Do I have to report accessibility problems to the ACM?

Who has to report?

Businesses that offer online shopping or electronic communications services to consumers in the Netherlands, unless they're a micro-enterprise. The duty comes from the EAA, which says service providers must "immediately inform" the national authority when their service doesn't meet the accessibility requirements, with details of the problem and what they're doing about it.

In the Netherlands, who you report to depends on your service:

If you're active in more than one EU country, you report to the regulator in each country. The ACM points out that you remain responsible for the reports in each country yourself.

Micro-enterprises (fewer than 10 staff, and €2 million or less in annual turnover or balance sheet total) are exempt from the accessibility requirements and from the obligations that come with them (Article 4(5) of the EAA), so they don't have to report either.

What counts as a problem, and how serious is it?

Anything that makes your service fail the accessibility requirements, rated by how much it affects a customer with a disability. In practice, the ACM measures websites and apps against the international accessibility standard, WCAG, at level AA. It covers the whole process of buying: searching, choosing, logging in and paying. And you're responsible even if another company built your site.

The ACM uses four impact levels. Here are its definitions, translated, with examples of the kind of problem that could fit. The examples are ours, not the ACM's.

The ACM's own research gives a sense of what "critical" looks like. In March 2026 it reported that at 61% of the largest Dutch online shops, people using assistive technology couldn't place an order, for example because the order button didn't work with a keyboard or a CAPTCHA couldn't be used.

Rating a problem takes judgement. When you're unsure between two levels, choose the higher one: it only shortens your deadline. You have to report again if the impact turns out to be higher than you reported.

How fast do I have to report?

Fix it straight away if you can. If you can't, report critical and serious problems within 1 week and moderate and minor problems within 1 month. The ACM's wording, in our translation:

• If your e-commerce service or electronic communications service isn't accessible, you must fix it right away. If that doesn't work, you must report it to us.
• Critical and serious problems: report within 1 week. You don't need to report if you've fixed it within the week.
• Moderate and minor problems: report within 1 month. You don't need to report if you've fixed it within the month.

The law itself says "immediately". The 1-week and 1-month periods are the ACM's guidance on what that means. The ACM doesn't say exactly when the clock starts, so the safest reading is from the moment you know about the problem.

What goes in the report?

Which parts aren't accessible, how serious each problem is, your plan to fix them, and the date you expect your service to be fully accessible. You report through the ACM's online form. There's no email option that we could find. You get a confirmation by email, and the ACM says it won't contact you afterwards unless it has questions.

Prepare this before you open the form:

1. Your company details.
2. Which parts of your service aren't accessible, for example "checkout, step 2: delivery options".
3. The impact level of each problem: critical, serious, moderate or minor.
4. Your plan to make the service fully accessible. You attach it to the report. The law adds that you describe the corrective measures you've taken in detail.
5. The date you expect the service to be fully accessible.

After that, you report again only if a problem turns out to be more serious than you said, or if the date for full accessibility moves.

What if fixing it would be too much?

You still report it. The EAA has two narrow exceptions: when meeting a requirement would fundamentally change your service, or would be a disproportionate burden. If you rely on either, the ACM says you "must report this to us". You must also document your assessment. You don't have to send it right away, but you must have it ready if the ACM asks.

The ACM is clear about one thing: a lack of time or knowledge doesn't count as a disproportionate burden.

What about Belgium?

Belgium has the same duty in law, to inform the authorities "immediately", but we found no fixed timetable like the ACM's. Belgian online shops and consumer banks report to the Economic Inspection of FPS Economy. We found no Belgian reporting form, so check with FPS Economy how to report. Remember that in Belgium, micro-enterprises are only exempt until 28 June 2030.

What to do next

1. Find out where your site stands, so you know whether you have anything to report. An accessibility review gives you a list of problems with an impact level for each.
2. Fix critical and serious problems first. If you fix them within a week, you don't need to report them.
3. For anything you can't fix in time, write a short plan with dates, and report it through the ACM's form.
4. Keep your accessibility statement consistent with what you reported.
5. Note the date you'll be fully accessible, and report again if it moves.