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European Accessibility Act: Netherlands
NL- Applies from
- 2025-06-28
- Maximum penalty
- No single fixed euro figure — see why.
- Enforcement authority
- Split by sector: Autoriteit Consument & Markt (ACM) for e-commerce, with the AFM for financial services; Commissariaat voor de Media for e-books and access to audiovisual media services; Inspectie Leefomgeving en Transport for passenger transport; the minister responsible for the Warenwet for products — https://www.acm.nl
- Microenterprise exemption
- Yes — under the EAA's EU-wide microenterprise exemption for services
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- National law
- Implementatiewet toegankelijkheidsvoorschriften producten en diensten (Stb. 2024, 87)
- Notes
- No single cap: the Dutch act amends existing laws, so each sector keeps its own enforcer and fine. E-commerce: the ACM can fine up to €900,000 or, if higher, 1% of the offender's turnover, doubled for a repeat within five years (Wet handhaving consumentenbescherming, art. 2.15). Products (Warenwet, art. 35e), e-books and access to audiovisual media services (Commissariaat voor de Media) and passenger transport (Inspectie Leefomgeving en Transport): up to the fifth fine category of the Criminal Code, €110,000 since 1 January 2026 (Wetboek van Strafrecht, art. 23). Electronic communications and financial services fall under their own sector legislation.
Who is obligated in Netherlands
The law covers a defined list: webshops and customer service channels, laptops and smartphones, ATMs and public transport ticket and check-in machines, and the 112 emergency number, among others. Manufacturers, authorised representatives, importers, distributors, and service providers all have obligations, not just the final business facing the consumer. The small-enterprise exemption follows the EU-wide threshold — fewer than 10 employees, turnover or balance sheet under €2 million — but only for services. A small enterprise placing a covered product on the market still has to make that product accessible.
What happens if you don't comply
The ACM investigates based on complaints, its own market analysis, or both, and has real investigative teeth: it can demand information, hear the parties involved, and carry out unannounced visits to secure evidence. Its main enforcement tool is the last onder dwangsom (order under penalty) — rather than jumping straight to a fine, the ACM orders the business to stop the violation and fix its product or service by a deadline; only if it doesn't comply, or doesn't comply enough, does it start owing penalty payments, which can accumulate. For e-commerce it can also impose a fine of up to €900,000 or 1% of turnover if that is higher, doubled for a repeat within five years; other sectors have their own enforcers, with fines of up to €110,000.
How this differs from the EU baseline
On the transition period the Netherlands transposes the Directive rather than departing from it: Artikel VIII of the implementing act mirrors Article 32. Service providers may keep delivering their services using products they were already lawfully using, until 27 June 2030; service contracts concluded before 28 June 2025 may continue unchanged until they expire, for at most five years; and self-service terminals lawfully in use before that date may run to the end of their economic life, capped at 20 years from first use. The relief is worded around products used to deliver a service and around pre-existing contracts. It does not say that a service itself, such as an existing website or app, may stay non-compliant until 2030.
How to complain
Complaints and signals go to the ACM, which factors them into deciding where to investigate. The ACM's own site has the current channel for submitting a signal about a specific business or product.
Frequently asked questions about the EAA in Netherlands
- What is the maximum EAA fine in Netherlands?
- Netherlands does not set a single fixed euro maximum in its implementing law. No single cap: the Dutch act amends existing laws, so each sector keeps its own enforcer and fine.
- Who enforces the European Accessibility Act in Netherlands?
- Split by sector: Autoriteit Consument & Markt (ACM) for e-commerce, with the AFM for financial services; Commissariaat voor de Media for e-books and access to audiovisual media services; Inspectie Leefomgeving en Transport for passenger transport; the minister responsible for the Warenwet for products. Details are published at https://www.acm.nl.
- Since when does the EAA apply in Netherlands?
- The requirements apply from 28 June 2025, the EU-wide date, transposed into Netherlands by Netherlands's national implementing law.
- Are small businesses exempt from the EAA in Netherlands?
- Only microenterprises — fewer than 10 staff and annual turnover or balance sheet total of €2 million or less — and only for services. A microenterprise in Netherlands that places a covered product on the market still has to make that product accessible.
Official source: https://zoek.officielebekendmakingen.nl/stb-2024-87.html
Verified on 2026-09-29. This page is not legal advice — verify against the official source above before making compliance decisions.