The Netherlands Sets a High Bar for EAA Compliance: ACM Introduces a Strict Reporting Framework for Inaccessible Digital Services

Introduction

In a significant move towards enforcing digital accessibility under the European Accessibility Act (EAA), the Netherlands Authority for Consumers and Markets (ACM) has published one of the most detailed and robust compliance frameworks yet seen among EU member states. This framework outlines clear obligations for organizations offering e-commerce and electronic communication services in the Netherlands, specifically on how they must report and resolve accessibility issues.

With a grace period ending on October 15, 2025, businesses now face a well-defined timeline and set of requirements. This blog explores the key highlights of the ACM’s reporting process, what it means for organizations, and whether other EU authorities will follow suit.

Who Is the ACM and Why This Matters?

The ACM is the designated monitoring authority for enforcing the EAA in the Netherlands, specifically responsible for ensuring that e-commerce platforms and electronic communication providers meet accessibility requirements. With the EAA becoming fully applicable across the EU from June 28, 2025, the clock is ticking for companies to make their services inclusive and accessible to people with disabilities.

What sets the Netherlands apart is the depth and clarity of ACM’s guidance. While many member states are still finalizing or have published high-level implementation plans, the ACM has gone a step further by defining a structured incident reporting system for accessibility violations — and it’s setting a new standard for transparency and accountability.

Check this European Accessibility Act Compliance: A Comprehensive Guide for Businesses

Key Elements of the ACM’s Accessibility Reporting Process

The ACM framework clearly distinguishes between different levels of accessibility issues and ties them to specific reporting deadlines. Here’s a breakdown:

1. Issue Categorization and Reporting Deadlines

Organizations must assess the severity of an accessibility problem and report it based on the following timeline:

• Critical and Serious Issues must be reported within 1 week of detection.
• Moderate and Minor Issues must be reported within 1 month of detection.

This classification introduces a risk-based urgency model, ensuring that more impactful accessibility failures are prioritized and resolved faster — a much-needed approach in the world of digital compliance.

2. The Accessibility Reporting Form

The ACM has launched a structured form for organizations to disclose accessibility problems. This goes far beyond a simple notification — it demands accountability and specificity.

Details required include:

• A description of the accessibility problems and where they occur (e.g., specific website pages, mobile app screens, etc.)
• An estimate of how many consumers are affected by the problem
• A declaration on when the organization expects to resolve the issues
• A projected remediation date
• A description of the measures being taken to fix the issues — along with corresponding dates
• Optional: Upload a remediation plan outlining actions and timelines

This level of granularity sends a clear message: compliance is not just a checkbox — it’s a managed process.

Grace Period Until October 15, 2025

Recognizing that organizations need time to adapt, the ACM has announced a grace period until October 15, 2025. During this period, reporting of accessibility problems is voluntary, offering businesses a runway to prepare their internal processes, conduct audits, and develop remediation plans. But come October 15, 2025, reporting becomes mandatory — and the ACM is expected to start enforcing compliance.

Why it Matters to E-Commerce and Digital Businesses?

The ACM’s new reporting framework should be a wake-up call to all e-commerce providers and communication service platforms operating in the Netherlands — and potentially elsewhere in Europe.

Here’s why it matters:

• Legal Compliance: Failure to report accessibility issues or resolve them could lead to penalties once the grace period ends. The detailed requirements make it easier for the ACM to audit, monitor, and enforce.
• Risk Mitigation: By identifying and reporting issues early, businesses can reduce legal and reputational risks — especially in sectors that rely heavily on digital interfaces.
• Operational Readiness: The requirement to document remediation plans and report on consumer impact forces organizations to mature their accessibility practices. It’s no longer enough to outsource a simple audit — teams need structured internal processes.
• Consumer Trust and Inclusion: Meeting accessibility obligations builds brand trust, expands customer reach, and ensures equal access for people with disabilities — a core principle of the EAA.

What Should Businesses Do Now?

With the grace period already ticking down, organizations need to act quickly:

1. Audit Digital Assets: Evaluate your websites, apps, and communication platforms for WCAG 2.1 Level AA compliance (minimum standard under the EAA).
2. Implement an Issue Tracking System: Set up internal tools to classify, track, and report accessibility issues according to the ACM's categories.
3. Develop a Remediation Plan: Work with accessibility experts to create clear, time-bound plans that can be shared with authorities if needed.
4. Train Teams: Educate development, design, and content teams on accessibility requirements and the importance of timely reporting.
5. Monitor for Updates: Keep an eye on guidance from other EU member states. The ACM may be the first — but likely not the last — to implement a detailed reporting process.

Conclusion

The Netherlands, through the ACM, has set a bold and transparent standard for how digital accessibility should be monitored under the EAA. By implementing a reporting structure tied to issue severity, demanding remediation plans, and ensuring accountability, the ACM is raising the bar for compliance across Europe. While it remains to be seen how quickly other countries will match this level of detail, the ACM's framework sends a powerful message: Digital accessibility is a process, not a one-time fix — and it must be managed accordingly. For businesses operating across the EU, the best path forward is to prepare for greater transparency, structured reporting, and consistent enforcement. The Netherlands may have led the way — but it’s only a matter of time before others follow.

That’s where BarrierBreak can help.

With deep expertise in European Accessibility Act (EAA) requirements and over 15 years of leadership in digital accessibility, BarrierBreak supports organizations in aligning with accessibility laws and standards. From accessibility audits, web and mobile remediation, and VPAT creation, to ongoing compliance tracking and training, we partner with you to make your digital assets inclusive and EAA-ready. We understand the challenges of navigating multi-country compliance — and we’re here to simplify the process with scalable, cost-effective, and expert-driven solutions.