Accessible healthcare website: does the EAA apply to you?

What the European Accessibility Act covers

The Netherlands implemented Directive (EU) 2019/882 sector by sector. For business websites the rules on e-commerce services are in the Dutch Civil Code (Book 6, Articles 230fa to 230fd) and apply since 28 June 2025, supervised by the ACM. The ACM describes an e-commerce service as an online service through which consumers can buy, rent, order, take out or book something, including searching, choosing, logging in and paying. Its examples come from travel and retail; it says nothing about healthcare.

Does it apply to a healthcare website?

• Micro-enterprises are exempt.
• Larger organisations offering online booking, registration, courses or payments should assume that part of the website may be covered.
• Self-pay services sold online are closest to the definition.

The micro-enterprise exemption

Article 6:230fc of the Dutch Civil Code exempts enterprises with fewer than 10 employees and an annual turnover or balance sheet total of at most 2 million euros. A solo practice or a six-person physiotherapy practice usually qualifies; a home-care organisation with fifty staff does not.

WCAG 2.1 or 2.2, and the statement

The ACM asks for WCAG 2.1 level AA (through EN 301 549) and expects WCAG 2.2 AA to become the standard during 2026; aim for 2.2 when building something new. Covered businesses publish an easy-to-find, accessible accessibility statement. No audit certificate is required. Private care providers have no general statutory accessibility duty outside the EAA; the separate Dutch duty applies to public bodies.

Why do it anyway

Healthcare websites are used by older people with poorer eyesight, carers on a phone, people with limited literacy and people with disabilities. An accessible site means fewer calls and fewer mistakes. See our pages for home care, day care and maternity care.

Quick fixes

1. Alt text for meaningful images.
2. Sufficient contrast, including buttons.
3. Visible labels on every form field and specific error messages.
4. Everything works with the Tab key, with visible focus.
5. Large enough touch targets on phones.
6. Logical headings, correct page language, captions on video.
7. Plain language, and no key information only in a PDF.

Accessibility overlays do not make a site compliant. All points are on the printable healthcare website checklist.

This guide describes Dutch rules as we read them on 28 October 2026. It is general information, not legal advice. Rules and regulator guidance change; check the sources, and ask your trade association or a lawyer when your situation is specific.