Accessibility of e-commerce services and electronic communications services

On this page:

• E-commerce services and electronic communications services must be accessible
• Rules for e-commerce services and electronic communications services
• Additional rules for e-commerce services
• Additional rules for electronic communications services
• Supporting products for your service
• Parts that do not need to be accessible
• Exceptions
• Reporting obligation for non-accessible services
• Enforcement of the accessibility rules
• Sources

E-commerce services and electronic communications services must be accessible

Do you employ 10 or more people, or do you have an annual turnover of more than 2 million euros, or both? If so, your e-commerce service must be accessible to all consumers. The same applies to electronic communications services.

E-commerce services

An e-commerce service is an online service where consumers can take out a contract online. These are websites and apps where a consumer can purchase, rent, order, take out, or reserve something. This can be anything, from products to digital services or subscriptions.

Examples of e-commerce services are:

• Online stores selling clothes, groceries, books, or electronics;
• Booking platforms for hotels, flights, or concert tickets;
• Apps for ordering meals, rides, or hiring a babysitter; and
• websites for taking out subscriptions to magazines, telecommunications services, broadband services, or energy contracts.

This concerns all types of websites or apps with offers for consumers, even if you only offer products or services in a small section of your website or app, or if the offers on your website come from other sellers, for example on an online platform, or if consumers do not need to pay any money for the offer, but they do need to pay with personal data.

Electronic communications services

An electronic communications service allows consumers to communicate electronically or digitally. Examples are services for internet, telephony, email, chat, and video calls.

Accessibility obligation

As a provider of an e-commerce service or electronic communications service, you must ensure that your website and app are accessible to everyone. This applies to everything that is related to the online conclusion of an agreement, such as the process of searching, choosing, logging in, and paying. With regard to electronic communications services, this applies to everything that is related to the internet service, calling, chatting, emailing or video calling. As the provider, you are responsible for accessibility, even if, for example, you hire another company to build your website or app.

If your website and app are accessible, most consumers will be able to buy products, conclude contracts, or communicate online independently, hassle-free, and without any help from others. This includes consumers with disabilities, for example individuals with visual or hearing impairments, and individuals who struggle to move, talk, or concentrate. If your website and app are accessible, it will enhance the user experience for everyone.

Rules for e-commerce services and electronic communications services

Please make sure that your e-commerce service and your electronic communications service comply with all the accessibility rules. This follows from the European Accessibility Act (EAA).

Accessibility principles

Please make sure that your website and app fully comply with the four basic principles of accessibility.

International standard

The four basic principles have been worked out further in the international standard for digital accessibility: the WCAG (Web Content Accessibility Guidelines) 2.1. Your website and app must comply with level AA of this standard. This means that you must comply with accessibility levels A and AA.

Attention: in the course of 2026, WCAG 2.2 level AA will become the new standard for digital accessibility. We recommend getting started now with Web Content Accessibility Guidelines (WCAG) 2.2. In this way, you will be well prepared, and you avoid having to make new adjustments soon.

Audit certificate is not mandatory

You do not need to have proof of accessibility for your website or app. Therefore, an independent WCAG audit or inspection is not mandatory. A certificate, label, or quality mark is not required either, but you can obtain one if you want to. The most important thing is that your website and app are accessible.

Real-world examples

Do you want to know more about what the four basic principles of accessibility mean in practice?

• Real-world accessibility issues

Accessibility statement

You publish a statement on your website and app, explaining how your service complies with the accessibility rules. This statement must be easy-to-find for consumers, and must be accessible. In your statement, you explain how your service works, including how it works with assistive tools, and how you comply with the accessibility rules. This statement must also be offered verbally, for example in an audio clip with the text read aloud.

Accessible customer service

Your helpdesk or call center must provide information about the accessibility of your service in a way that is accessible to everyone.

Being and remaining accessible

If part of your website or app is not accessible, you must restore accessibility. In addition, with every change on your website or app, you must ensure that your e-commerce service remains accessible. Ensuring an accessible website or app is not a one-off action. Create a procedure for this, and stay up-to-date with the latest industry developments.

Additional rules for e-commerce services

The following additional rules apply to e-commerce services.

Information about the accessibility of products and services

You must also provide information about the accessibility of the products or services offered on your website and app. This allows consumers to have that information before purchasing anything. The manufacturer or supplier of the products, or the supplier of the services you sell, must provide this information to you.

Digital signatures

If consumers need to sign contracts digitally, make sure they can do so in an accessible way, such as by having simple software that anyone can use.

Identification and payment

Logging in to a website or paying for a product or service must be accessible for everyone. Make sure that the payment services and identification methods you offer are also accessible. If you send emails or other documents, such as attachments, that are necessary for logging in or for paying, make sure that they are also accessible.

Additional rules for electronic communications services

The following additional rules apply to electronic communications services.

Real-time text

If you offer an electronic communications service that enables consumers to communicate using their voices, please make sure that consumers are also able to communicate via real-time text (RTT). This allows users to see during a conversation what the other person is typing, letter by letter, without having to wait, for example during a phone call. This allows individuals with hearing or speech impairments, for example, to take part in conversations properly, too.

Total conversation

If your communications service offers the ability to make video calls, you must do so in accordance with the ‘total conversation’ standard. According to this standard, users of a video service must be able to see, hear, and communicate with each other via real-time text at the same time.

Supporting products for your service

If you provide consumers a product so that they are able to use your service (for example, a modem for your internet subscription as a communications service), that supporting product must also comply with the accessibility rules, for example, an accessible user manual. If you wish to know more, please refer to sections I and II of Annex I to the European Accessibility Act (EAA).

On your website and app, you must also provide information about the accessibility of the supporting products, and about how the consumer’s assistive tools can be used with the supporting products.

Transitional period for supporting products

You do not need to immediately replace any supporting products that are not yet compliant. You have until 28 June 2030 to do so.

Parts that do not need to be accessible

Some parts of your website do not need to comply with the accessibility requirements. Read more what parts do not need to comply.

Old videos or sound recordings from before 28 June 2025

If you uploaded any videos, sound files, or animations on your website or app before 28 June 2025, you do not need to adjust these. This means you do not need to add subtitles, audio descriptions, or transcripts to these types of old media.

Documents from before 28 June 2025

If you have any office files, such as PDF or Word documents, on your website or app that you uploaded to your website before 28 June 2025, these do not need to be made accessible. However, all files that you have posted since 28 June 2025 must be accessible.

Navigation maps

If you display a navigation map on a website or app, for example, a map showing the location of your business, a clear route description in accessible text will suffice. You do not need to describe navigation maps.

Archives

If you have any old content on your website or app that you have not modified or updated since 28 June 2025, for example, old information that will not change anymore, this information is referred to as archives. You do not need to make archives accessible.

Content of others that you have no control over

If your website or app contains content from others, for example, posts or images posted by users themselves, and you have not commissioned this content yourself, paid for it, nor have no control over it, then this content does not need to be accessible. We refer to this as third-party content.

Exceptions

E-commerce services and electronic communications services must meet the statutory requirements for accessibility. However, there are exceptions:

Microenterprises

If you employ fewer than 10 people, and you have an annual turnover that does not exceed 2 million euros, your company is considered a ‘microenterprise’. Microenterprises are not required to comply with the statutory requirements for accessibility.

The European Commission’s user guide contains additional information about microenterprises, such as how to count the number of employees in the case of part-time or seasonal work.

Other exceptions: fundamental alteration and disproportionate burden

There are two exceptions where you do not have to fully meet the accessibility requirements.

If you are unable to fully comply with the accessibility rules, and you fall into one of the two below exceptions, you must report this to us. You must properly substantiate this, while indicating what elements are involved, and you must record your assessment in a document. You do not need to send your substantiated assessment straight away, but you must have it ready, as we may ask for it.

Fundamental alteration: your service will change too much

If, in order to comply with the law, you need to alter your e-commerce service or electronic communications service to such an extent that it becomes a completely different service, it is referred to as a ‘fundamental alteration’ under the law. In that case, you need to comply with as many accessibility rules as possible. You do not need to comply with those parts of the rules that will change your e-commerce service to such an extent that it becomes a completely different service. Cases like these are rare.

Disproportionate burden: costs are too high or efforts are too great

If the costs that you need to incur for complying with one or more accessibility requirements are unreasonably high in relation to the benefits for people with disabilities, it is referred to as a ‘disproportionate burden’ under the law. In that case, you need to comply with as many accessibility rules as possible. You do not need to comply with those parts of the rules for which the costs are too high or the efforts are too great. If you lack the time or knowledge, it is not considered a disproportionate burden. If you receive external funding for making your website or app accessible, you cannot invoke this exception.

Please refer to Annex VI to the European Accessibility Act (EAA) for more details about the circumstances that are taken into account when assessing whether something truly is a disproportionate burden. You must include these circumstances in your assessment.

Reporting obligation for non-accessible services

If your e-commerce service or electronic communications service is not (or not fully) accessible in accordance with the rules, you must report this to us.

What you need to report

You indicate what parts of your service are not accessible, as well as the level of the impact that the accessibility problem has on consumers. You must also draw up a plan for making your service fully accessible. You must send this plan along with your report.

Even if you invoke the fundamental-alteration exception or the disproportionate-burden exception (in Dutch), you must report this to us.

• Reporting obligation for non-accessible services

Levels of impact on consumers

We distinguish between four levels of impact on consumers: critical, serious, moderate, and minor.

Critical:

A critical problem makes it impossible for users with disabilities to use the service. Users cannot circumvent these critical accessibility issues. The only option is to close the website completely.

Serious:

A serious problem makes it partially impossible for users with disabilities to use the service. These are major accessibility issues that users are only able to circumvent with great effort.

Moderate:

A moderate problem makes it difficult for users to use the service, but not to the extent that it is impossible (partially or fully).

Minor:

A minor problem is one that users are easily able to circumvent, enabling them to use the service.

Reporting deadline

If your e-commerce service or electronic communications service is not accessible, you will need to solve this immediately. If you are unable to do so, you need to report this to us.

Reporting within one week or one month

How soon you need to do so depends on the impact that the accessibility problem has on consumers.

• One week: problems with a ‘critical’ or ‘serious’ impact must be reported to us within one week. You do not need to do so if you have already resolved the problem within a week.
• One month: problems with a ‘moderate’ or ‘small’ impact must be reported to us within one month. You do not need to do so if you have already resolved the problem within a month.

Filing a report again

In the report form, you enter the date on which you expect your service to be fully accessible. If new problems occur after filing your report, you only need to file a new report if:

• The impact level of the new problems is higher than what you have reported to us; or
• The date on which your service is fully accessible changes.

Active in multiple EU Member States

If you are active in multiple EU Member States, you must register with the relevant regulator of each country in which you are active. Please note that you need to deal with multiple regulators. Regulators also work together. You remain responsible yourself for filing reports in each country.

Enforcement of the accessibility rules

Since 28 June 2025, e-commerce services and electronic communications services must comply with the statutory rules on accessibility. There is no transitional period for services. Please make sure your service is and remains accessible. This will help you avoid fines.

The Netherlands Authority for Consumers and Markets (ACM) is the regulator charged with overseeing whether e-commerce services and electronic communications services are accessible in accordance with the law. Consumers are able to file reports with us if they notice that your website or app is not accessible. We also select websites and apps to investigate ourselves. Our enforcement actions depend on the magnitude of the problems, and on what steps companies are taking to solve those problems.

Sources

• European Accessibility Act (EAA)
• European technical accessibility requirements EN 301 549
• WCAG (Web Content Accessibility Guidelines) 2.1 on level AA