EAA enforcement in Belgium: FPS Economy, complaints and fines

Which law applies

Belgium transposed the service rules with the law of 5 November 2023, which inserts accessibility requirements for services into the Code of Economic Law. It covers e-commerce, consumer banking, e-books and terminals from 28 June 2025 (FPS Economy, 2 July 2025).

The Directive exempts microenterprises that provide services: fewer than 10 staff and an annual turnover or balance sheet total of EUR 2 million or less (Article 4(5)). Both conditions have to hold. Everyone above that line who sells to consumers online is in scope from 28 June 2025. Note one wrinkle: the FPS Economy announcement says microenterprises get "an additional five years" to comply, which reads differently from the outright exemption in the Directive. If you are near the threshold, check the text that applies to you.

The Act itself describes outcomes (perceivable, operable, understandable, robust) rather than naming WCAG. In practice authorities and courts measure websites against the harmonised European standard EN 301 549, whose web chapter in version 3.2.1 maps to WCAG 2.1 level AA. Working to WCAG 2.2 AA covers those criteria plus the six new level A and AA criteria WCAG 2.2 added.

Who enforces it for online shops

The Economic Inspection of the FPS Economy controls e-commerce and consumer banking services. The telecoms regulator BIPT covers electronic communications (FPS Economy). The same inspection already runs regular e-commerce controls on other consumer rules.

How a complaint reaches a shop

Consumers report problems through ConsumerConnect, the FPS Economy's reporting point, or its contact centre. We found no Belgian collective action or court case on webshop accessibility as of 1 October 2026.

Fines and other sanctions

The FPS Economy announcement states: "Administrative sanctions are provided for. These sanctions can reach EUR 200,000 or 6% of annual turnover for the most serious infringements" (FPS Economy, 2 July 2025). We could not tie that figure to a specific article of the Code, so treat it as the government's own summary.

What has actually happened so far

• 2 July 2025. The FPS Economy announced the rules, the authority and the sanction range (FPS Economy).
• Press coverage has described Belgium as struggling to comply with the directive overall (Le Vif).
• No accessibility fine, order or case against a named Belgian webshop was found as of 1 October 2026.

What to do if you sell into Belgium

If you sell to consumers in Belgium and you are above the microenterprise line, the defensible position is the same as everywhere else in the EU: fix the barriers in your own code, keep dated evidence of what you tested and changed, and publish the accessibility information the law asks for.

1. Scan your key templates (home, category, product, cart, checkout, account) for the failures a script can verify. Our free scan does this for up to 10 pages.
2. Test the purchase journey with a keyboard only and with a screen reader. A script cannot judge whether alt text makes sense or a checkout error is announced.
3. Fix the issues in the theme or codebase, not with an overlay widget. Overlays vs code fixes explains why.
4. Publish the service information the Act requires, in an accessible format. See what an EAA accessibility statement must contain.
5. Re-test after every redesign, theme update or new app, and keep the reports.

A Fix Sprint covers steps 1, 2, 3 and 5 for a fixed price. None of this is legal advice, and no audit can promise that a regulator or court will agree with it. It is the work that makes a complaint easy to answer.