The verdict in three sentences
If your company has more than 10 employees and 2 M EUR in turnover and sells or signs up customers online, the European Accessibility Act has applied to you since 28 June 2025. A realistic budget in Amsterdam in 2026 runs from 8,000 EUR excl. VAT (small site, few issues) to over 40,000 EUR (e-commerce or complex customer portal), audit included. The most profitable lever is to fix templates (header, forms, product pages) rather than page by page, and to build accessibility into any redesign.
Who is actually in scope in 2026
Directive 2019/882 was transposed in the Netherlands through the accessibility requirements implementation act, with market supervision led mainly by the consumer authority ACM for consumer-facing services. Scope covers specific services: e-commerce, consumer banking, passenger transport, electronic communications, e-books. A purely corporate site with no sales or sign-up is not automatically in scope, but it becomes exposed as soon as it adds an order form, a payment flow or a customer area. The technical benchmark is EN 301 549, which references WCAG 2.1 level AA.
| Company situation | Subject to the EAA? | Main obligations |
|---|---|---|
| Fewer than 10 staff and under 2 M EUR turnover | No (micro-enterprises exempt for services) | Recommended good practice |
| B2B SME, brochure site with no transactions | In principle no | Risk once an order flow is added |
| SME or mid-cap with B2C e-commerce | Yes | WCAG 2.1 AA conformance, statement, service information |
| Bank, insurer, neobank | Yes | Website and mobile app conformance |
| Carrier, online ticketing | Yes | Accessible booking and passenger information |
| Public body (already under Dutch government rules) | Yes, public regime | Accessibility statement, status reporting |
The figure to bring to the board: roughly 1 person in 5 lives with a disability or lasting limitation (sight, mobility, cognition, hearing), and an ageing population adds to that share. An inaccessible site is not only a legal risk: it loses orders.
What compliance costs in Amsterdam
The prices below are 2026 Amsterdam market estimates, observed across specialist agencies and independent audit firms. They depend on the number of templates, technical debt and whether a mobile app is involved.
| Item | Small site (10 to 20 page types) | Mid-size e-commerce | Platform with customer portal |
|---|---|---|---|
| WCAG 2.1 AA sample audit | 3,000 to 5,000 EUR | 5,000 to 9,000 EUR | 9,000 to 15,000 EUR |
| Technical and editorial fixes | 5,000 to 9,000 EUR | 10,000 to 20,000 EUR | 20,000 to 30,000 EUR |
| Re-audit after fixes | 1,000 to 1,800 EUR | 1,800 to 3,000 EUR | 3,000 to 5,000 EUR |
| Accessibility statement | Included or 350 EUR | 350 to 700 EUR | 700 to 1,200 EUR |
| Editor training (1 day) | 1,000 to 1,500 EUR | 1,300 to 2,000 EUR | 1,800 to 2,800 EUR |
| Indicative total timeline | 4 to 6 weeks | 8 to 12 weeks | 3 to 5 months |
On the risk side, the regulator can issue binding instructions, orders subject to periodic penalty payments and administrative fines, plus public naming. Disability organisations are also watching. Compliance should be compared with a recurring penalty, not treated as an optional expense.
Fix or rebuild: the CFO's decision
When the audit shows less than 50 % conformance, the fix list usually looks like a disguised redesign. In that case, a redesign that is accessible by design costs less over three years. As a reference point, Kolonell builds brochure and corporate sites on the following grid: Growth 1,830 to 3,050 EUR (1,200,000 to 2,000,000 FCFA) and Premium 3,050 to 5,340 EUR (2,000,000 to 3,500,000 FCFA), with WCAG 2.1 AA components, checked contrast and tested keyboard navigation. An independent external audit is still recommended for the formal statement.
| Criterion | Fix the existing site | Rebuild accessible by design |
|---|---|---|
| Initial conformance rate | Above 70 % | Below 50 % |
| CMS and theme | Maintained and documented | Outdated or overloaded with plugins |
| 3-year cost (estimate) | 9,000 to 28,000 EUR | 7,000 to 22,000 EUR depending on scope |
| Regression risk | High with every update | Low if components are tested |
| Side benefits | None | Performance, SEO, mobile conversion |
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Illustrative example: Sanne, CFO of an office supplies distributor in Amsterdam, 45 employees, 9 M EUR turnover, 1.8 M EUR of it through an online shop. The audit (6,500 EUR) shows 38 % conformance: unlabelled form fields, poor contrast, checkout impossible by keyboard. Fix quote: 18,000 EUR, plus 2,500 EUR re-audit, so 27,000 EUR. Option to rebuild the front end and templates accessibly: 17,000 EUR, re-audit included in the budget. If checkout blockers cost even 2 % of orders, that is 36,000 EUR of revenue a year: the investment pays back in under a year, and regulatory exposure disappears.
FAQ
Does my B2B brochure site with no payments need to comply?
In principle not under the EAA, which targets transactional services. But once an order form or customer portal appears, the obligation applies, and building accessibility into a redesign costs 30 to 50 % less than retrofitting.
How long does a WCAG audit take?
Allow 5 to 10 working days for a sample of 10 to 20 page types against the 50 WCAG 2.1 AA success criteria. The report gives a conformance rate, the list of failures and a prioritised plan.
Is an accessibility overlay plugin enough?
No. Overlays billed at 50 to 300 EUR a month do not fix the source code and do not make a site WCAG 2.1 AA conformant. Regulators and disability groups consider them insufficient.
What must the accessibility statement contain?
The conformance status, non-accessible content, audit date, a contact channel and complaint routes. Update it at least every 3 years or after any major change.
Who enforces this in the Netherlands?
Market supervision sits mainly with the ACM for consumer services, with sector regulators for specific areas. Measures range from binding instructions to penalty payments and fines that can repeat while the breach continues.
Let's scope your project. Send us your site URL and scope (pages, checkout, customer area) and we will price the accessible redesign or remediation plan with an indicative budget and a 4 to 12 week timeline. 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.
