Netherlands accessibility law: Tijdelijk Besluit + EAA Wet explained

Who has to comply

Public-sector since 2018 via Tijdelijk Besluit; private-sector under the Dutch EAA Implementatiewet from 28 June 2025.

The Netherlands is a highly digitised, English-comfortable market that many international sellers use as a logistics and e-commerce hub, so cross-border exposure is high. Under the Dutch EAA Implementatiewet, a foreign store selling to Dutch consumers is covered on the country-of-consumption basis, and the Dutch regime is notable for penalties reaching up to 10% of annual turnover for repeat offenders, one of the steeper multipliers in the EU. Dutch consumers are accustomed to the Digitoegankelijk statement, so an absent or vague conformance declaration stands out quickly.

What the law actually requires

The technical baseline is WCAG 2.1 Level AA via EN 301 549. EN 301 549 references WCAG 2.1 Level AA in full and adds a few requirements specific to mobile apps and documents. Beyond the technical bar, Netherlands requires the following operational items, which auditors check first because they are simple to verify:

• EN 301 549 / WCAG 2.1 AA

• Public accessibility statement using the Digitoegankelijk template

• Conformance status disclosed (full / partial / non-conformant)

Penalties and how enforcement actually works

Up to 10% of annual turnover for repeat offenders.

The Netherlands runs a split model: Logius / Digitoegankelijk drives the mature public-sector monitoring programme, while the ACM (Authority for Consumers and Markets) handles private-sector consumer enforcement. The Dutch approach leans on transparency and status disclosure — covered services are expected to publish whether they are fully, partially or non-conformant, with a remediation plan for anything less than full. Persistent partial-conformance status without visible progress is precisely what invites ACM attention, so the declared status is treated as an enforcement signal, not a formality.

Practical first steps for a Netherlands site

If you are starting now and want to land before enforcement, run an automated audit, fix the high-impact issues (contrast, labels, keyboard, focus), publish an accessibility statement, and set up a feedback inbox. That sequence covers 80% of what auditors look for in a first sweep.

• Run a baseline scan to know your current score

• Fix critical and serious issues in priority order — these are the ones cited in complaints

• Publish a public accessibility statement on a stable URL (Netherlands regulators expect this discoverable)

• Add a feedback channel and answer within the country-specified window

• Re-scan after every major release; track regressions