Digital accessibility in a post-EAA deadline world: Actionable advice for developments in the Netherlands and France
The European Accessibility Act (EAA) deadline was June 28, 2025, and we are now in a post-deadline world. For any business based in or selling into the European Union (EU), preparation is no longer the issue. The new era of digital accessibility is defined by monitoring, enforcement, and accountability. From this point forward, products and services, new web page content, and feature updates must be accessible.
If there were doubts about whether the EAA would be enforced with rigor, those doubts can now be dismissed.
Two recent developments make this clear. In the Netherlands, companies are being asked not only to demonstrate progress but to acknowledge where they fall short and explain how they plan to improve. In France, four of the country’s largest grocers are facing legal action and reputational fallout after disability groups brought a high-profile case against them.
In this post, we’ll explore these two developments as early signals and position them as springboards to action.
It’s essential to understand that the EAA is not going away and that scrutiny will only increase. Your organization needs a long-term plan—one that involves every team across the company.
This post will equip you with insights to bring back to your organization, helping you spark the vital conversations about what needs to be done and how to move forward.
Let’s begin with the developments in the Netherlands.
The Netherlands: Transparency through mandatory reporting
To set context, remember that each country in the EU must transpose EAA requirements into national law. They must declare conformity, and they must have a regulatory body (often called Market Surveillance Authorities) responsible for monitoring and enforcement. In the Netherlands, one of their monitoring bodies is the Dutch Authority for Consumers and Markets (ACM). Their primary oversight is e-commerce.
The ACM has published its process for the “reporting obligation in case of non-compliance with accessibility”:
“Do you have an e-commerce service or electronic communications service that doesn’t meet accessibility requirements? Then you’re required to report this and take action. Your report will help us understand your progress.”
The letter campaign to raise deadline awareness
The ACM is trying to take a proactive and transparent approach. They have a letter campaign to businesses operating in the Netherlands to ensure they are aware of this non-conformance reporting deadline, and to remind them of their obligation to report their conformance in their statements of service. From Deque’s discussions with the ACM, it is important to note that the letter campaign is not yet fully executed (your business may still receive one in the days leading up to the ACM deadline). It should also be stressed that businesses should not wait to receive a letter or assume that not receiving one means that the reporting requirement does not apply to them. All affected businesses are required to report.
Plans for data usage
The ACM intends to use the first round of data to identify the biggest challenges people with disabilities are facing and potentially offer clarifications and recommendations to businesses on how to rapidly improve conformance. The inclusion of a plan-to-conformance will be used to help the ACM understand the biggest issues companies are facing and to provide insight into how mature a company’s plans are to reach conformance.
So what does it all mean? There are EAA requirements and processes for Conformity Declarations, but this activity in the Netherlands introduces a process for non-conformity reporting requirements.
Reporting requirements
Organizations must describe where they are failing to meet conformance to EAA and outline a credible plan for addressing those gaps. It also means that, as of October 15, 2025, reporting of newly found accessibility issues will be mandatory. Reporting requirements are strict, and categorized by degree of severity: issues defined as critical or serious must be reported within one week of detection, and moderate or minor issues must be reported within one month. There is a caveat, however, that you do not need to report if you resolve the violation within the respective reporting window. Imagine how this will affect your development teams and product owners. It offers your accessibility program a clear path forward, ensuring that accessibility defects do not end up in the backlog.
With this requirement, organizations must track, categorize, and communicate with regulators in an ongoing model. For this to be possible, the entire organization must be engaged—not just the development teams tasked with identifying and fixing accessibility issues, but all the way from the product owners to regulatory reporting teams.
The importance of cross-functional collaboration
Some other things to consider: Is your customer service team prepared to answer questions about accessibility, and have they been trained on disability etiquette? Does your social media team understand how to add alt text to images and caption videos? Is your procurement team equipped to evaluate vendors for accessibility? Does your regulatory reporting team have a process in place to receive and analyze your release conformance data? Does your compliance team have a process in place to ensure that teams are retaining, storing, and can recall conformance data during a regulatory inquiry event?
Phew! That’s a lot! It is crucial that your organization recognizes that every team has a role to play. For reporting to be accurate and comprehensive, there must be effective cross-functional collaboration and communication.
How to use this information to support digital accessibility reporting at your organization
Let’s say you are part of the Central Accessibility Team (CAT). You could approach your regulatory reporting team to discuss ensuring they have the necessary data for their required Dutch reporting. You can determine whether that will be your role or that of some other individual or team within the company. It could be the technology team, your CAT team, the compliance organization, or even different product owners. Start the dialog now—if it’s your team, you’ll want ample time to prepare. Additionally, you can speak with your respective teams to ensure that if a demand letter is received from a monitoring body, it is routed to more than just the regulatory team—your accessibility team needs visibility, too.
France: Accountability through lawsuits and public campaigns
In France, disability organizations, working in conjunction with legal partners, have recently issued a demand against four major grocery retailers for failing to make their digital services accessible.
The influence of a public campaign
That alone is a major development. However, what makes this case especially notable is that the legal action has been accompanied by a public campaign, featuring press releases, social media visibility, and media coverage that has pushed the case into the spotlight. The defendants now face not only legal and financial risk, but also reputational damage in full public view.
The press release made clear just how high the stakes are:
“Since June 28, 2025, the Consumer Code has required small, medium, and large businesses to market products and services that are accessible to all, in order to remove barriers that constitute a disability. In an era of dematerialization and digitalization of our economy, this obligation is crucial to ensuring the digital accessibility of online services.”
It was equally clear about the risk faced by the named defendants:
“If the online shopping services offered by these companies are not made fully accessible by September 1st, the associations will turn to the courts to put an end to this violation of the law, which is the cause of serious discrimination against people with visual impairments.”
This case may be a first, but it most certainly will not be the last of its kind.
The many pathways to register complaints
Much of the strength of the EAA lies in its multiple pathways for calling attention to non-conformance and instances of discrimination. Individuals can bring complaints directly to brands or regulators. Advocacy groups and disability organizations can mobilize as social movements to complain directly to the brand or the regulators and pursue litigation. Monitoring bodies themselves can increase scrutiny, send demand letters, and even pursue legal action of their own.
How to use this information to raise digital accessibility awareness at your organization
As with the Dutch situation, you can use your knowledge of the situation in France to instigate an EAA-related dialogue—perhaps with an area of the business that you have not yet spoken to, such as the brand team or your legal team. You could even talk with customer support to ensure that they’re listening for similar demand-like comments from your customers. You could also alert your public relations team and encourage them to expand their “channel listeners” to include news about the EAA and digital accessibility.
From signals to strategy: Achieving long-term transformation
The EAA is creating a permanent state of accountability. Reporting requirements, lawsuits, and public campaigns are all mechanisms that require organizations to fully, completely, and comprehensively embrace digital accessibility.
What these Dutch and French use cases signal is that the EAA will continue to need our attention well past the June 2025 deadline. At the same time, we can see that these situations are only one facet. Long-term transformation is required for every organization impacted by the EAA, and reactive emergency measures alone will not be sufficient.
As scrutiny intensifies, companies will need to reshape how they operate. Accessibility must be built into governance, decision-making, and daily workflows. Teams that may have once worked in silos—such as developers, designers, customer service, and marketing—will need to act in concert with accessibility leaders and executives. Knowledge will need to flow across the organization so that every individual and group knows what they’re responsible for and how their efforts connect to the broader picture.
Your opportunity as an advocate
Regardless of your role, if you care about digital accessibility and want to see your organization stay ahead of these requirements, you’re in a position to be an advocate and raise awareness. Talk to your manager, your compliance officer, your accessibility leader. Leverage the above ideas on how you might use these developments in your organization to invigorate your company’s preparedness. Share this post within your company communication channels and your network. Ask open-ended questions about how the new deadline in the Netherlands needs to be addressed, or whether there is awareness about the French action.
If accessibility is already a priority at your company, this is an ideal time to take things to the next level. If awareness isn’t at the full enterprise level yet, or if certain doors have remained closed to these conversations, now is the time to open them. This is about translating insight into action.
A practical first step
The most important first step is to understand how conformant you are – or how much risk you have. This can be done by running audits. You need to test your digital properties and assess your current state. For more accessibility-mature organizations, you need to ensure that the processes you have implemented have led to conformance. If these steps seem daunting, prioritize. Try to think like an auditor. What are they going to be looking at first? Your most trafficked pages. And it’s probable they will prioritize unauthenticated spaces over authenticated ones, so that’s where your focus should be as well.
How will they be able to monitor at scale? They’re likely going to begin with automated testing—to catch as much as they can, as quickly as they can. This could be your approach, as well. You want to find what they potentially would find—however, it’s best to find it before they do.
Test against the right standards
Here’s something else to understand: The monitoring bodies aren’t going to try to reinvent the wheel in real time. More likely than not, they will work within their existing systems. The Web Accessibility Directive (WAD) was established for the public sector in 2016, with the first compliance deadline coming in 2018. It established a mechanism of a wide, automated testing pool and a focused manual testing effort. That’s the experience they have at their disposal. EAA requires digital content to be compliant with EN 301 549, which incorporates WCAG 2.1AA. So that’s the standard you should be testing to, because that’s what the monitoring bodies are likely to be testing to. You can even future-proof things by testing to EN 301 549 and WCAG 2.2 AA.
Get started with Deque today
While compliance frameworks provide the benchmarks, long-term success depends on how well your organization integrates accessibility into everyday practice. The real goal is not to fix defects, but to prevent them from happening in the first place.
Deque is uniquely positioned to provide the expert strategic guidance and support necessary to stay ahead of regulatory scrutiny, ensure a defensible position, reduce organizational risk, and build a sustainable program that keeps you on the right side of the law—and of history.
You’ll have an opportunity to engage with us live during our upcoming webinar on September 25, “Making sense of the post-deadline EAA landscape.” During this informative conversation, experts from Deque and law firm Taylor Wessing will share insights on the latest developments related to the EAA.
Please join us to:
- Determine how the new non-conformance requirement may apply to your organization.
- Understand differences and requirements related to both conformance and non-conformance reporting.
- Discover how the monitoring bodies hope to use your non-conformance report and your plan-to-reach-conformance information.
- Learn about association and disability group demands, and how they could be used to mature your EAA plans.
- Get expert answers to your most pressing EAA questions.
