European Accessibility Act (EAA) in Belgium – All the Key Details

Melwyn Joseph

06 May 2025 | 8 minute read
Illustration of the Belgian flag with an EU accessibility symbol (a person inside a circle of stars), representing Belgium’s implementation of the European Accessibility Act (EAA).

While EAA is implemented similarly across most countries, there are some minor differences, so it’s necessary to understand the specifics. If you’re a business operating in Belgium and working on EAA compliance, we’re here to help you understand what’s required.

In this post, we break down everything you need to know about the European Accessibility Act in Belgium – who needs to comply, key exemptions, deadlines, penalties, and the steps you need to take to stay compliant. By the end, you’ll have a clear, practical understanding of what’s expected.

How Is the EAA Implemented in Belgium?

Belgium implemented the European Accessibility Act (EAA) by amending existing national laws rather than creating one single law. The core of this transposition happened through the Belgian Accessibility Act, adopted in November 2023.

This law:

Together, these changes introduce accessibility requirements for services like e-commerce, online banking, and consumer-facing digital platforms.

Who Needs to Comply with the EAA in Belgium?

Private-sector companies that manufacture, distribute, or provide consumer-facing products and services in Belgium must comply with the EAA (unless exempt).

Key areas covered include:

  • Websites and mobile applications: All consumer-facing sites and apps, such as e-commerce platforms, banking apps, and streaming services, must meet accessibility standards.
  • Digital services: Includes online marketplaces, financial services, telecom platforms, and public transport booking/check-in systems.
  • Physical products: Consumer devices like smartphones, computers, ATMs, ticketing machines, and self-service kiosks must be designed to be accessible.
  • Electronic communications and media services: TV services, video-on-demand platforms, and telecom providers must support features like screen reader compatibility, subtitles, audio descriptions, and accessible user interfaces.

Who Is Exempt from the EAA in Belgium?

While most businesses need to follow the new accessibility rules, there are a few exceptions under Belgium’s implementation of the European Accessibility Act (EAA):

Micro-enterprises

If your business has fewer than 10 employees and earns €2 million or less per year, you’re temporarily exempt from service-related accessibility requirements – but only until June 28, 2030.

Disproportionate burden clause

You can apply for a partial exemption if meeting a specific accessibility requirement would cause excessive cost or technical difficulty.

  • This applies only to the specific requirement that causes the burden, not to the whole law.
  • You must document your reasons clearly and be ready to share them with regulators if asked.

Fundamental change exception

If an accessibility requirement would fundamentally alter the core function of your product or service, you may request an exemption.

  • You’ll need clear justification and supporting documentation.
  • Authorities must be able to review and approve your claim.

Even if you’re claiming an exemption, make everything as accessible as possible within your constraints.

Also, you’re still expected to be transparent: publish an accessibility statement, clearly explain any exceptions you’re relying on (like a disproportionate burden or fundamental change), and show that you’re actively working to improve accessibility wherever you reasonably can.

What Are the Compliance Deadlines?

Belgium follows the EU-wide timeline for the EAA, with a few additional grace periods built in. Here’s what businesses need to know:

28 June 2025:

All new or significantly updated products and services placed on the market from this date must comply with EAA accessibility requirements. ​

28 June 2027:

Emergency services, such as the 112 number, must meet accessibility requirements, including real-time text, video relay, and other accessible communication options. ​

28 June 2030:

  • Products and services already on the market before 28 June 2025 must comply with EAA requirements by this date or upon their next significant update, whichever comes first.
  • Micro-enterprises (businesses with fewer than 10 employees and an annual turnover or balance sheet total not exceeding €2 million) are exempt from service-related obligations until this date.

28 June 2045:

Self-service terminals (e.g., ATMs, ticketing machines) installed before 28 June 2025 can remain in use for up to 20 years but must comply with EAA requirements by this date at the latest.

What Are the Penalties for Non-Compliance?

If your business fails to meet the accessibility requirements under the Belgian implementation of the European Accessibility Act (EAA), there are serious consequences. Enforcement focuses on both financial penalties and restrictions on market access.

  • Monetary fines: Fines can go up to €200,000 per breach. The amount depends on factors like the severity of the violation, the company size, and whether it’s a repeat offence. Multiple violations can lead to cumulative fines.
  • Product market restrictions: Non-compliant products (like smartphones, ATMs, or ticket machines) can be banned from sale in Belgium or recalled if already on the market. These actions fall under product compliance and EU market surveillance laws.

When an authority identifies a violation (through a complaint or an inspection), the first step will typically be a notice or order to comply. The company will be given a deadline to fix the accessibility issues and bring the product or service into conformity.

How to Ensure EAA Compliance in Belgium

To ensure EAA compliance in Belgium, businesses must meet the accessibility requirements outlined in the European Accessibility Act. While there isn’t a single, unified law, the standard for compliance is consistent: your products and services must be accessible to people with disabilities.

This means aligning with two key technical standards:

  • EN 301 549 for both digital services and physical products
  • WCAG 2.2 Level AA for websites, apps, and digital content

Here’s how to get started:

Step 1: Identify affected products and services

Determine which of your consumer-facing products and digital services fall under the EAA. These include websites, mobile apps, e-commerce platforms, banking interfaces, telecom services, self-service terminals (like ATMs or ticket machines), e-books, and video streaming platforms.

Step 2: Conduct an accessibility audit

Evaluate your digital platforms and physical products against EN 301 549 and WCAG 2.2 Level AA to spot any accessibility gaps. Use WebYes to test your website or app, and seek expert advice for hardware or sector-specific services like telecom or transport.

Step 3: Develop a compliance roadmap

Use your audit results to build a clear action plan. Focus on fixing high-impact accessibility issues first, and assign clear responsibilities to make steady progress, keeping Belgium’s June 28, 2025, deadline in mind.

Step 4: Train your teams on accessibility

Make sure your designers, developers, and content teams understand the WCAG principles and how they apply in practice. Offer ongoing training to embed accessibility into your design, development, and QA processes.

Step 5: Publish an accessibility statement

Once you’ve improved accessibility, publish a statement on your website or with your product. This is a legal requirement in Belgium and should clearly outline your compliance status and give users a way to report any issues.

Step 6: Implement continuous monitoring

Accessibility is an ongoing responsibility, not a one-time fix. Regularly re-test your digital platforms using WebYes for automated monitoring, and schedule manual checks for physical products and custom digital solutions to stay compliant long term.

How Can WebYes Help You Meet EAA Requirements in Belgium?

WebYes can help you make your website EAA compliant. You don’t need to spend hours trying to interpret complex WCAG guidelines – our tool does the heavy lifting by automatically detecting issues and guiding you through simple, clear fixes.

Here’s how WebYes supports your accessibility and compliance journey:

  • Instant accessibility audits: Scan your site for WCAG 2.2 issues with a single URL – no setup required.
  • AI-powered fixes: Get AI solutions you can review and paste directly into your code to fix accessibility issues.
  • Continuous monitoring: Stay compliant with regular scans that catch issues before they impact users or put you at risk.

By helping you meet WCAG 2.2 Level AA – the standard behind Europe’s accessibility rules – WebYes sets you on the path to EAA compliance. Run a free website audit to check your site’s accessibility and take the first step toward compliance.


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