation. For reputation-sensitive businesses, this is often worse than the fine itself.

How to prepare

You don't need to make your website perfectly accessible overnight. But you do need to start and show progress.

Step 1: Run an accessibility scan. Use our free scanner to get a baseline score. It checks for WCAG 2.1 violations automatically and gives you a prioritized list of issues.

Step 2: Fix the high-impact issues first. Missing alt text on images, missing form labels, low contrast text and broken keyboard navigation are the most common problems. These are also the easiest to fix.

Step 3: Write an accessibility statement. The EAA requires you to publish an accessibility statement on your website. It should describe your current level of compliance, list known issues and explain how visitors can report problems. Put a link to it in your footer.

Step 4: Set up a feedback mechanism. Visitors need a way to tell you about accessibility barriers. A simple contact form or email address works. You're required to respond within a reasonable time.

Step 5: Document your efforts. Keep a record of what you've fixed and when. If the ACM comes knocking, showing a clear improvement trajectory matters. A business that's actively working on accessibility gets treated very differently from one that's done nothing.

What good enough looks like

Perfect WCAG 2.1 Level AA compliance is hard. Even large companies with dedicated accessibility teams don't score 100%.

The ACM knows this. What they're looking for is a good faith effort combined with a working feedback process. If your website has some accessibility issues but you have an accessibility statement, a feedback mechanism and evidence that you're fixing problems, you're in a much stronger position than a business that's ignored the requirement entirely.

Focus on these four areas first:

• All images have alt text
• All forms have proper labels
• Color contrast meets the 4.5:1 minimum
• The site works without a mouse

Those four changes fix roughly 70% of the accessibility issues we find in our scans.

Frequently asked questions

Does the EAA apply to my small business?

If you have 10 or more employees or more than 2 million euros in annual turnover, and you sell to consumers through a website, the EAA almost certainly applies to you. Micro-enterprises (under both thresholds) are exempt.

Can the ACM fine me without warning?

In most cases, the ACM will contact you first and give you time to fix the issues. But for serious violations or cases where you've been warned before, they can impose fines directly.

What's the difference between the EAA and the existing Dutch accessibility law?

The existing Dutch accessibility law (Tijdelijk besluit digitale toegankelijkheid overheid) only applies to government websites. The EAA extends similar requirements to private businesses that sell to consumers.

Do I need to hire an accessibility consultant?

For most small business websites, no. The most common issues (missing alt text, low contrast, broken form labels) can be fixed by your web developer. Our free scan identifies the specific issues on your site so you know exactly what to fix.

Is there a deadline to become compliant?

The EAA took effect on 28 June 2025. The requirements apply now. There's no official transition period for private businesses, though the ACM has indicated it will prioritize education in the early phase.

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Check your website's accessibility for free at trustyourwebsite.nl/scan. The scan takes 30 seconds and shows you exactly what to fix.