The verdict in three sentences
Since 28 June 2025, the European Accessibility Act requires consumer-facing digital services, including e-commerce and customer portals where people sign contracts or pay, to be accessible, and in the Netherlands the market regulator can order fixes and impose fines. A mid-sized services group typically starts at 40 to 60 % conformance with EN 301 549 and WCAG 2.1 AA, and the gap closes in three moves: audit, prioritised remediation, accessibility statement. The costliest item is rarely the marketing site: it is the customer portal, its forms and its documents.
Are you in scope, and for what?
The digital lead of a mid-sized company first needs to know which rules apply. The EAA was transposed into Dutch law and sits alongside procurement and sector requirements, and many firms find they are caught by more than one.
| Situation | Applicable rule | Scope | Key obligation | Risk |
|---|---|---|---|---|
| Selling or signing contracts online with consumers | EAA, Dutch transposition | website, portal, apps | meet accessibility requirements, publish accessibility information | regulator orders and fines |
| Banking, transport, telecoms | EAA sector provisions | end-to-end journeys | accessible journeys including authentication | supervision by the competent authority |
| Supplier to Dutch government bodies | public procurement criteria | delivered services | WCAG 2.1 AA conformance | lost tenders |
| Microenterprise providing services (under 10 staff and 2 M EUR) | exempt for services | none | no obligation | low |
| Pure B2B site with no consumer contracts | outside the EAA in principle | to be checked | good practice, often required by large buyers | lost deals |
A 600-employee services group in Amsterdam that lets individuals sign up or pay online is almost always in scope. Even a pure B2B site benefits from conformance: large corporates and public buyers increasingly write it into their tenders.
WCAG 2.1 AA, referenced by EN 301 549, contains 50 success criteria grouped under four principles: perceivable, operable, understandable, robust. The French RGAA translates the same requirements into 106 testable criteria, which shows how granular a serious audit is.
Remediation cost and method in 2026
An efficient programme follows four steps. First measure starting conformance on a representative sample of 15 to 25 pages. Then fix shared components (header, menu, forms, modals), which clears dozens of issues at once. Next handle content and PDF documents. Finally publish the accessibility statement and roadmap.
| Item | 2026 order of magnitude (Netherlands market) | Duration | Comment |
|---|---|---|---|
| Initial WCAG 2.1 AA audit (15 to 25 pages) | 3,000 to 8,000 EUR | 2 to 4 weeks | gives the baseline, often 40 to 60 % |
| Marketing site remediation | 5,000 to 20,000 EUR | 4 to 8 weeks | shared components first |
| Customer portal remediation | 15,000 to 60,000 EUR | 8 to 16 weeks | forms, authentication, dashboards |
| Accessible PDFs | 30 to 150 EUR per document | variable | contracts, invoices, terms |
| Follow-up audit and statement | 2,000 to 4,000 EUR | 1 to 2 weeks | publication required |
| Contributor training | 1,000 to 2,500 EUR | 1 to 2 days | prevents regression |
When the portal is old, fragile or built on an abandoned framework, remediation costs more than an accessible rebuild. That is where Kolonell comes in: a rebuilt customer portal as a custom application, with components tested by keyboard and screen reader. Our grid: simple application 2,500,000 to 4,000,000 FCFA (3,810 to 6,100 EUR), medium 4,000,000 to 7,000,000 FCFA (6,100 to 10,670 EUR), complex 7,000,000 to 15,000,000+ FCFA (10,670 to 22,870+ EUR). External audits, PDF remediation and hosting are quoted separately. Maintenance that keeps new pages compliant costs 35,000, 75,000 or 120,000 FCFA a month (53, 114 or 183 EUR).
The issues that cost the most
On mid-market customer portals, the same defects recur: form fields without programmatic labels, errors signalled by colour only, visual captchas with no alternative, modals that trap keyboard focus, invoice tables without headers, short session timeouts with no way to extend. Each one blocks a full journey, which is serious under the EAA because the service is judged end to end.
Prioritise by critical journey (sign up, pay, view an invoice, cancel) rather than by isolated criterion. One journey fixed end to end is worth more than twenty scattered fixes.
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Sanne, digital lead of a 600-employee services group in Amsterdam, gets a 48 % conformance score after a 6,000 EUR audit. The marketing site can be fixed for 12,000 EUR. The eight-year-old customer portal would need 45,000 EUR of remediation with an uncertain result.
She compares this with a Kolonell rebuild of the portal as a medium-complexity application, in the 6,100 to 10,670 EUR range, plus a 3,000 EUR follow-up audit. High estimate: 10,670 + 3,000 = 13,670 EUR, versus 45,000 EUR of remediation. Savings reach about 31,000 EUR, and the company closes a live regulatory exposure. The simpler sign-up journey also cuts support calls: 120 fewer calls a month at 6 EUR each, or 8,640 EUR a year.
FAQ
Does the EAA apply to a B2B company?
In principle not if it sells no services to consumers, and service microenterprises are exempt. But roughly 1 in 2 tenders from large corporates and public buyers now asks for an accessibility commitment, which makes it a sales issue.
How long does full compliance take?
Allow 3 to 6 months for a mid-sized company: 2 to 4 weeks of audit, 2 to 4 months of fixes, then 1 to 2 weeks of follow-up audit. A portal rebuild is planned over 10 to 16 weeks.
Do we need 100 % conformance?
The realistic target is full conformance on critical journeys and at least 75 % overall, with a published roadmap. The statement must honestly report the measured level.
Is an automated tool enough for the audit?
No. Automated tools catch about 30 to 40 % of issues. Manual keyboard and screen reader testing remains essential, especially on forms.
What happens after compliance?
Every new page can lower the score. A quarterly check on 5 to 10 pages plus contributor training keeps the risk low.
Let's scope your project. Audit, journey-based remediation or an accessible portal rebuild: we define the scope with you and a 3 to 6 month schedule. Detailed quote within 48 h. WhatsApp +221 77 596 93 33.
Mohamed Bah
Fondateur, Kolonell
Passionate about digital and entrepreneurship in Africa, Mohamed has been helping Sénégalese businesses with their digital transformation since 2020. Founder of Kolonell, he believes every SME deserves a professional and accessible online présence.
