The European Accessibility Act: does it apply to your webshop?
The European Accessibility Act is Directive (EU) 2019/882. In the Netherlands it was transposed by the Implementatiewet toegankelijkheidsvoorschriften producten en diensten. It has applied since 28 June 2025 and requires businesses selling to consumers to make their website, app and customer documentation accessible.
Written by Julia Tol, senior accessibility auditor at Proper Access
The short answer
You fall under it if you sell to consumers in one of the listed sectors and you are not a microenterprise. You only count as a microenterprise when both conditions hold at once: fewer than 10 staff and an annual turnover or balance sheet total of at most € 2 million. Meet one of the two but not both, and the law applies to you in full. That is the mistake we run into most often.
Which sectors it covers
The law names the products and services explicitly, so this is not an open norm you estimate for yourself. If you sell online to consumers, you are almost always in the first category.
- Webshops and other e-commerce aimed at consumers
- Consumer banking services, including online banking
- E-books and the software you read them in
- Electronic communication services, and access to the 112 emergency number
- Audiovisual media services, such as the site and app you pick programmes in
- Passenger transport: ticket sales, travel information and check-in machines
What you have to meet
The law itself sets no technical rules. It points at the European standard EN 301 549, and for the part about websites and apps that standard amounts to WCAG 2.1 at level AA. In practice you test against WCAG, not against the text of the law.
It reaches further than the website. The law also covers the information about the product, the customer support, and the way you explain how accessible your service is. A webshop that is technically sound but ships an inaccessible PDF manual is not done.
Why an automated scan is not enough here
A scanner finds 30 to 40 percent of the problems on a page. The rest needs someone operating the page with a keyboard and a screen reader: whether the order in your checkout makes sense, whether an error message says what to do, whether an alt text actually describes the image.
For the European Accessibility Act every success criterion has to be walked through. A scan report is a starting point, not evidence.
| Situation | Does the law apply? |
|---|---|
| Webshop, 25 staff, € 8 million turnover | Yes |
| Webshop, 6 staff, € 900,000 turnover | No, microenterprise |
| Webshop, 6 staff, € 4 million turnover | Yes, only one of the two limits is met |
| Webshop, 40 staff, € 1.5 million turnover | Yes, only one of the two limits is met |
| Sells exclusively to other businesses | No, the law is about consumers |
| Government body | No, the Dutch BDTO applies instead |
Common questions about the EAA
Since when does the European Accessibility Act apply?
Since 28 June 2025. The directive is (EU) 2019/882 and every member state has written it into its own law. There is no general transition period left to fall back on.
Does the EAA apply to my webshop?
Yes, unless you are a microenterprise. You only are one when both conditions hold at once: fewer than 10 staff and at most € 2 million in turnover or balance sheet total. Meet only one of those, and the law applies. A webshop with 6 staff and € 4 million in turnover is covered.
I only sell to other businesses. Am I covered?
No. The EAA covers products and services aimed at consumers. If you sell business to business only, this law does not reach you. Watch your clients, though: a public sector body has its own obligations and can pass those requirements on to what you deliver.
Which standard do I have to meet?
The law points to the European standard EN 301 549. For websites and apps that amounts to WCAG 2.1 level AA. We test against WCAG 2.2, because 2.2 contains everything in 2.1 and the standard is moving that way. It covers more than the website: product information, customer support and manuals fall under it too.
Is an automated scan enough to prove compliance?
No. A scanner finds 30 to 40 percent of the problems on a page. The UK government put 142 known barriers in a single page and ran thirteen scanners against it: the best found 40 percent, the worst 13 percent. The EAA requires every success criterion to be checked, and that takes someone operating the page with a keyboard and a screen reader.
What if I am a Dutch public sector body?
Then the BDTO applies to you instead. It has been in force since 1 July 2018 and asks for an accessibility statement in a public register on top of meeting the standard. The technical requirement is the same; the obligation around it is heavier.
Want to know where you stand?
An audit walks every success criterion, with assistive technology alongside, and gives you findings per element with a fix for each. Tell us what kind of organisation you are and we will say straight away whether the EAA or the Dutch BDTO applies to you.
Request a quoteDo you work for a public body?
Then the EAA does not apply to you, but the Dutch Tijdelijk besluit digitale toegankelijkheid overheid does. That asks for something different: a published accessibility statement with a compliance status.
Read about the BDTOLast updated: