EAA accessibility audit for an insurer's customer portal in the Netherlands

The verdict in three sentences

Since 28 June 2025, the European Accessibility Act, implemented in Dutch law, requires consumer-facing online services to be accessible, and an insurer that sells or manages policies online is in scope, with the competent Dutch regulator able to issue binding orders and administrative fines. A typical programme costs 4,000 to 9,000 EUR excluding VAT for a WCAG 2.1 AA audit of a 20 page sample, then 8,000 to 35,000 EUR of fixes depending on the state of the public site and the customer portal. The priority is not 100% in month one, but an honest accessibility statement and a credible remediation roadmap, then fixing the critical journeys first.

What the law requires of a Dutch insurer in 2026

For a health or non-life insurer based in Utrecht or Rotterdam, three areas need review: the marketing site (products, cover, contact), the quote and purchase flow, and the policyholder portal (claims, declarations, digital insurance card, messages). The purchase flow and the portal fall under the EAA as soon as they are used to conclude or perform a contract with a consumer. The technical benchmark is EN 301 549, which references WCAG 2.1 level AA.

In practice that means meeting WCAG 2.1 AA, publishing an accessibility statement explaining how the service meets the requirements and where it does not yet, offering a way to report problems, and keeping documentation available for the regulator. Many Dutch insurers already use the government's statement format and the 'toegankelijkheidsstatus' labels A to E as a familiar model.

The WCAG criteria most often failed on insurance sites

WCAG 2.1 AA contains 50 success criteria, while the French RGAA translates them into 106 testable criteria. On insurer sites a handful of them concentrate most audit failures. Frequencies below are 2026 orders of magnitude from published audits and auditor feedback.

Most of the risk sits in the calculator, the quote form and the policy PDFs: exactly where the customer makes a decision.

Budget by compliance level

Price depends on the number of templates, the portal technology (often a vendor platform) and the volume of PDFs. 2026 orders of magnitude seen in the Dutch market.

A re-audit is essential before claiming a compliance level. Kolonell handles remediation and template rebuilds on quote, starting from an existing audit report or one carried out by an independent auditor.

A five step method over six months

Month 1: choose the sample (home, product page, calculator, quote, login, portal dashboard, claim form, legal pages, contact, sitemap, plus about ten representative pages) and audit. Month 2: publish the statement with the real status and the roadmap. Months 2 to 4: fix shared components (header, menu, forms, modals), which often resolves 40 to 60% of issues at once. Months 4 to 5: fix business journeys and PDFs. Month 6: re-audit and update the statement.

Mini case study

Anouk, digital director of a health insurer with 220,000 policyholders in Utrecht, starts from an audit showing 31 failed AA criteria. She orders a 20 page audit at 6,000 EUR and a remediation package at 22,000 EUR, plus 150 policy PDFs at 60 EUR each, or 9,000 EUR. Total: 37,000 EUR excluding VAT.

On the other side: the contact centre handled 3,000 calls a month from customers stuck online. If accessibility and the cleaner UX remove 10% of them, 300 calls at 7 EUR average cost, the saving is 2,100 EUR a month, or 25,200 EUR a year. The project pays back in about 18 months on that line alone, before counting the regulatory risk on three in-scope services.

FAQ

Is a mid-sized insurer really in scope of the EAA?

Yes, as soon as it offers online quotes or purchases to consumers, unless it is a micro-enterprise with fewer than 10 staff and under 2 million EUR turnover. An insurer with 60 staff is clearly in scope.

How many pages should be audited?

A sample of 15 to 25 pages is usual, including every page of the critical journeys. 20 pages is a sound compromise for a site with a policyholder portal.

Can an automated tool do the job?

No: automated tools catch only about 20 to 30% of issues. A proper audit needs manual testing with screen readers and keyboard navigation.

Do we have to reach 100% immediately?

Full compliance is the legal target, but a transparent statement listing remaining issues with dated fixes is far more defensible than silence. Missing documentation is itself a compliance failure.

What if the portal is a vendor platform?

Require the vendor's own conformance report and a fix schedule, and put it in the contract. Vendor platforms often account for 30 to 50% of an insurer's issues.

Let's scope your project. We start from your audit or arrange one, then fix the quote, purchase and portal journeys first over a 3 to 6 month plan. Detailed quote within 48 h. WhatsApp +221 77 596 93 33.