Accessibility laws · Netherlands

Netherlands: Digital Accessibility Decree and the EAA

The Netherlands makes every public body declare in public how accessible its website actually is. Each declaration carries a status label running from A down to E, it goes into a central register anyone can search, and it expires. Let the examination behind it run past its three-year validity and the status drops to D on its own. No fine exists anywhere in this system. Visibility is the enforcement mechanism, and the government publishes how far that has got it.

WCAG version named: 2.1 AA
Statement register: Public
EAA application date: Jun 2025
Technical standard: EN 301549

What the law is

The Digital Accessibility Decree took effect on 1 July 2018, transposing the EU Web Accessibility Directive into Dutch law. Its Article 6 sets three dates, and the test is a publication date rather than a judgement about how new something feels. A website published on or after 23 September 2018 had to comply by 23 September 2019. A website published before that date had until 23 September 2020. Mobile apps had until 23 June 2021. From 1 July 2023 the Wet digitale overheid became the legal basis, the word temporary came out of the title, and the instrument is now the Besluit digitale toegankelijkheid overheid. The obligation itself did not change. One oddity is worth knowing, because it will make you think we have this wrong. The Dutch statute database still shows the old temporary title, so two Dutch government systems disagree about the name of their own decree.

The standard is EN 301 549, and Article 3 applies it dynamically, so when the harmonised European standard moves the Dutch duty moves with it. Read the decree cold and it will mislead you, because Article 1 still defines EN 301 549 as a set of technical requirements including the WCAG 2.0 guidelines. That definition is a fossil from 2018. The harmonised standard has since moved to EN 301 549 V3.2.1 and WCAG 2.1, and the Dutch government's own current guidance says WCAG 2.1 Level AA and counts 50 tested success criteria. The decree also defines accessible in about the plainest words a statute has ever managed. Perceivable, operable, understandable, and robust.

The European Accessibility Act supplies the private-sector half, applying since 28 June 2025 to e-commerce, consumer banking, passenger transport, e-books, and the rest of the covered list. Service providers with fewer than 10 employees and either turnover or a balance sheet total no higher than €2 million are exempt from the service accessibility requirements outright. Two later dates sit behind the headline one. Services delivered using products lawfully in use before 28 June 2025, and contracts agreed before that date, can run to 28 June 2030. And the directive lets a member state allow a self-service terminal lawfully in use before 28 June 2025 to serve out its economic life, up to 20 years from when it entered use. That one is a national choice rather than an automatic grace period, so check what the Netherlands actually took up before planning around it.

This applies to you if…

You are a Dutch public sector body. The decree defines that as a state, regional, or local authority, a body governed by public law, or an association formed by them to meet a need in the general interest that is not industrial or commercial. Municipalities, provinces, and water authorities are all inside it. Public media institutions are not, because Article 2 carves them out by name along with the NPO and the RPO.
You sell EAA-covered products or services to consumers in the Netherlands, wherever your company is headquartered, and you employ 10 or more people or clear the €2 million line on turnover or balance sheet.
You supply digital services into Dutch public procurement, where the buying body's own accessibility duty tends to arrive in your contract before it arrives anywhere else.

What it technically requires

Meet EN 301 549 across your content, which today means WCAG 2.1 Level AA. Read the decree's own definition of content before you scope the work, because it is broader than a page of text. It covers everything the body wants to convey through the site or app, including downloadable documents and forms, and it covers interaction, naming the processing of digital forms and the handling of identification procedures. Your login flow is content.
Watch the European citation rather than the Dutch decree, because the decree hands the version question over. The reference in force is EN 301 549 V3.2.1, published in March 2021 and applying to the presumption of conformity since 12 February 2022. A revision carrying the web clauses up to WCAG 2.2 is drafted and working through ETSI's process, with no published version number and no date behind it, so anybody who quotes you one is guessing. Nothing in Dutch law has to change for that revision to reach you. When it lands, the examination sitting underneath your statement gets measured against the new edition, while your three-year validity clock keeps running from the old one. Which is the argument for testing against WCAG 2.2 Level AA before anyone makes you.
Publish an accessibility statement using the model the Minister sets, and register it centrally rather than only on your own site. The government runs a nine-step guided tool at toegankelijkheidsverklaring.nl that produces a statement meeting the mandatory model, and filing there is what puts you in the public register. The point of the register is that a citizen, a journalist, or a competitor can check any Dutch government site's status without hunting for a buried page.
Carry the right status label, and there are five of them rather than the three most guides describe. Status A means an examination was carried out, all 50 tested success criteria are met, and the statement is published. Status B means an examination was carried out, fewer than 50 criteria are met, and the statement sets out the improvements under way. Status C means you have published a statement and booked an examination within six months. Status D means you do not comply. Status E means you never published a statement at all. C and E are the interesting two, because C rewards having a plan and E exposes having done nothing.
Keep the clocks running, because this status decays without anyone touching it. A statement at status A or B is updated at least once a year, and a status B has to demonstrably improve each year rather than sitting still. The accessibility examination underneath a status A or B stays valid for three years. When that validity lapses the statement falls to status D on its own. So the work here is recurring by design, and doing nothing is a decision that shows up in public.
Claim the disproportionate burden if it genuinely applies, and understand what claiming it costs you. The decree lets a body decline to apply EN 301 549 so far as doing so would be a disproportionate burden. Three things get weighed there. The body's nature, size, and financial resources come first. Then the costs and benefits to that body, set against the benefits for people with disabilities. Then how often and for how long that particular site or app is used. That last factor is unusual, and it cuts both ways on a heavily used service. A body that claims the burden then has to name in its statement which requirements it is not meeting and offer accessible alternatives. The decree also excludes some content outright. That covers live video, third-party content you neither funded nor developed nor control, and online maps where the essential navigation information is given accessibly elsewhere. It covers heritage reproductions too, where accessibility would harm preservation or authenticity, along with older office documents and prerecorded media published before the dates the decree sets.

All roads lead to WCAG. Start with Level AA, the legal standard or the full 55-rule library. Unfamiliar term along the way? The A to Z glossary decodes it.

This law expects a published accessibility statement, and regulators check for it first. Generate yours free →

How it is enforced

Supervision here runs on democratic control rather than a regulator with a penalty book, and it starts closer to home than most people expect. Horizontal control comes first, meaning the elected body supervises its own executive, so a municipal council checks the accessibility of its own municipality's websites and apps. Vertical control then asks whether that horizontal control is actually working, with provinces supervising municipalities and water authorities, and the results shared with the Ministry of the Interior and Kingdom Relations. The final step is a higher authority stepping in and performing the task itself. No fine or punishment has been established at any point in that chain.

The vertical layer is thinner in practice than on paper. Dutch reporting describes provinces struggling to work out how to supervise this at all, with Limburg among the few that assigned somebody and started spot-checking accessibility statements from 1 February 2021. So the pressure that actually moves a Dutch public body is the published status label, not an inspector.

The government publishes its own scoreboard, and the way to read it is two numbers at once. On 31 August 2026 the dashboard covered 9,111 government websites and mobile applications, and it reported that 64% of them met the legal obligation while 10% met the accessibility requirements. Those are not the same test, and the distance between them is the whole story. The law accepts status A, B or C, so a body with a published statement, an improvement plan, and an examination booked inside six months is compliant while its site is still unusable. Only status A means the site itself passed, and that is 870 of the 9,111, five years after the last of the decree's deadlines went by. Read those figures with the dashboard's own caveat attached. It draws on the register of statements, it says plainly that it is still being filled in, and 920 entries sit at status E, meaning no statement was ever published at all.

The EAA layer works on a different logic, because the directive requires member states to set penalties that are effective, proportionate, and dissuasive. The Netherlands put it into the Civil Code rather than into a standalone accessibility act, which is why it is easy to miss. Book 6 articles 230fb to 230fd carry the service duties, the microenterprise exemption and the presumption of conformity, and the same statute hands sanctioning powers to the sector authorities. What we are not going to hand you is a euro figure, because the amount depends on which sector authority you answer to and on category indexation nobody should recite from memory. For a private business selling into the Netherlands, the reliable statement is that the obligation is real, the law is findable, and the number is a question for whoever regulates your sector.

Key dates

Sep 23, 2019New public sector websites in scope
Sep 23, 2020All public sector websites in scope
Jun 23, 2021Public sector mobile apps in scope
Jun 28, 2025European Accessibility Act applies to covered private services

What to do about it

Every obligation on this page is measured against WCAG, so the first step is knowing where you actually stand. Run the free 10-page scan for the machine-checkable slice. For the rest, we review the key journeys with an expert and a real blind screen-reader user, then attach a screenshot and a fix to every finding. $499, 5 business days.

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This law does not set the web requirement itself. It points at EN 301 549, the European accessibility standard, and that is where the requirement actually lives. Clause 9 of the standard carries WCAG 2.1 Level AA, so a site that already meets Level AA has met the web part of it. The rest of the standard covers ground WCAG never touches, including hardware, two-way voice, documents that are not web pages, and the support channels a customer reaches once the site has already failed them. Several countries adopt the standard under their own national designation, which carries the same requirements under a different name.

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Orientation only, current as of August 2026. Not legal advice, and no attorney-client relationship is created. For your specific situation, talk to your own lawyer.