The Netherlands’ Dutch Implementation Act and the EAA

In the Netherlands, the Dutch Implementation Act was approved by the Dutch Parliament in April 2024. This act aligns Dutch legislation with the European Accessibility Act (EAA) as well as a broader range of EU directives, including the General Data Protection Regulation (GDPR) and the Digital Services Act (DSA).

The EAA specifically aims to ensure consistency across EU member states regarding accessibility requirements for certain products and services.

Implementation in the Netherlands

The accessibility requirements for products and services will be incorporated into existing Dutch laws and regulations. For products, the relevant rules are laid out in the Commodities Act and the underlying Commodities Accessibility Decree 2023.

For services, the requirements are distributed across sector-specific legislation as follows:

• Electronic Communication Services: Telecommunications Act
• E-Commerce Services: Dutch Civil Code
• Consumer Banking Services: Financial Supervision Act
• Enforcement Rules: Consumer Protection Enforcement Act
• Other services (e.g., passenger transport, e-readers, audiovisual media services): Equal Treatment of Disabled and Chronically Ill People Act

This approach reflects the broad scope of the EAA, which applies to a wide range of services. Each piece of legislation will reference the EAA and its annexes to ensure alignment with EU objectives.

It’s important to note that the use of different pieces of legislation to implement the EAA means that enforcement responsibilities are divided among the competent authorities associated with each law.

This sectoral enforcement model differs from the complaint-based mechanisms used in some other EU member states. It provides a proactive framework for oversight, allowing authorities to ensure compliance without relying on individual complaints.

Dutch Accessibility Requirements

Private businesses operating in the Netherlands must carefully assess their obligations under the Dutch implementation of the European Accessibility Act (EAA). The requirements apply to a wide range of products and services, with specific rules depending on the type of business activity. These obligations aim to ensure that goods and services are accessible to persons with disabilities, promoting inclusion and equal access.

Neither the EAA nor the Dutch Implementation Act explicitly defines “accessibility.” However, Annex I of the EAA provides a detailed list of requirements for accessibility. While Annex II of the EAA provides examples of nonbinding measures that businesses can use to improve accessibility. These guidelines help businesses interpret and apply accessibility principles effectively.

Multi-Sensory Availability

Products and services must be accessible through multiple sensory channels. This means businesses need to design solutions that cater to various needs, such as offering visual, auditory, and tactile options. For example, a device with audio instructions should also provide visual or tactile feedback for users who cannot hear.

Clear and Understandable Presentation

Information about products and services must be easy to understand and use. Accessibility measures include:

• Using legible fonts and sufficient text size to accommodate those with visual impairments.
• Ensuring strong contrast between text and background for readability.
• Structuring content in a way that is intuitive for all users, including those relying on assistive technologies like screen readers.

CE Marking

Manufacturers are required to ensure that their goods conform to EAA standards by obtaining CE marking (an acronym for the French “Conformite Europeenne”). This marking demonstrates compliance with EU regulations and assures customers of the product’s accessibility. Documentation outlining how the product adheres to accessibility standards is also required to support the CE marking.

The Importance of Early Compliance

Businesses must act promptly to implement accessibility measures. Noncompliance could result in penalties, such as fines, product recalls, or service restrictions, imposed by supervisory authorities. On the other hand, compliance with accessibility standards is an opportunity for businesses to demonstrate leadership, enhance their reputation, and expand their market reach to include consumers with disabilities.

Compliance Monitoring in the Netherlands

The Dutch government has adopted a structured and transparent approach to ensure public services and platforms meet accessibility standards, setting an example for private entities:

• Independent Expert Reviews. Government.nl undergoes accessibility evaluations by independent experts several times a year. These assessments identify design or functionality barriers, which are addressed through strategic, long-term solutions to improve usability.
• Audits by the Central Audit Service (ADR). The ADR audits internal processes to verify that accessibility procedures align with web guidelines. This ensures that the accessibility of digital platforms is not just a one-time effort but an ongoing practice integrated into operational workflows.
• Web Guidelines Monitor. Since 2014, the Web Guidelines Monitor has conducted quarterly evaluations of government websites. This program systematically tests compliance with accessibility standards, helping identify areas for improvement and fostering accountability within public-sector organizations.
• Editorial Oversight. The editorial team at Government.nl performs accessibility checks on all published content to ensure adherence. In addition to routine monitoring, interim reviews are conducted for specific projects, ensuring the accessibility of new initiatives or significant updates.

Implications for Private Businesses

Private businesses should view compliance as an opportunity to strengthen their market position rather than merely a regulatory requirement. Accessible products and services not only fulfill legal obligations but also open doors to a broader customer base. When you commit to digital accessibility, you’re showcasing your dedication to social responsibility, building trust and fostering inclusion, and safeguarding against reputational or financial risks.

Learn More About EAA Compliance and Beyond

The clock is ticking toward the June 28, 2025, deadline and organizations will benefit from working proactively to ensure that their websites and other digital assets are accessible to all.

If you need help achieving EAA compliance, TPGi is here to help. Our EAA Resource Center is a great place to start, featuring webinars, accessibility testing solutions, and other tools designed to help organizations improve their approach to digital accessibility.

If you are looking for an in-depth educational resource, we invite you to download our Essential Guide to the European Accessibility Act, which provides a detailed trail map to help guide your team forward on their accessibility journey.

Explore Additional EU Member Resources:

• French Law 2005-102, RGAA and Web Accessibility
• Ireland Digital Accessibility Laws: EAA and Beyond
• Understanding the Stanca Act, Italy’s Digital Accessibility Law