Dutch accessibility fines: the ceiling depends on who regulates you
The Netherlands does not have one accessibility penalty. It has two, and they are eight times apart. Which one applies to you depends entirely on which supervisor you fall under, and we have not found a single other source that says so.
This page walks the statutory chain from the European Accessibility Act to the number, quoting each link. Last verified against the legislation on 25 July 2026.
Webshops and e-commerce services. Or 1% of turnover if that is higher. Supervisor: the ACM, the Netherlands Authority for Consumers and Markets.
Media and passenger transport. The fifth fine category, as at 1 January 2026. Supervisors: the Commissariaat voor de Media, and the Inspectie Leefomgeving en Transport.
If you run a webshop: EUR 900,000 or 1% of turnover
"De bestuurlijke boete, bedoeld in artikel 2.9, bedraagt ten hoogste EUR 900.000 of, indien dat meer is, 1% van de omzet van de overtreder."
Artikel 2.15, eerste lid, Wet handhaving consumentenbescherming. English: the administrative fine referred to in article 2.9 amounts to at most EUR 900,000 or, if that is more, 1% of the offender's turnover.
How the accessibility duty reaches that provision
- Directive (EU) 2019/882, the European Accessibility Act.
- Implemented by the Implementatiewet toegankelijkheidsvoorschriften producten en diensten, Staatsblad 2024 no. 87, applying from 28 June 2025.
- That act inserts article 6:230fb of the Civil Code: a provider of e-commerce services to consumers must design and provide those services in accordance with the accessibility requirements. Article 6:230fc carries the exemptions.
- It then inserts article 8.15 into the Wet handhaving consumentenbescherming (Whc): a provider of an e-commerce service must observe article 6:230fb.
- Article VII, part D of the same act adds a row to part a of the annex to the Whc, reading "Artikelen 8.15 en 8a.1 van deze wet". Part a of that annex is the ACM's competence list. This is the step that makes accessibility an ACM-enforceable matter.
- ACM competence engages article 2.9 Whc, the administrative-fine power, whose ceiling is set by article 2.15.
Everyone else: EUR 110,000
The same implementing act gives the other Dutch supervisors a very different ceiling: the fifth fine category of article 23 of the Criminal Code.
| Sector | Supervisor | Maximum |
|---|---|---|
| E-commerce services | ACM | EUR 900,000 or 1% of turnover |
| Media services | Commissariaat voor de Media (Whc art. 8a.2) | EUR 110,000 |
| Passenger transport | Inspectie Leefomgeving en Transport (Whc art. 8a.3) | EUR 110,000 |
| Products | The Minister, under Warenwet art. 35e | EUR 110,000 |
| Financial services | AFM and DNB, under Wft art. 4:22.0a | EUR 110,000 |
The fifth category is indexed every two years. It rose from EUR 103,000 to EUR 110,000 on 1 January 2026 (Staatscourant 2025 no. 39854). If you read EUR 103,000 anywhere, the page has not been updated since 2025.
Why the EUR 900,000 figure keeps getting called stale, wrongly
EUR 900,000 used to be the sixth criminal fine category. That category was indexed to EUR 1,030,000 in 2024 and EUR 1,100,000 in 2026, so anyone who assumes the accessibility ceiling is the sixth category concludes, reasonably but incorrectly, that EUR 900,000 must be out of date.
It is not. The EUR 900,000 in article 2.15 of the Whc is a hard-coded statutory amount, not a reference to a fine category. It does not move with the indexation. The coincidence with the old sixth category is exactly that, a coincidence. The figure is current.
We flagged our own published version of this figure as unverified during a research pass and went to the primary legislation to settle it. This section is what that check produced.
Who is in scope
- Threshold
- 10 or more employees, or annual turnover above EUR 2 million, or both. Firms under both thresholds are exempt as micro-enterprises. This is the ACM's own statement of the test.
- Where you are registered is irrelevant
- What matters is that you serve consumers in the Netherlands.
- In force since
- 28 June 2025.
- The EUR 2 million is a scope test
- It is not a fine and not a percentage. Any page quoting it as a penalty has misread the act.
What the ACM is actually doing, with dates
The Netherlands is the only country in Europe where the regulator has published a test, named a deadline and said out loud what happens next. The sequence, in order:
- 24 March 2026. The ACM published the results of its own accessibility test of around 100 of the largest Dutch webshops: 61% were not digitally accessible, and a further 33% had serious problems. Only 2 of the 300 largest Dutch webshops fully complied.
- 22 June 2026. The ACM visited the ten worst performers in person, and said it would re-test them after three months, with fines to follow for those still not compliant.
- Around late September 2026. That re-test falls due. This is the only dated enforcement trigger anywhere in the EU accessibility regime today.
The ACM's stated approach remains proportionate: what it does next depends on the scale of the problem and on what the company is doing about it. Read that as the window it is. Demonstrable work in progress is worth a great deal more than a perfect score you cannot evidence, and "we tested in August and here is the plan" is a materially better position to be in on the day an inspector looks than "we intend to review this".
Find out where you actually stand
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- Implementatiewet toegankelijkheidsvoorschriften producten en diensten, Stb. 2024, 87: officielebekendmakingen.nl
- Wet handhaving consumentenbescherming, consolidated text: wetten.overheid.nl
- Fine-category indexation in force 1 January 2026, Staatscourant 2025 no. 39854: officielebekendmakingen.nl (PDF)
- ACM, accessibility of e-commerce and electronic communications services: acm.nl
- ACM webshop accessibility test, published 24 March 2026: acm.nl
- ACM visits to the ten worst performers and the three-month re-test, 22 June 2026: NOS
- Directive (EU) 2019/882: EUR-Lex
We are an accessibility testing company, not a law firm, and this page is not legal advice. It is a plain-language reading of published legislation with the text quoted so you can check us. If you think we have something wrong, email hello@able.cat and we will correct it and say so.