The verdict in three sentences
Since 28 June 2025, the European Accessibility Act (EAA), transposed into Dutch law, requires a wide range of consumer-facing online services to meet EN 301 549, which references the 50 success criteria of WCAG 2.1 level AA. For a 250-employee company in Amsterdam, compliance in 2026 means an audit of 3,000 to 7,000 EUR and 6,000 to 28,000 EUR of fixes, over 4 to 10 weeks. Doing nothing carries real exposure: supervisory authorities can order corrections and impose fines, and public and enterprise buyers increasingly reject suppliers without an accessibility statement.
Are you in scope? A five-minute triage
The first question for a CIO is a legal one: which rule applies to which service? The table below covers the most frequent situations in the Netherlands in 2026.
| Company situation | Applicable rule | Main obligation | Deadline |
|---|---|---|---|
| E-commerce, online banking, ticketing, passenger transport | EAA, Dutch implementation act | Service conforming to EN 301 549 | Since 28 June 2025 |
| Services already offered before June 2025 | EAA transitional period | Progressive compliance | Depending on service, up to 2030 |
| Public sector bodies | Temporary Digital Government Decree | WCAG 2.1 AA, accessibility statement | Already in force |
| Pure B2B SME, brochure site without transactions | No direct obligation | Recommended for tenders | None |
| Microenterprise (fewer than 10 staff, under 2 M EUR turnover) | Exempt for EAA services | None | None |
| Supplier to municipalities or ministries | Public procurement clauses | WCAG 2.1 AA required in tender | Per contract |
A 250-employee Amsterdam company running a B2B portal that consumers can also use often sits in two boxes: the transactional part falls under the EAA, and the corporate site must be accessible to win tenders from the City of Amsterdam, Rijkswaterstaat or large corporates that now ask for an accessibility statement.
The real cost of compliance in 2026
The figures below are 2026 orders of magnitude seen in Amsterdam, Rotterdam and Utrecht for a site of 40 to 150 pages with one or two transactional journeys. Dutch rates sit roughly 10 to 15 % above French ones.
| Step | 2026 range | Duration | Deliverable |
|---|---|---|---|
| WCAG 2.1 AA audit on 15 to 25 sample pages | 3,000 to 7,000 EUR | 1 to 2 weeks | Report on 50 criteria, conformance level |
| Technical fixes (HTML, ARIA, contrast, forms) | 6,000 to 28,000 EUR | 3 to 8 weeks | Fixed code, accessible components |
| Editorial fixes (alt text, PDFs, video) | 1,800 to 7,000 EUR | 2 to 4 weeks | Tagged PDFs, captions |
| Verification re-audit | 1,500 to 3,500 EUR | 1 week | Final level, accessibility statement |
| Content team training | 1,000 to 3,000 EUR | 1 to 2 days | Contribution guide |
| Annual monitoring | 2,000 to 5,000 EUR per year | Ongoing | Roadmap, control audit |
The line that moves the bill is complex components: mega menus, carousels, configurators, filterable tables and multi-step forms. A site built on a 60 EUR off-the-shelf theme can need 18,000 EUR of fixes, while a site built cleanly from the start often reaches 85 % conformance before any remediation.
The five most frequent failures
- Insufficient contrast: light grey on white, often on 30 to 40 % of pages.
- Images without meaningful alt text, especially service icons.
- Forms without associated labels or clear error messages.
- Keyboard navigation blocked in the main menu or modals.
- Untagged PDF documents: catalogues, datasheets, ESG reports.
Fix or rebuild? If the audit shows conformance below 40 % and the site is more than five years old, an accessible rebuild often costs only slightly more than heavy remediation. For an institutional site of this size, Kolonell prices the rebuild on quote, with the initial audit included in scoping.
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Sanne de Vries, CIO of a 250-employee logistics equipment supplier in Amsterdam, receives an audit showing 38 % conformance across the corporate site and the ordering portal. She compares two paths.
Remediation: 4,800 EUR for the audit, 24,000 EUR of fixes, 2,800 EUR for the re-audit, so 31,600 EUR, on a platform due for replacement within two years. Accessible rebuild: the audit is already paid, and the agency's rebuild quote bakes accessibility into design and development, so the company does not pay twice. Sanne uses a simple rule: if the rebuild costs less than 1.5 times remediation, rebuild. The risk calculation settles it for the board: a single municipal framework contract lost for lack of an accessibility statement was worth 210,000 EUR in annual revenue.
FAQ
Does a B2B SME with no online sales need to comply?
Usually not directly, as the EAA targets consumer services. But a growing share of public tenders and enterprise procurement now requires WCAG 2.1 AA, which turns it into a commercial obligation.
What happens if a company in scope does nothing?
Dutch market surveillance authorities can request information, order corrective measures and impose fines under the implementation act. Consumers and disability organisations can also file complaints, which tends to trigger inspections.
Is a free automated scan enough?
No, automated tools catch roughly 30 % of issues. A manual audit on 15 to 25 pages, between 3,000 and 7,000 EUR, remains necessary for a credible statement.
How long does compliance take?
Plan 4 to 10 weeks depending on the volume of fixes. The schedule is mostly driven by PDFs and editorial content to rework.
Should we aim for 100 % conformance?
Full conformance is rare, a realistic target is 75 to 90 % with a credible roadmap. The accessibility statement must honestly report the level reached and any exemptions claimed.
Let's scope your project. Send us your site URL, your transactional journeys and your tender deadlines, and we will scope the audit followed by a remediation or rebuild plan. 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.
