The Dutch BDTO: what the law asks of a government website
The Tijdelijk besluit digitale toegankelijkheid overheid, BDTO for short, has applied to every Dutch public body since 1 July 2018. It asks two things: your website and app meet the standard, and you publish an accessibility statement about them in the public register.
Written by Julia Tol, senior accessibility auditor at Proper Access
The short answer
Every Dutch government website and app has to meet EN 301 549, which for the web part amounts to WCAG 2.1 level AA. On top of that comes an accessibility statement in the register at toegankelijkheidsverklaring.nl. That statement gets a compliance status from A to E, and the status is public: anyone can look up where your organisation stands.
Who it applies to
The decree names public bodies: central government, provinces, municipalities, water authorities, bodies governed by public law and partnerships between them. In practice it also covers plenty of organisations that do not think of themselves as government, such as independent administrative bodies and organisations with a statutory task.
If you supply a website or application to a Dutch public body as a company, the decree does not bind you directly. Your client does have to comply, so it reaches you through the contract anyway.
The deadlines have already passed
This is where most of the confusion sits: there is no deadline coming. They have all passed, and the obligation has simply been running ever since.
- Websites published after 23 September 2018: had to comply by 23 September 2019
- Websites that already existed before that: 23 September 2020
- Mobile apps: 23 June 2021
The statement is the evidence, not the website
What the BDTO is checked on is the statement in the register. That statement calls for research: which part of the site was examined, by whom, when, using which method, and which deviations were found. A statement without research is a statement that does not meet the law.
That makes the status fairer than it looks. Status B does not mean you have your house in disorder; it means you had it examined, you know what is wrong and you work on it every year. That meets the law. Status D and E mean the research is not there.
| Status | What it means | Does it meet the law? |
|---|---|---|
| A | Complete and recent research, less than three years old, and no deviations found | Yes |
| B | Complete and recent research, deviations were found | Yes, if the measures are described and there is improvement every year |
| C | A statement without complete research, valid for six months, for a site being retired or examined within six months | Temporarily |
| D | A statement without suitable research, and none is planned either | No |
| E | No statement has been published at all | No |
Common questions about the BDTO
Who does the BDTO apply to?
Every Dutch public body: central government, provinces, municipalities, water authorities, bodies governed by public law and their joint arrangements. Independent administrative bodies and organisations with a statutory task are covered too, even when they do not think of themselves as government.
When was the deadline?
All of them have passed. Websites published after 23 September 2018 had to comply by 23 September 2019, older websites by 23 September 2020, and mobile apps by 23 June 2021. No new deadline is coming; the obligation has simply been running ever since.
How many compliance statuses are there?
Five: A to E. A is fully compliant, B partially, C first measures taken, D does not comply, and E means there is no statement at all. That last one is the one people forget, and it is where you end up automatically if you do nothing.
Does status B mean I am breaking the law?
No. Status B complies as long as the measures are described and there is improvement every year. It says you had the site audited, know what is wrong and are working on it. Status D and E mean the audit is missing, and that is a different matter.
What is actually checked, the website or the statement?
The statement in the register. It asks for an audit: which part of the site was examined, by whom, when, using which method, and which failures were found. A statement without an audit behind it does not meet the law, even when the site itself is fine.
Can I fill in the statement based on an automated scan?
Not entirely. A scanner finds 30 to 40 percent of the problems on a page, and the statement asks about the audit method. A statement with status A or B should have a manual audit behind it in which every success criterion has been checked.
From status D or E to a statement that holds up
Status A or B needs research that walks every success criterion. You get a report per element from us, with a user story from the visitor's side for each finding and a concrete fix, so you can carry it straight into the statement.
Request a quoteDo you sell to consumers?
Then the BDTO does not apply to you, but the European Accessibility Act may well. It has been in force since 28 June 2025 and works from a completely different threshold.
Read about the EAALast updated: