What applies
The European Accessibility Act has been enforceable since 28 June 2025. Netherlands implements it through Implementatiewet toegankelijkheidsvoorschriften producten en diensten. The Act does not itself list technical requirements — it points at harmonised standard EN 301 549, which adopts WCAG 2.1 level AA for web content.
Dutch enforcement leads with an order to remedy within a set period, with penalty payments accruing for each period the failure continues.
Penalties
The ceiling in Netherlands is €90,000. In practice enforcement usually begins with a complaint, followed by a requirement to remedy within a stated period; penalties attach to failure to act rather than to the first finding.
Who is in scope
Ecommerce services sold to consumers are in scope, including stores established outside the EU that sell into it. Microenterprises — fewer than 10 people and under €2 million turnover — are exempt for services in most member states, but the exemption is narrower than merchants tend to assume and does not cover products.
What to do about it
The technical test in both cases is WCAG 2.1 level AA. Run the scan, fix the ranked findings, and keep the dated report as a record of what you identified and when. Automated testing covers part of the standard; a full assessment needs a qualified auditor.