ACM's Phased Crackdown on Inaccessible E-Commerce Under the European Accessibility Act

The European Accessibility Act (EAA) became enforceable across the EU on 28 June 2025, requiring e-commerce websites and apps run by businesses with 10 or more employees or over EUR 2 million in annual turnover to meet digital accessibility rules so that customers with disabilities can browse, purchase and communicate independently. In the Netherlands, enforcement responsibility is split by sector among five regulators — the Authority for Consumers and Markets (ACM) for e-commerce, the AFM for financial services, the RDI for products, the CvdM for media and the ILT for transport — with ACM covering the largest and most visible slice: online shops and communications services.
Rather than opening with fines, ACM adopted a phased, information-first approach. It first allowed businesses to voluntarily self-report non-compliance through 15 October 2025, after which reporting became mandatory. ACM has since sent information requests to e-commerce operators worldwide, including companies headquartered outside the EU, that sell to Dutch consumers. Companies that did not respond, or whose responses were incomplete, are being prioritised for audits starting in spring 2026, with active enforcement expected to escalate through the second half of the year.
Speaking at AbilityNet's TechShare Pro conference, ACM project leader and senior supervisory officer Hanneke van Rooijen was candid about the scale of the shortfall: 'There is a very big gap between the status of the industry and the compliance with EAA.' She said fines are 'absolutely not the goal', framing ACM's approach as mission-driven — testing companies that failed to respond, analysing the results, then opening deeper investigations and, if needed, formal enforcement action against businesses that continue to underperform.
The Dutch rollout offers a transferable regulatory pattern: rather than a single compliance deadline followed by immediate sanctions, ACM sequenced disclosure, engagement and evidence-gathering before enforcement, an approach other EU market surveillance authorities are watching as they build out their own EAA audit capacity.

Read the full analysis: https://www.acm.nl/en/accessibility/accessibility-e-commerce-services-and-electronic-communications-services