As of 28 June 2025, the European Accessibility Act (EAA) applies. From this date onwards, the EAA must be complied with and supervisors may begin enforcing it. The substance of the EAA has already been discussed in earlier blogs and legislative articles. In this article, we focus on the EAA supervisors and their responsibilities.
Supervisory authorities
-
The EAA applies across multiple sectors. The Dutch government has therefore designated several sector-specific supervisory authorities for EAA compliance:
-
The Netherlands Authority for Consumers and Markets (ACM) for the accessibility of e-commerce services and electronic communications services, such as websites, apps and chat services.
-
The Netherlands Authority for the Financial Markets (AFM) for the accessibility of online financial services, such as online banking.
-
The Dutch Digital Infrastructure Inspectorate (RDI) for products such as e-readers, smartphones and payment terminals.
-
The Netherlands Media Authority (CvdM) for e-books and audiovisual media services, such as streaming services for films, series and games.
-
The Inspectorate for the Environment and Transport (ILT Inspectorate) for passenger transport by air, bus, rail and water.
-
The Inspectorate of Justice and Security (JenV Inspectorate) for the emergency number 112 and related services.
Supervisory tasks
The supervisory authorities are responsible for monitoring whether companies comply with the EAA accessibility requirements within their respective sectors. To ensure compliance with the EAA, supervisors have various enforcement powers. For example, they can handle consumer complaints regarding accessibility. Supervisors are also authorised to take enforcement action against companies that fail to comply with the EAA accessibility requirements.
Supervisors may assess a product if there are sufficient grounds to believe that it does not meet the EAA requirements. If the supervisor concludes that the product does not comply, it may require the market participant to take corrective measures to bring the product into line with the EAA.
Supervisors may also impose appropriate corrective measures. These may include a warning or a fine. When imposing a fine, account is taken of the size of the company concerned. After imposing corrective measures, the supervisor may carry out follow-up inspections to verify whether the required measures have been implemented. In addition, remedial measures may be imposed, such as a mandatory product recall, a sales ban or the imposition of a penalty payment. If these measures are not complied with, the supervisor may even decide to withdraw the product from the market.
All supervisory authorities, with the exception of the ILT Inspectorate and the JenV Inspectorate, have published their supervisory tasks on their websites.
Notification obligation for non-accessible products and services
A recent inventory among companies and institutions in both the public and private sectors shows that significant steps are still required. The results indicate that seven out of ten digital products and services do not yet meet the standards of the European Accessibility Act (EAA). Companies whose products or services do not comply with the EAA accessibility requirements are subject to a notification obligation. This notification must be made via the website of the supervisory authority responsible for the sector in which the company operates. The notification obligation also applies where companies rely on one of the EAA exemptions.
The deadline has passed, time for action
The EAA has applied since 28 June 2025. From that moment, supervisory authorities may exercise various enforcement powers. It is important for companies to be aware of the accessibility requirements and to draw up a plan to achieve EAA compliance as soon as possible. It is also advisable to assign internal responsibility for accessibility. If a company cannot comply with the requirements in time, a notification must be made to the relevant supervisory authority. Making an organisation accessible requires a tailored approach and may take time. Need help? We are ready to support you.
