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Accessible webshop: meet the WCAG law

Louie Valkhof
Louie Valkhof
12 min read
Isometric 3D magnifying glass surrounded by accessibility objects on a dark grid with rainbow rim lighting

Is an accessible webshop legally required?

Yes. An accessible webshop has been a legal requirement since 28 June 2025. The European Accessibility Act applies from that date to webshops, apps and payment terminals, and your webshop has to meet WCAG 2.1 level AA. Only the smallest companies escape it: organisations with fewer than 10 employees and under 2 million euro in annual revenue are exempt. In practice almost every serious e-commerce business falls under the law.

Enforcement became real in 2026. The Dutch regulator completed its first inspection round, and the result is sobering: at 61% of large Dutch webshops a customer with a disability cannot complete an order. This is no longer an abstract deadline but an active supervision track with sanctions at the end.

This article explains what the law demands, who it covers, what the regulator does when you fail, and why an accessible webshop does more than keep you out of trouble: it lifts your revenue too. No legal jargon, just concrete steps you can take this month.

What exactly does the WCAG 2.1 AA standard require?

WCAG 2.1 level AA is the standard the law prescribes. It sits between A (baseline) and AAA (strictest), and it is achievable for any webshop. The standard rests on four principles: your site must be perceivable, operable, understandable and compatible with assistive technology. In practice that translates into a handful of concrete requirements you can check today.

Perceivable means information is readable for everyone: enough colour contrast between text and background, alt text on images, and no information carried by colour alone. Operable means you can use the entire site with a keyboard, without a mouse. Understandable means clear error messages on forms and predictable navigation. Compatible means your code works with assistive technology such as screen readers.

The standard is not a matter of taste. These are measurable criteria. A button has enough contrast or it does not. An image has alt text or it does not. A form field has a linked label or it does not. That makes accessibility easy to test, and it makes it easy to build: you always know where you stand.

WCAG principle What it means Concrete example on your webshop
Perceivable Everyone can see or hear the content Sufficient contrast on buttons, alt text on product photos
Operable Everything works without a mouse Check-out fully navigable by keyboard
Understandable The site is predictable and clear Error message states which field is wrong and why
Compatible Works with screen readers and assistive tech Correct HTML structure and labels

Who falls under the accessibility law?

Almost every webshop in the Netherlands. The law makes one exception, and it is small: micro-enterprises that stay both under 10 employees and under 2 million euro in annual revenue. Both thresholds have to apply. Cross either one and you fall under the law and must meet WCAG 2.1 AA.

The threshold is deliberately low. The legislator wants accessibility to become the norm, not the exception. For most e-commerce founders we speak to it simply means: this applies to you. A webshop with serious traffic and a team around it almost always sits above the revenue threshold.

One thing to watch: the exemption applies to the whole company, not per webshop. Run several shops under one entity and you add everything up. And if you grow past a threshold this year, you fall under the law from that moment on. Do not leave it to the last minute.

Situation Exempt? Note
< 10 employees AND < 2 million euro revenue Yes Both thresholds must apply
12 employees, 1.5 million euro revenue No Above the employee threshold
6 employees, 3 million euro revenue No Above the revenue threshold
Growth past a threshold this year No Law applies from the moment you cross it

What does the regulator do if you fail?

Enforcement happens in phases, so you get a chance to fix things first. But the odds of being caught have become real. In the first inspection round in March 2026 the ACM checked roughly 100 large webshops, and at 61% of them a customer with a disability cannot place an order. That is not a sample you easily slip through.

The approach runs in steps. First you receive a written deadline to remedy the shortcomings. If you do not respond, or respond insufficiently, a sanction follows: a fine or a penalty payment, where you pay per unit of time for as long as you fail to comply. That first inspection round came nine months after the deadline. The announcement phase is therefore over: the regulator has its baseline and knows which parties score badly.

The biggest risks sit in fixed places. Check-out and product comparison are the biggest operational bottlenecks in 2026, partly because of legacy platform architecture. That makes sense: those are exactly the areas with many forms, steps and dynamic elements. The good news is that they are also the places where accessibility and conversion overlap most.

How big is the accessibility gap really?

Huge. Most webshops do not comply right now, and that is not a guess but measured data. 95.9% of all homepages contain WCAG errors, averaging 56.1 errors per homepage. That is not an outlier but the structural picture: most of the sites you visit daily fall short somewhere.

That sounds like bad news, but it is mostly an opportunity. If almost everyone leaves it untouched, you stand out the moment you get it right. Your webshop becomes usable for a group that currently drops off systematically, and you get ahead of the competitors who wait until the regulator knocks.

The group that drops off is also large. A substantial share of people in the Netherlands lives with a long-term limitation, according to figures from CBS, the Dutch statistics office. That is not a niche. It is a substantial part of your market that currently runs into an inaccessible check-out and moves to another shop. Read more about why many webshops do not convert despite good traffic.

Why does accessibility lift your conversion?

Because an accessible webshop is simply a more usable webshop. The fixes you make for WCAG compliance (clear contrast, logical navigation, short forms, clear error messages) are exactly the fixes that lower the barrier for everyone. And the effect on revenue is direct: accessible means usable, and usable means you stop losing this audience. A large majority of users with access needs (around 71%) will click away from a site they find hard to use, and around 82% would spend more on sites that are accessible. That shifts the story from "required by law" to "pays for itself".

The effect is strongest on mobile, and that is where the volume sits. 69% of all online orders now come via smartphone, yet the Netherlands underperforms precisely on mobile compared with countries like Germany and the United States. With a Dutch e-commerce market worth 35 billion euro in 2025, that gap costs the sector billions. An accessible, fast, simple mobile experience is exactly the lever.

The technical detail makes it concrete. Load time is a conversion killer: every extra second of load time costs, indicatively, roughly 7% conversion, and on mobile a slow page is where visitors drop off most. The same goes for forms in your check-out: every extra field lowers conversion. Cutting fields and steps helps both your accessibility and your revenue.

What does a slow, complex check-out cost you?

Far more than you think. The check-out is where law and revenue meet: it is the biggest WCAG bottleneck and the place where most customers drop off. Every second of load time and every redundant form field costs you money, and it is measurable.

Speed counts directly. Every extra second of load time costs, indicatively, roughly 7% conversion, and on mobile a slow page is a direct cause of drop-off. Forms work in the same direction: the more fields you ask for, the more people drop off before they finish. Cutting fields and steps therefore helps both your revenue and your accessibility.

Bottleneck Effect on conversion Accessibility gain
+1 second load time indicatively around -7% A faster site is more usable for everyone
Slow mobile page More drop-off before check-out Lower barrier, fewer drop-offs
More form fields Lower conversion, more drop-offs Fewer fields means fewer errors, easier to operate

The lesson is simple: a check-out you make accessible, you also make faster and shorter. The same fix serves two goals. That is why an accessibility test always starts here.

What gets added to that same checkout on 27 September

A second legal obligation lands on exactly the same screens this autumn. If you are opening up your checkout for accessibility anyway, it pays to take both in one go.

On 27 September 2026 the measures from the Empowering Consumers Directive start to apply. That directive amends Article 6(1) of the Consumer Rights Directive, the article covering distance selling, and places a series of new information duties on the product page and in the shipping step.

New or amended Where it lands Does it touch your accessibility work?
Show an environmentally friendly delivery option if you have one Shipping step of the checkout Yes: an extra choice element that must be keyboard operable and correctly labelled
Reminder of the legal guarantee, prominently shown Product page Yes: "prominent" and "legible" call for contrast and heading structure, not a footer line
Durability guarantee longer than two years Product page Limited
Minimum period of software updates Product page Limited
Reparability score, where applicable Product page Limited
Spare parts: availability, cost, ordering procedure Product page plus repair page Yes: a new page means new navigation and forms

Two of those points land exactly where the regulator itself identifies the biggest bottlenecks: the checkout and the product page. A guarantee block that legally has to be prominent but sits grey on white at the bottom of the page fails two laws at once.

Practically this is one development round instead of two. Anyone touching the checkout in September takes the new fields along; anyone scheduling them separately pays twice for the same testing work. The full breakdown of the information duties is in what must be on your product packaging and in your listing in 2026.

One warning: the harmonised label and the standard notice from Article 22a are being set at EU level. Do not design those ahead of time.

How do you make your webshop accessible, step by step?

Start by measuring, then build. You do not make a webshop accessible in a single sprint, but you know within a few days where you stand. A test against the WCAG 2.1 AA criteria shows which errors you have and how heavily they weigh. Then you fix them in order of impact, beginning with the check-out.

The practical order we follow:

  • Step 1: Test your site. Run your key pages (homepage, product page, category page, check-out) against the WCAG criteria. You get a list of concrete errors, not an abstract report.
  • Step 2: Contrast and alt text. These are the most common errors and often quick to fix. Adjust colour contrast on buttons and text, add alt text to product photos.
  • Step 3: Keyboard operation. Go through your entire site without a mouse. Can you reach and operate every button, every menu and the whole check-out? If not, fix the focus order.
  • Step 4: Forms and error messages. Link labels to fields, cut redundant fields, and make sure error messages state which field is wrong and why.
  • Step 5: Retest and safeguard. Test again, and document how you stay accessible when adding new pages and products.

The good part is that none of these steps gets in the way of your brand. Accessible does not mean dull or generic. You can meet WCAG 2.1 AA and still have a webshop that looks sharp and feels like your brand. That just requires design and development that work together from the start.

What does Oase Creative do for accessible webshops?

We build webshops that are accessible and brand-consistent, in one trajectory. That is exactly where many parties fall short: the developer delivers a technically correct but visually flat site, or the designer delivers something beautiful that fails the WCAG test. With us, design and development sit under one roof, so accessibility is not a coat of paint afterwards but a starting point.

In practice that means we design with sufficient contrast from the first sketch, we build forms that are short and operable, and we test the check-out with keyboard and screen reader before going live. The result is a webshop that meets the law and converts, without looking like a compromise. For brands on Shopify the same applies: an accessible theme is a design choice, not a limitation.

Want to know where you stand? Start with a test against the WCAG 2.1 AA criteria: within a few days you have a concrete view of your biggest errors and what they cost you in conversion. Read more about how we think about GEO and findability for webshops, because accessible, well-structured code also helps search engines. Or get in touch to walk through your situation.

Frequently asked questions

Below are the questions we get most often about the accessibility law and what it means for your webshop. Short and concrete, the way you would ask a search engine.

Updated on 31 augustus 2026

Louie Valkhof
Louie ValkhofFounder & Art Director, Oase Creative
Knowledge Base

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