Since 28 June 2025, webshops and booking sites have to be accessible to people with disabilities. Most business owners I talk to know that by now. What they don't know is what to do when their site isn't fully there yet. Two questions keep coming back: do I have to report this myself, and when can I say that fixing it is a disproportionate burden?
In this article I set out what is fixed, what you actually do and when it makes sense to get help.
Which sites this is about
The rules come from the European Accessibility Act (EAA). Among other things, they apply to e-commerce services. According to the ACM, the Dutch regulator, that means a website or app where you can buy, take out or book products and services. So a webshop is covered, but so is a site where customers book an appointment, a room or a class.
There is no transition period for services. They have had to comply since 28 June 2025.
Why this matters now
On 24 March 2026 the ACM published the results of its own investigation: 61 percent of the largest Dutch webshops are not digitally accessible. The ACM tested about 100 of the largest webshops and the sites of the largest telecom and energy providers. Another 33% had serious problems.
The examples are very familiar: an order button you can't activate with the keyboard, or a Captcha that isn't accessible. At that point someone simply cannot order. The ACM points the worst-performing large companies to areas for improvement, and those that don't improve, or not enough, risk enforcement.
In Belgium, the Economic Inspection of the FPS Economy checks whether e-commerce sites follow the rules. Those who don't risk administrative penalties of up to 200,000 euros or 6% of annual turnover.
Does it apply to you
According to the ACM, the obligations apply to businesses with 10 or more people employed and/or an annual turnover above 2 million euros. A micro-enterprise has fewer than 10 people employed and an annual turnover of at most 2 million euros. In the Netherlands, such a business does not have to meet the legal requirements. If you work with part-time or seasonal staff, you count them using the European Commission's SME user guide.
Belgium puts it differently. In July 2025 the FPS Economy wrote that micro-enterprises get "five years extra time" to adapt. So there it is a postponement, not a permanent exemption. If you sell to Belgian customers, it's wise to plan for that.
The reporting duty in the Netherlands
The rule is simple: if your e-commerce service is not, or not fully, accessible, you fix it immediately. If you can't, you report it to the ACM. The deadline depends on the impact on the customer. The ACM uses four levels:
- Critical: the service is unusable and the error can't be worked around.
- Serious: partly impossible, only worked around with a great deal of effort.
- Moderate: difficult, but no longer impossible.
- Minor: easy to work around.
Critical and serious problems must be reported within 1 week, moderate and minor ones within 1 month. If you've solved the problem within that period, you don't have to report it.
In the report you state which parts are not accessible and their impact level, along with a plan to make the service fully accessible. You only report again if the expected date of full accessibility moves, or if new problems appear with a higher impact level than you reported before.
The reporting form has a few steps: company details, your report, e-commerce service, electronic communications service and a review. You get a confirmation by email. The ACM only contacts you afterwards if it has further questions.
If you're active in several EU countries, you report to the regulator in each country, and you remain responsible for every report yourself. Whether Belgium has a similar reporting duty with fixed deadlines is best checked with the FPS Economy.
Disproportionate burden and fundamental alteration
Disproportionate burden means the cost of meeting one or more requirements is unreasonably high compared to the benefits for people with disabilities. You still have to meet all other requirements as far as possible. Two things explicitly don't count: lack of time or lack of knowledge. And if you receive external funding to make your site accessible, you can't rely on this exception.
The second exception is a fundamental alteration: the change would turn your service into a completely different service. According to the ACM, that doesn't happen often.
If you rely on either one, you report that too. You justify it per component and record your assessment in a document. You don't send it along, but it has to be ready, because the ACM can request it. The circumstances listed in Annex VI of Directive (EU) 2019/882 must be included.
What you don't have to do, and what you do
Videos, audio recordings and documents you put online before 28 June 2025 don't have to be accessible. Neither does third-party content you have no control over. What you do have to do is publish an accessibility statement on your site that visitors can easily find.
For Belgian customers, information about entering into, performing or cancelling a contract must also be clear and easy to find, in two formats, for example text and audio. Non-text content needs a perceivable alternative.
As the technical benchmark, the ACM refers to the EN 301 549 standard (v3.2.1) and WCAG 2.1 at level AA.
How I approach it
- Check whether you're a micro-enterprise. Count your staff using the European Commission's SME guide and keep the difference between the Netherlands and Belgium in mind.
- Appoint someone who is permanently responsible for accessibility, and make a plan with the steps needed.
- Test the ordering or booking flow first: can you do everything with the keyboard, does your Captcha work for everyone? That's where the critical problems are.
- Give each problem an impact level and fix what you can fix straight away.
- If that's not possible within the deadline, report to the ACM with a remediation plan and an expected end date. Report again if that date moves.
- Considering disproportionate burden? Record a justified assessment per component following Annex VI and report it.
- Publish an easy-to-find accessibility statement on your site.
- Active in several countries? Report to the regulator in each one.
When to outsource it
You can do most of the inventory and the statement yourself. As soon as it involves changes to your theme, your checkout or a third-party module, you need someone who can read and change the code. A critical problem has to go quickly, and you can only write a report with a realistic remediation plan once you know how much work it is.
I do that kind of work as part of maintenance and security. If you want to know where your site stands now, get in touch.
