Who enforces the European Accessibility Act in the Netherlands?

Q: Who enforces the European Accessibility Act in the Netherlands?

Six regulators enforce the European Accessibility Act in the Netherlands: the ACM for e-commerce, apps and electronic communications, the AFM for consumer banking and financial e-commerce, the RDI for hardware, the Dutch Media Authority for e-books and access to audiovisual media, the ILT for passenger transport, and the Justice and Security Inspectorate for the 112 emergency number.

There is no single accessibility authority in the Netherlands. Enforcement of the European Accessibility Act is split across six existing regulators, each covering its own type of product or service.

The six, and what each covers

Regulator	Covers
ACM, Authority for Consumers and Markets	E-commerce services: web shops and apps. Plus electronic communications services.
AFM, Authority for the Financial Markets	Consumer banking services, and e-commerce of a financial nature.
RDI, Dutch Authority for Digital Infrastructure	Hardware: computers, laptops, smartphones, tablets, ATMs, payment terminals, ticket and check-in machines, e-readers, televisions.
Commissariaat voor de Media, Dutch Media Authority	E-books, and services giving access to audiovisual media services.
ILT, Human Environment and Transport Inspectorate	Passenger transport by air, bus, rail and water.
Inspectie JenV, Justice and Security Inspectorate	The 112 emergency number.

It is six, not seven. The number seven circulates because one widely shared article adds up two different laws: the seventh regulator in that list covers the Wet digitale overheid, not the EAA. A second source of confusion is that the Dutch implementing act amends seven existing laws. Seven laws, six regulators.

One caveat if you want to build on this legally: for the Justice and Security Inspectorate and 112, three official sources name the supervision but we could not find the underlying legal article.

What the ACM actually did in 2026

The ACM is the regulator most companies will meet, and it has been the most open about its method. What follows comes from a presentation by the ACM on 25 June 2026, at the Dutch Digital Accessibility Day.

It started with guidance rather than penalties. Ten companies received a full investigation following WCAG-EM, with a report. Two weeks later each got a company visit, with the chief executive at the table and an ACM colleague with lived experience of disability present. Alongside that, the ACM examined one important functional part of the website at more than a hundred companies.

Companies that do not comply get three months, after which a retest follows.

Worth knowing if you run a shop: when the ACM tests, it walks the entire checkout process, from putting a product in the basket through to payment. That is the path to test first.

The duty to report, since October 2025

If your e-commerce or communications service does not meet the requirements, you have to report that yourself. For e-commerce and electronic communications the report goes to the ACM through a form; for financial services it goes to the AFM.

The ACM names two deadlines. Critical or serious problems are reported within a week, moderate or minor ones within a month. Alongside the report you publish an accessibility statement on your site or in your app, somewhere easy to find.

This reverses the burden of proof. You are the one demonstrating where your service stands, and that takes a substantiated audit rather than an impression.

Fines

The ACM does not name an amount on its own pages. Trade sources almost unanimously cite 900,000 euro or 1% of annual turnover, whichever is higher. For larger companies the second figure is usually the heavier one. For the AFM, trade sources put the maximum lower, somewhere around 103,000 to 110,000 euro.

Treat those numbers as what they are: figures from trade sources rather than from the regulator.

Enforcement so far

No enforcement case is known in the Netherlands yet. Elsewhere in Europe there is movement. In France, disability organisations brought interim proceedings against large supermarket chains over inaccessible checkouts in late 2025. In Germany, online shops received warning letters shortly after the law took effect. The pressure in France came from advocacy organisations rather than from the regulator, which is worth noting: enforcement is not the only route to a legal problem.