Does the European Accessibility Act apply to my website?

The European Accessibility Act is Directive (EU) 2019/882. It was adopted on 17 April 2019 and member states have applied it since 28 June 2025. In the Netherlands it landed as the Implementatiewet toegankelijkheidsvoorschriften producten en diensten.

It does not cover the whole web. It covers a defined list of products and services aimed at consumers.

What the law covers

On the services side: e-commerce, consumer banking, electronic communications, services giving access to audiovisual media, passenger transport by air, bus, rail and water, and e-books.

On the products side: computers, smartphones, tablets, e-readers, televisions with internet access, payment terminals, ATMs, ticket machines and check-in machines.

If you sell to consumers online, you are almost certainly in scope. If you run a business-to-business platform with no consumer offering, you are probably not, though the line runs through what you offer rather than what you call yourself.

The public sector follows a different law

Dutch government bodies and bodies governed by public law fall under the Besluit digitale toegankelijkheid overheid, which has applied since 2018 and comes from the Web Accessibility Directive. For an organisation's own website or app, one regime applies, never both. Which one depends on what the organisation is, not on what it sells.

That distinction matters in the cultural sector in particular. Two museums that look alike from the outside can fall under different laws, so it has to be assessed case by case. A subsidy on its own does not make an organisation a body governed by public law: that term comes from procurement law and has three conditions that all have to be met.

The micro-enterprise exemption, and how it is quoted wrong

An enterprise with fewer than 10 employees and an annual turnover or balance sheet total of at most 2 million euro is exempt.

Two details get lost. The first is the word "or": turnover or balance sheet total, not both. The second is bigger. The exemption applies to services only. If you place a product on the market, you are not exempt; at most you get relief on the documentation duty.

Disproportionate burden is not a free pass

A company can invoke a disproportionate burden, or argue that a requirement would fundamentally alter the product. That is not an automatic exemption. The assessment has to be documented and substantiated, it has to be redone every five years, and the regulator may ask to see it.

The dates that still matter

Services that were already running on 28 June 2025 may continue to use products that were already in use until 28 June 2030. Self-service terminals that were in use on 28 June 2025 may stay in service until the end of their economic life, with a maximum of twenty years.

Those transition periods buy time for existing hardware. They do not postpone the requirement for the service itself.

Which standard you are measured against

Both Dutch regimes point to EN 301 549, the European standard for accessibility of ICT. That standard currently sits at WCAG 2.1 level A and AA. The version that counts legally is the one referenced in the Official Journal of the EU, which is V3.2.1 from March 2021.

Version 4 of the standard, which adopts WCAG 2.2, exists only as a draft. ETSI published V4.1.0 as a draft in November 2025 and as a final draft in June 2026. Designation in the Official Journal is expected around October 2026, but that is a plan and not a date.

One nuance for anyone building a legal argument on this: no harmonised standard has yet been designated under the EAA itself. The designation of V3.2.1 belongs to the Web Accessibility Directive. In practice EN 301 549 is the yardstick everyone works with, and the Dutch implementing act aligns with it.

Still not sure

The scope questions above settle most cases. If yours sits on a line, the sector monitors on this site show who else in your market publishes an accessibility statement, and the Dutch knowledge base covers the scope questions in more detail.