European Accessibility Act: Complete Compliance Guide for the Netherlands and EU
Everything you need to know about EAA compliance, deadlines, requirements, fines, and how to ensure your digital products and documents meet accessibility standards.
EqualXS Compliance Team
Updated January 2, 2026
The European Accessibility Act (EAA), officially Directive (EU) 2019/882, came into effect on June 28, 2025, fundamentally changing accessibility requirements for businesses operating in the European Union. Unlike previous regulations that focused primarily on public sector organizations, the EAA extends comprehensive accessibility standards to private sector companies, creating new compliance obligations for businesses of all sizes.
For organizations operating in the Netherlands and broader EU market, understanding and implementing EAA compliance is no longer optional—it's a legal requirement with significant financial and reputational consequences for non-compliance. This guide provides a comprehensive overview of what the EAA means for your organization, who must comply, and how to ensure your digital products and documents meet the required accessibility standards.
What is the European Accessibility Act?
The European Accessibility Act is a landmark piece of EU legislation designed to improve the functioning of the internal market for accessible products and services by removing barriers created by divergent accessibility requirements in different member states. The directive establishes common accessibility requirements for specific products and services, particularly those identified as being most important for persons with disabilities.
The EAA builds upon the Web Accessibility Directive (Directive (EU) 2016/2102), which applies to public sector bodies' websites and mobile applications. While the Web Accessibility Directive focused exclusively on government and public sector digital properties, the EAA significantly expands the scope to include private sector businesses offering certain products and services to EU consumers.
Key Differences: EAA vs. Web Accessibility Directive
Understanding how the EAA differs from existing regulations is crucial:
- Scope: The Web Accessibility Directive applies only to public sector websites and mobile apps. The EAA extends to private sector businesses offering covered products and services.
- Coverage: The EAA covers a broader range of products and services, including e-commerce platforms, banking services, e-books, and transport ticketing systems.
- Enforcement: Member states have implemented different enforcement mechanisms, with penalties ranging from corrective action requirements to substantial fines.
- Timeline: While the Web Accessibility Directive has been in effect since 2016, the EAA enforcement began on June 28, 2025.
Who Must Comply with the EAA?
The EAA applies to businesses operating in or serving customers within the European Union that provide specific products and services. Importantly, compliance requirements extend to companies based outside the EU if they offer covered products or services to EU consumers.
Covered Sectors and Services
The EAA specifically mandates accessibility for the following sectors:
E-commerce and Digital Services
Online retail platforms, marketplaces, and digital storefronts must ensure their websites, mobile applications, and digital purchasing processes are fully accessible. This includes product catalogs, shopping carts, checkout processes, and customer service interfaces.
Banking and Financial Services
Consumer banking services, including online banking platforms, mobile banking applications, ATMs, and self-service payment terminals must meet accessibility standards. This extends to loan applications, account management systems, and financial product information.
Telecommunications
Electronic communications services, including voice and messaging services, must be accessible. This includes both the service interfaces and customer support systems.
Transportation Services
Air, bus, rail, and waterborne passenger transport services must provide accessible websites, mobile applications, and electronic ticketing systems. This includes real-time travel information, booking systems, and ticket validation.
Audiovisual Media Services
Providers of audiovisual media services must ensure their content, platforms, and program guides are accessible, including proper captioning, audio description, and accessible electronic program guides.
E-books and Digital Publications
Digital books, dedicated e-reader devices, and reading software must be accessible, allowing persons with disabilities to access, navigate, and interact with digital publications effectively.
Exemptions and Special Provisions
The EAA includes limited exemptions, most notably for micro-enterprises:
- Micro-enterprise exemption: Businesses with fewer than 10 employees and annual turnover or balance sheet not exceeding €2 million may be exempt from certain requirements, though this varies by member state implementation.
- Disproportionate burden: Organizations may claim exemption if compliance would impose a disproportionate burden, though this requires detailed justification and is subject to regulatory approval.
- Fundamental alteration: If compliance would require a fundamental alteration to the nature of a product or service, exemption may be possible, but the threshold for this is very high.
Critical Deadlines and Timeline
Understanding the EAA's implementation timeline is crucial for planning your compliance strategy:
June 7, 2019
Directive (EU) 2019/882 officially published. Member states given three years to transpose into national law.
June 28, 2022
Transposition deadline. All EU member states required to implement the EAA into national legislation. The Netherlands implemented the directive through amendments to existing accessibility legislation.
June 28, 2025 — NOW IN EFFECT
Application date. All covered products and services placed on the market after this date must comply with accessibility requirements. Enforcement began, with market surveillance authorities empowered to take action against non-compliant products and services.
For products and services already on the market before June 28, 2025, there are specific transition provisions. However, organizations should not rely on these exceptions and should instead prioritize bringing all offerings into compliance as quickly as possible.
Required Accessibility Standards
The EAA references specific technical standards that define what "accessible" means in practical terms. Understanding these standards is essential for compliance:
EN 301 549: The Primary Standard
EN 301 549 "Accessibility requirements for ICT products and services" is the harmonized European standard referenced by the EAA. This comprehensive standard covers:
- Web content accessibility (incorporating WCAG 2.1 Level AA)
- Non-web documents (including PDF, Word, and other digital formats)
- Software (both web and non-web)
- Hardware (including ICT with two-way voice communication and video capabilities)
- Support documentation and services
The current version, EN 301 549 V3.2.1, incorporates WCAG 2.1 Level AA requirements for web content. An update to reference WCAG 2.2 is expected, meaning organizations should plan for WCAG 2.2 Level AA compliance now rather than waiting for the formal standard update.
WCAG 2.2 Level AA
The Web Content Accessibility Guidelines (WCAG) 2.2, developed by the W3C's Web Accessibility Initiative, provides the technical requirements for web content accessibility. WCAG 2.2 Level AA includes 55 success criteria organized under four principles:
1. Perceivable
Information and user interface components must be presentable to users in ways they can perceive. This includes:
- Providing text alternatives for non-text content
- Providing captions and alternatives for multimedia
- Creating content that can be presented in different ways without losing information
- Making it easier for users to see and hear content including separating foreground from background
2. Operable
User interface components and navigation must be operable. This includes:
- Making all functionality available from a keyboard
- Providing users enough time to read and use content
- Not designing content in a way that is known to cause seizures
- Providing ways to help users navigate, find content, and determine where they are
3. Understandable
Information and the operation of the user interface must be understandable. This includes:
- Making text readable and understandable
- Making content appear and operate in predictable ways
- Helping users avoid and correct mistakes
4. Robust
Content must be robust enough to be interpreted reliably by a wide variety of user agents, including assistive technologies. This includes:
- Maximizing compatibility with current and future user tools
- Ensuring parsing and proper use of markup
PDF/UA (ISO 14289)
PDF/UA (Universal Accessibility) is the ISO standard for accessible PDF documents. Given that PDFs remain widely used for contracts, reports, forms, and other business-critical documents, PDF/UA compliance is essential for most organizations.
PDF/UA ensures that PDF documents are:
- Properly tagged with semantic structure
- Readable by screen readers in logical order
- Navigable using assistive technologies
- Compatible with text-to-speech conversion
- Usable by persons with low vision or color blindness
PDF Accessibility Requirements in Detail
PDF documents present unique accessibility challenges. Research shows that over 90% of PDF documents fail accessibility audits, making PDF remediation one of the most critical—and often overlooked—aspects of EAA compliance.
Why PDFs Fail Accessibility Audits
Most PDFs are created as "print-ready" documents without consideration for digital accessibility. Common issues include:
- Lack of proper document structure and semantic tags
- Images without alternative text descriptions
- Tables without proper header associations
- Forms with unlabeled fields
- Incorrect reading order that confuses screen readers
- Insufficient color contrast for text and graphics
- Scanned documents without OCR or proper tagging
Technical Requirements for Accessible PDFs
To meet PDF/UA and WCAG 2.2 AA standards for non-web documents, PDFs must include:
Document Structure and Tags
Every PDF must include a complete tag tree that represents the logical structure of the document. This includes:
- Heading tags (H1-H6) for document hierarchy
- Paragraph tags for body text
- List tags for bulleted and numbered lists
- Table tags with proper structure
- Figure tags for images and graphics
Alternative Text for Images
All meaningful images must include alternative text that conveys the same information as the image. Decorative images should be marked as artifacts so screen readers skip them. Alt text should be:
- Concise but descriptive
- Meaningful and contextually relevant
- Properly associated with the image element
Reading Order
The content reading order must be logical and match the visual presentation. Screen readers follow the tag order, so documents with multiple columns, sidebars, or complex layouts require careful attention to ensure information is presented in the correct sequence.
Table Accessibility
Data tables must include:
- Properly marked table headers (TH tags)
- Header-data cell associations
- Table summaries for complex tables
- Proper nesting for multi-level headers
Form Fields
Interactive PDF forms require:
- Properly labeled form fields
- Tooltips for additional instructions
- Logical tab order
- Programmatic field type identification
Color Contrast
Text and graphical elements must meet WCAG 2.2 Level AA color contrast requirements:
- 4.5:1 contrast ratio for normal text (smaller than 18pt or 14pt bold)
- 3:1 contrast ratio for large text (18pt or 14pt bold and larger)
- 3:1 contrast ratio for graphical objects and UI components
Document Types Requiring Special Attention
- Financial statements and reports: Often contain complex tables, charts, and graphs requiring detailed alternative descriptions
- Legal contracts: Must maintain exact formatting while ensuring accessibility, often requiring specialized expertise
- Annual reports: Typically include infographics, photos, and complex layouts
- Product catalogs: Heavy use of images requiring meaningful alternative text
- Forms and applications: Interactive elements requiring proper labeling and structure
- Technical documentation: May include code samples, diagrams, and specialized notation
Fines, Penalties, and Enforcement
The EAA delegates enforcement to member states, resulting in varying penalty structures across the EU. Understanding the enforcement landscape is crucial for compliance planning.
Enforcement in the Netherlands
In the Netherlands, the Authority for Consumers & Markets (ACM) is the primary enforcement body for EAA compliance, particularly for e-commerce and consumer services. The ACM has indicated that enforcement will follow a progressive approach:
- Warning and guidance: Initial violations may result in warnings with guidance on required corrective actions
- Formal compliance orders: Persistent non-compliance results in binding orders to remediate within specified timeframes
- Financial penalties: Continued non-compliance can result in fines up to €3 million or 4% of annual turnover, whichever is higher, for the most serious violations
- Product withdrawal: Market surveillance authorities can require withdrawal of non-compliant products or services
Penalties Across the EU
While specific penalty amounts vary by member state, the trend across the EU is toward substantial fines for non-compliance:
- Germany: Fines up to €100,000 per violation
- France: Penalties up to €20,000 for initial violations, increasing for repeat offenses
- Spain: Tiered fine structure with maximum penalties reaching €1 million for serious violations
- Ireland: Significant penalties with additional provisions for continuous daily fines for ongoing violations
Beyond Financial Penalties
Non-compliance carries risks beyond direct financial penalties:
- Reputational damage: Public enforcement actions can harm brand reputation and customer trust
- Competitive disadvantage: Compliant competitors can highlight accessibility as a differentiator
- Lost business opportunities: Public sector procurement increasingly requires accessibility compliance
- Legal action: While the EAA doesn't create private rights of action, national disability discrimination laws may provide grounds for lawsuits
- Market access restrictions: Non-compliant products and services may be barred from sale in the EU market
How to Become Compliant: A Practical Roadmap
Achieving EAA compliance requires a systematic approach. Based on experience helping Dutch and EU organizations meet accessibility requirements, we recommend the following six-step process:
Step 1: Assess Your Current State
Begin with a comprehensive accessibility audit covering all digital products and services within the EAA's scope:
- Website audit: Complete WCAG 2.2 Level AA assessment of your public-facing and authenticated web properties
- Mobile application audit: If you offer mobile apps, these require separate accessibility evaluation
- Document portfolio audit: Evaluate a representative sample of your PDF and other digital document library
- E-commerce flow audit: For online retailers, assess the entire purchase journey from product discovery to checkout
- Third-party components: Identify accessibility issues in third-party widgets, chatbots, and embedded services
Professional audits following the WCAG-EM methodology provide the most reliable assessment. While automated tools can identify about 30% of accessibility issues, expert manual testing is essential for comprehensive evaluation.
Step 2: Identify and Prioritize Gaps
Create a detailed inventory of accessibility issues with priority ratings based on:
- Severity: How significantly does the issue impair access for persons with disabilities?
- Frequency: How often do users encounter this issue?
- Impact on critical functions: Does the issue prevent completion of essential tasks?
- Remediation effort: How complex and resource-intensive is the fix?
Focus initial efforts on high-severity issues affecting critical user journeys. For e-commerce sites, prioritize product search, cart, and checkout functionality. For information sites, ensure core content and navigation are accessible.
Step 3: Develop a Remediation Plan
Create a detailed remediation roadmap that includes:
- Timeline: Realistic schedule for addressing all identified issues
- Resource allocation: Assignment of development, design, and content team members
- Budget: Costs for tools, training, external expertise, and ongoing maintenance
- Milestones: Specific checkpoints for measuring progress
- Risk mitigation: Plans for addressing technical challenges or resource constraints
Step 4: Implement Fixes
Execute your remediation plan, starting with highest-priority issues:
Website and Application Remediation
- Implement proper semantic HTML structure
- Add ARIA labels where necessary for complex interactions
- Ensure keyboard navigation for all interactive elements
- Fix color contrast issues
- Add captions and transcripts for multimedia content
- Ensure forms have proper labels and error identification
PDF Document Remediation
PDF remediation is often the most time-intensive aspect of compliance. Options include:
- Automated remediation: AI-powered tools can handle simple, templated documents at scale
- Semi-automated approach: Tools assist, but expert review and manual refinement ensure quality
- Full manual remediation: Required for complex documents with tables, forms, charts, and graphics
- Done-for-you service: External specialists handle the entire process from audit through certified delivery
Step 5: Verify Compliance
After implementing fixes, conduct thorough verification:
- Automated testing: Use tools like Axe, WAVE, or PA11Y to catch regression issues
- Manual expert review: Professional accessibility evaluators should verify critical fixes
- Assistive technology testing: Test with actual screen readers, voice control, and other assistive technologies
- User testing: If possible, engage persons with disabilities to test real-world usability
Plan for free re-examination 12-15 weeks after initial remediation to ensure fixes remain effective and no new issues have been introduced through regular updates.
Step 6: Maintain Compliance
Accessibility is not a one-time project but an ongoing commitment:
- Accessibility policy: Document your organization's commitment and approach to accessibility
- Training programs: Ensure developers, designers, and content creators understand accessibility requirements
- Quality assurance integration: Build accessibility checks into your development and content publishing workflows
- Regular audits: Conduct quarterly or semi-annual accessibility reviews
- Feedback mechanism: Provide clear channels for users to report accessibility issues
- Continuous improvement: Stay current with evolving standards and best practices
Getting Expert Help
Many organizations find that external expertise accelerates compliance and ensures quality:
- Audit services: Professional assessment identifies all issues and provides clear remediation guidance
- Remediation services: Specialists can handle complex PDF portfolios and technical website fixes
- Training and consulting: Build internal capability while meeting immediate compliance needs
- Done-for-you compliance: Full-service solutions that handle everything from audit through certification
Ready to Ensure EAA Compliance?
The European Accessibility Act is now in effect, and enforcement is active. Don't wait for regulatory action—proactive compliance protects your organization from penalties while expanding your market reach to all users.
EqualXS specializes in WCAG 2.2 AA and PDF/UA compliance for Dutch government and EU enterprises. We don't just audit—we remediate, delivering compliant documents and websites ready for regulatory review.