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.

If your service reaches consumers in Netherlands, EAA enforcement applies the same way it does to a domestic provider. The "country of consumption" rule means a Shopify store run from outside the EU but selling into Netherlands is covered. There is no carve-out for non-EU sellers.

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.

Logius (public sector) and ACM (private sector) runs the audits. They start with the largest covered services and move down. The first cycle of EAA audits in 2025–2026 will focus on visible non-compliance — missing accessibility statements, obvious WCAG violations on the homepage, lack of feedback channel — because those are cheap to detect. Deep technical audits come later.

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

Frequently asked questions

Accessibility law in nearby jurisdictions