European Accessibility Act: must your online store comply?

In short: the European Accessibility Act (EAA) has applied since June 28, 2025. Online stores and other digital consumer services run by companies with 10 or more employees or more than €2 million in revenue must meet WCAG 2.1 level AA. The Dutch regulator ACM supervises compliance. Micro-enterprises are exempt. The checklist below shows you where you stand in 15 minutes.

What the EAA has required since June 28, 2025

The European Accessibility Act is Directive (EU) 2019/882. The Netherlands transposed it through the Implementation Act on accessibility requirements for products and services. Since June 28, 2025, products and services within scope must be usable by people with disabilities. For websites and apps that means, in practice, conforming to the European standard EN 301 549, which for web content points to WCAG 2.1 level AA. Its successor, EN 301 549 version 4, aligns with WCAG 2.2 and is expected in the fall of 2026. If you are building now, build to 2.2 straight away.

The law is not just about your homepage. The whole customer journey counts: product pages, filters, the cart, the checkout, your payment provider's hosted page, the account area, the emails and PDF invoices you send, and the chat or contact form.

Service contracts concluded before June 28, 2025 may continue unchanged until June 28, 2030 at the latest; for an online store that is largely irrelevant, because every order is a new contract.

Who is covered (and the micro-enterprise exemption)

The EAA targets services to consumers. These services are in scope:

E-commerce: any website or app where consumers buy, book or reserve products or services.
Consumer banking and payment services, including apps and online banking.
Electronic communications: telephony, chat, video calling, messaging.
Passenger transport: websites, apps, tickets and travel information for air, bus, rail and waterborne transport.
E-books and e-reader software.
Access to audiovisual media services, such as a streaming service's website and app.

Micro-enterprises are exempt from the service requirements: fewer than 10 employees and an annual revenue or balance sheet total of no more than €2 million. Exceed either threshold and you are covered. Two nuances that often go wrong: an online store that sells exclusively to businesses is outside the EAA (which is about consumers), and so is an informational company website with no ordering or booking function. As soon as you sell, book or take reservations online, you are e-commerce.

Situation	Covered by the EAA?	Standard
Online store, 12 employees, sells to consumers	Yes	WCAG 2.1 AA (EN 301 549)
Online store, 6 employees, €1.2 million revenue	No (micro-enterprise)	Voluntary, but sensible
Wholesaler with a B2B ordering portal only	No	Voluntary; increasingly demanded by large buyers
Restaurant with online reservations, 15 employees	Yes (reservations are e-commerce)	WCAG 2.1 AA
GP practice, informational site with appointment form	Usually no	Voluntary; strongly advisable given the audience

For retail and e-commerce the law almost always applies. In healthcare the legal duty is narrower, but the audience is exactly the reason to get it right.

WCAG 2.1 AA in plain language: the 10 requirements you notice immediately

WCAG has 50 success criteria at levels A and AA. These 10 are visible without specialist knowledge:

Contrast: text at least 4.5:1 against its background, large text 3:1 (criterion 1.4.3).
Alternative text for images, and an empty alt for decorative ones (1.1.1).
Keyboard: everything can be reached and operated with Tab, Enter and the arrow keys, without a mouse (2.1.1).
Visible focus: you can always see where you are on the page (2.4.7).
Forms: every field has a label, and error messages say what is wrong and how to fix it (3.3.1, 3.3.2).
Heading structure: 1 h1, logical h2 and h3, recognizable regions such as navigation and main content (1.3.1).
Scalable: 200% zoom without losing content, reflow down to 320 pixels wide (1.4.4, 1.4.10).
Video: captions and a transcript or audio description (1.2.2, 1.2.5).
Motion: carousels and animations can be paused (2.2.2).
Meaningful links and buttons: "View the returns policy" instead of "click here". Custom components such as dropdowns and modals expose a name, role and state (2.4.4, 4.1.2).

How the ACM enforces and what a violation costs

The Netherlands Authority for Consumers and Markets (ACM) supervises online stores, communication services and most other digital consumer services; separate regulators are designated for banking and transport. In June 2025 the ACM announced it would first focus on critical accessibility problems: failures that simply stop someone with a disability from ordering. Its own research in late 2024 showed that most large online stores fell short on exactly that point.

The toolkit is the same as for other consumer rules: a warning or commitment, an order subject to a periodic penalty, and an administrative fine that can reach €900,000 or 1% of annual revenue, whichever is higher. Consumers and advocacy groups can also file complaints with ConsuWijzer, and the Dutch collective action regime (WAMCA) leaves room for claims.

15-minute self-test (checklist)

Do this with your own online store, on a laptop and on a phone:

Put the mouse away. Tab from the homepage to a product, into the cart and through the checkout. Can you reach everything, and can you always see where you are?
Zoom the browser to 200%. Does content disappear or does horizontal scrolling appear?
Run Lighthouse (in Chrome, Lighthouse tab) or the free axe DevTools extension on 3 pages. Automated tests find roughly a third of the problems, but give a quick impression.
Turn on VoiceOver (Mac: Cmd+F5, iPhone: Settings, Accessibility) or install the free NVDA on Windows. Go through the checkout with your eyes closed.
Check the contrast of buttons, links and placeholder text with a contrast checker.
Fill in a form incorrectly on purpose. Does the error message say what is wrong, and does it sit next to the field?
Check videos for captions and carousels for a pause button.
Open a PDF invoice or your terms and conditions: is it real text with headings, or a scan?
Look at your cookie banner, chat widget and payment page. They count too, even if a vendor supplies them.
Is there an accessibility statement on your site?

Three or more times "no"? Then an audit is the logical next step.

What it costs to make an existing site accessible

The cost depends on 3 things: the technical foundation (a modern Shopify theme or a well-built custom frontend can mostly be repaired; an old theme with dozens of plugins usually cannot), the number of unique page types, and the amount of content such as videos and PDFs.

RABZI indication: a mini-audit of your 10 most important pages starts from €950 excl. VAT and delivers a prioritized list within 1 week. A full WCAG-EM audit with accessibility statement starts from €2,950. Audit and remediation in 1 bundle starts from €9,500; large online stores with a lot of custom work land between €10,000 and €25,000. With a new website or online store from RABZI, accessibility is included in the price. See web accessibility for the approach and the pricing page for all rates.

One warning: accessibility widgets or overlays (a button that adjusts contrast and font size) do not fix the underlying code and do not count as compliance. Put that money into real repairs.

If you are considering a new online store anyway, first read what online store development costs and make accessibility a hard requirement in your request for proposals. With a RABZI online store you do not need to ask for it separately.

Accessibility is better SEO and conversion

What works for a screen reader also works for Google and for a customer in a hurry on a phone. A logical heading structure, alt text, fast and mobile-friendly pages and clear link text are exactly the things search engines reward. Forms with good labels and error messages reduce abandoned orders. And the audience is large: more than 2 million people in the Netherlands live with a disability that makes using websites harder.

Writing an accessibility statement

The EAA requires service providers to explain how their service meets the requirements, for example in the terms and conditions or on a dedicated page. In practice you do that with an accessibility statement. Include:

The scope: which website, app or components.
The standard: WCAG 2.1 level AA (EN 301 549) and the date of the last assessment.
The status: fully, partially or not conforming, with the known deviations and when you will fix them.
A way for people who hit a problem to contact you, with a response time.
A claim of "disproportionate burden" if you invoke one, with justification. The burden of proof is on you.

Update the statement after every major change and at least once a year. Combine that moment with your annual check of the cookie banner and your NIS2 obligations, so compliance becomes 1 fixed agenda item.

Frequently asked questions

My online store has 8 employees. Do I have to comply?

Only if your revenue or balance sheet total exceeds €2 million. Stay below both thresholds and you are a micro-enterprise, exempt from the service requirements. Grow past them and the law applies immediately. Building accessibly is sensible even without the obligation: it reduces abandoned orders and saves you an expensive catch-up later.

Is WCAG 2.2 already mandatory?

No. The harmonized standard still points to WCAG 2.1 AA. Its successor, EN 301 549 version 4, aligns with WCAG 2.2 and is expected in the fall of 2026. WCAG 2.2 adds 6 criteria at levels A and AA, such as a minimum target size of 24 by 24 pixels and accessible authentication. Building new work to 2.2 avoids having to adjust again within a year.

Does an accessibility widget or overlay help?

No. A widget changes the presentation but does not repair the code that assistive technology depends on: missing labels, wrong headings, unreachable buttons. Regulators and advocacy groups in Europe and the US do not treat overlays as compliance. Spend the budget on an audit and real repairs.

Does the law also apply to my B2B ordering portal?

Not through the EAA, which is about consumer services. More and more large buyers and public tenders do require WCAG, and public organizations may only use accessible supplier portals. If you are building a new portal, put 2.1 AA in the requirements. The extra cost on a new build is limited.

Conclusion

The EAA is not a paper law: the ACM has been checking since June 28, 2025. If you are in scope, the question is not whether you meet WCAG 2.1 AA, but how soon. Start with the self-test above, commission an audit if you find more than 3 problems, and plan remediation in phases: the checkout first, then the rest. Want to know where your online store stands? Request a free first scan: within 1 business day you get the 5 biggest blockers and a proposal.

The European Accessibility Act: does your website or online store have to comply? 2026 checklist