EAA enforcement in the Netherlands: ACM, webshops and fines

Which law applies

The Netherlands did not write one new act. The Implementatiewet toegankelijkheidsvoorschriften producten en diensten amends several existing laws and spreads supervision over sector regulators. It applies from 28 June 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. ACM states the rules apply to businesses with 10 or more staff or more than EUR 2 million turnover (ACM).

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 Autoriteit Consument & Markt (ACM) supervises e-commerce and electronic communications services. The AFM covers banking and other financial services. A business that relies on the disproportionate burden or fundamental alteration exception for its webshop must notify ACM (ACM).

How a complaint reaches a shop

Consumers are told to raise the problem with the shop first, then report it to ACM ConsuWijzer. ACM says it uses those reports to decide where to look (ACM). We found no Dutch court case on webshop accessibility under the new rules as of 1 October 2026.

Fines and other sanctions

ACM enforces through its general consumer protection powers under the Wet handhaving consumentenbescherming: warnings, binding instructions, orders backed by a penalty payment (last onder dwangsom), and fines. The fine ceiling is EUR 900,000 per violation, or a percentage of turnover where that is higher (Houthoff factsheet, July 2025). We found no separate accessibility-specific fine band.

What has actually happened so far

• Before 28 June 2025. ACM publicly called on companies to prepare their websites and apps (ACM).
• 24 March 2026, ACM's webshop research. ACM tested about 100 of the largest Dutch webshops plus large telecom and energy providers. In 61% of the webshops a person with a disability could not place an order at all; another 33% had serious problems. Examples: order buttons that could not be reached by keyboard and inaccessible CAPTCHAs. ACM said it will point out improvements to the companies concerned and that "companies that do not improve, or improve insufficiently, risk enforcement" (ACM, 24 March 2026).
• No published fine against a named webshop as of 1 October 2026.

What to do if you sell into the Netherlands

If you sell to consumers in the Netherlands 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.