ACM Accessibility Requirements: Dutch EAA Compliance Guide
The Netherlands has transposed the European Accessibility Act into national law. The ACM (Authority for Consumers & Markets) enforces digital accessibility requirements. Here's what Dutch businesses need to know.
Key Dates and Facts
June 28, 2025
EAA enforcement began in the Netherlands
ACM is the enforcement body
Autoriteit Consument & Markt
Besluit digitale toegankelijkheid
Dutch transposition of the EAA
EN 301 549 / WCAG 2.1 AA
Technical standard required
What is the ACM?
The Autoriteit Consument & Markt (ACM) is the Netherlands' independent regulator for competition, consumer protection, and market oversight. Under the Dutch implementation of the European Accessibility Act, the ACM is responsible for enforcing digital accessibility requirements.
The ACM can investigate complaints, conduct inspections, issue warnings, and impose fines for non-compliance. They work alongside other regulators including the Dutch Data Protection Authority (AP) for accessibility issues related to data processing.
Covered Products and Services
The EAA covers specific categories of digital products and services. If your business offers any of the following to consumers in the Netherlands (or broader EU), accessibility requirements apply:
E-commerce
- Online shops and marketplaces
- Product comparison websites
- Auction platforms
- Ticketing services
Banking & Finance
- Online banking websites
- Investment platforms
- Insurance portals
- Payment services
Transport
- Travel booking websites
- Public transport apps
- Flight and train ticket platforms
- Car sharing services
Telecommunications
- Telecom provider websites
- VoIP services
- Messaging platforms
- Video calling services
E-books & Media
- E-book platforms and readers
- Digital publishing services
- Streaming services (certain categories)
- News websites with paid content
Exemptions
- -Microenterprises: Fewer than 10 employees AND annual turnover or balance sheet under €2 million
- -Content not controlled by provider: User-generated content, archived content (pre-2019), third-party content under separate contract
- -Disproportionate burden: Must be documented and reported in accessibility statement
Reporting Timelines and Requirements
While the EAA does not specify exact remediation timelines, Dutch regulatory guidance and industry best practices suggest the following response times for accessibility issues:
Critical Issues
Complete barriers to access
Issues that completely prevent users from completing essential tasks (e.g., cannot complete checkout, cannot access account).
Serious Issues
Significant barriers
Issues that make tasks difficult but not impossible (e.g., missing form labels, poor color contrast).
Moderate Issues
Minor barriers or inconveniences
Issues that cause frustration but don't prevent task completion (e.g., inconsistent navigation, minor contrast issues).
Documentation Requirements
Regardless of remediation timeline, you should maintain records of:
- When issues were discovered
- Remediation efforts and timelines
- When issues were resolved
- Any claims of disproportionate burden (with justification)
Accessibility Statement Requirements
The EAA requires an accessibility statement (toegankelijkheidsverklaring) that describes your product or service's conformance with EN 301 549. This statement must be:
Required Elements
- 1Conformance status
Fully conformant, partially conformant, or non-conformant with EN 301 549
- 2Known limitations
List of non-accessible content with reasons and alternatives provided
- 3Preparation method
How the statement was prepared (self-assessment, external audit, automated testing)
- 4Feedback mechanism
How users can report accessibility issues and request accessible alternatives
- 5Enforcement procedure
Link to enforcement body (ACM) for complaints
- 6Date of preparation/update
When the statement was last reviewed
Generate Your Accessibility Statement
inclly can generate an EU-compliant accessibility statement from your scan data. The statement includes all required elements and is formatted according to the EU model template.
Generate StatementSteps to Compliance
Audit your current state
Use automated scanning tools to identify EN 301 549 issues, then conduct manual testing for issues that require human judgment.
Start with an automated scan to get a baseline of issues.
Prioritize and remediate
Fix critical issues first (complete barriers), then serious issues, then moderate issues. Document your remediation efforts.
Create a remediation roadmap with realistic timelines.
Create your accessibility statement
Document your conformance status, known limitations, and provide contact information for accessibility feedback.
Publish the statement on your website (typically in footer).
Monitor continuously
Accessibility is not a one-time fix. Schedule regular scans and audits to catch new issues as your site evolves.
Set up weekly or monthly automated scans.
Train your team
Ensure developers, designers, and content creators understand accessibility requirements and can prevent issues from being introduced.
Establish accessibility guidelines for new content.
Frequently Asked Questions
What happens if I receive an ACM complaint?
The ACM will first investigate the complaint and may request information about your accessibility efforts. They typically give businesses an opportunity to remediate issues before taking enforcement action. Maintain documentation of your accessibility efforts to demonstrate good faith compliance.
Do I need to hire an external auditor?
External audits are not legally required, but they can strengthen your compliance position. A combination of automated scanning (like inclly) and internal manual testing covers most requirements. Consider external audits for high-risk services or if you need third-party validation for legal or contractual reasons.
What if I can't fix an issue due to technical limitations?
Document the issue in your accessibility statement as a known limitation. Explain why it cannot be fixed and what alternatives you provide. If the cost would be disproportionate to your organization's resources, document the disproportionate burden claim with supporting analysis.
How often should I update my accessibility statement?
Update your statement whenever you make significant changes to your product or service, when you fix or discover new accessibility issues, or at minimum once per year. The statement should reflect the current state of your product.
Does the EAA apply to B2B services?
The EAA primarily covers products and services offered to consumers. B2B-only services may be exempt. However, if your B2B service also has consumer users (e.g., employees of your clients), the consumer-facing parts may still need to comply.
Continue Learning
Explore related guides to support your Dutch accessibility compliance.
EAA Compliance Checklist
EN 301 549 Chapter 9 web requirements mapped to WCAG 2.2 criteria.
European Accessibility Act
What US and UK businesses need to know about the EAA in 2026.
EN 301 549 Guide
The European accessibility standard explained with chapter breakdowns.
EAA vs WCAG
How the European Accessibility Act relates to WCAG and what compliance means.
Ready to Get Started?
inclly helps Dutch businesses achieve EAA compliance with automated scanning against EN 301 549 requirements, detailed remediation guidance, and EU-compliant accessibility statement generation.