European Accessibility Act: Does It Apply to Your Website?

Since 28 June 2025, websites and apps through which businesses sell products or services to consumers must be accessible to people with disabilities. This follows from the European Accessibility Act (EAA). The ACM supervises compliance and uses WCAG 2.1 level AA as its benchmark. Micro-enterprises with fewer than 10 employees and up to €2 million annual turnover are exempt for services.

But accessibility is more than a legal obligation. It is an opportunity to make your website better for everyone while expanding your reach.

Last updated: 14 October 2026. What changed: the benchmark has been corrected from WCAG 2.2 to WCAG 2.1 level AA (via EN 301 549). Scope (e-commerce and communication services for consumers), the micro-enterprise exemption and ACM supervision have been added, with a decision table. The article originally appeared on 3 July 2025.

Source: ACM, Directive (EU) 2019/882 (Article 3(23) and Article 4(5)) and the Tijdelijk besluit digitale toegankelijkheid overheid (Dutch Temporary Decree on Digital Accessibility for Government). A micro-enterprise has fewer than 10 employees and an annual turnover or balance sheet total of up to €2 million. The table is an indication and not legal advice: if in doubt, have it assessed.

The European Accessibility Act requires businesses that supply products and services to consumers to make them accessible. For websites and apps, the ACM uses WCAG 2.1 level AA, as included in the European standard EN 301 549. We test against WCAG 2.2 AA ourselves: it covers 2.1 and is more future-proof.

In practice this means your website must be navigable by keyboard, images need alt text, color contrast must be sufficient, and forms must be properly labeled. Consumers can file reports with the ACM; the ACM also investigates on its own initiative and can approach businesses and, if improvements fail to materialise, take enforcement action.

Many people in the Netherlands have some form of disability. On top of that, everyone experiences temporary or situational limitations: a broken arm, a screen in bright sunlight, or a slow connection on the road.

Accessible websites rely on semantic HTML, a good heading structure and fast load times. That also touches the basics of technical SEO, and these are qualities that modern frontend frameworks provide by default. Also read about UX design for business software, responsive design and web performance.

In our audits, we encounter the same issues repeatedly: missing alt text, forms without labels, insufficient color contrast, and interactive elements that are unreachable via keyboard.

Another frequent problem is the use of JavaScript frameworks that break standard HTML semantics. A custom-built dropdown that looks beautiful but does not work with a screen reader is a mistake we see often. Using established component libraries like shadcn/ui or Material UI avoids these pitfalls because they are built with accessibility in mind.

Since 28 June 2025, the ACM has supervised the accessibility of webshops and communication services. In March 2026 the ACM reported that it had tested about 100 of the largest Dutch webshops and the websites of large telecom and energy providers: 61 percent turned out not to be digitally accessible. The ACM approaches the largest companies with the poorest results about the points for improvement. Businesses that do not improve, or do not improve enough, risk enforcement.

The ACM focuses mainly on critical problems with a large negative impact, such as an order button that cannot be operated with the keyboard and captchas that are not accessible. In our own audits, missing alt text, forms without labels and insufficient contrast are added to that list. So start with that basis: keyboard operation, labels, contrast and alt text. That covers the most common bottlenecks.

The cost depends heavily on when you address accessibility. If it is included from the start of a newly built web application, the extra cost is close to zero in our experience. It mostly comes down to choosing the right components and testing consistently during the build. Fixing things afterwards is a different story: for an average business website, our project experience says to expect considerably more work, depending on how many custom components need replacing.

A useful rule of thumb from our own projects, as an indication and not a guarantee: an audit plus fixing the four most common problems typically costs ten to twenty percent of the original build cost. If your website runs on a heavily outdated technical foundation, it usually makes more sense to include accessibility in a broader software redevelopment project. That way you solve performance, security, and maintainability in one move, which ends up cheaper than three separate projects in a row. Unsure where your website stands? An audit quickly gives clarity on the scope of the work.

At MG Software, we build accessibility in from the start. We use semantic HTML, ARIA attributes where needed, and test every interface with screen readers and keyboard navigation.

For existing projects, we perform an accessibility audit based on WCAG 2.2 AA, which covers the ACM's WCAG 2.1 AA benchmark. You receive a concrete report with priorities, and we can implement the improvements directly as part of our development services.

Digital accessibility is not mandatory for every website, but it is for webshops, apps and communication services that supply consumers, unless you are a micro-enterprise. The benefits go far beyond compliance: an accessible website is a better website for all your visitors.

Have your webshop or app tested against WCAG 2.1/2.2 AA, or use our project calculator for an initial estimate.

Sources (consulted 13 October 2026)

• ACM, accessibility of e-commerce services and electronic communication services: WCAG 2.1 level AA benchmark, micro-enterprise exemption, supervision.
• ACM, news item of 5 June 2025: rules apply from 28 June 2025, supervision and reports by consumers.
• ACM, news item of 24 March 2026: research into large webshops and the ACM approach.
• Directive (EU) 2019/882 (European Accessibility Act), EUR-Lex: definition of micro-enterprise (Article 3(23)) and exemption for services (Article 4(5)).
• Tijdelijk besluit digitale toegankelijkheid overheid, wetten.overheid.nl.
• W3C, Introduction to Web Accessibility: Tim Berners-Lee quote.