Since 28 June 2025, digital accessibility is no longer just good practice in Belgium: it is a legal obligation for a large share of online commerce. For e-commerce and banking services, the European Accessibility Act was transposed into Belgian law by the Act of 5 November 2023, which added new requirements to the Code of Economic Law. Many businesses have heard of it, few know exactly whether it applies to them. And a good deal of what circulates on the subject is approximate, sometimes plainly wrong.
Who is concerned
The law targets e-commerce services, defined as services provided at a distance, through a website or a mobile app, at the individual request of a consumer. In other words: as soon as your website or app lets a private individual enter into a contract, whether buying a product, booking a service or taking out a subscription, you are in scope. Consumer banking services are covered too.
Two categories fall outside the obligation, at least for now:
- Pure B2B: if your platform only serves professionals, that service is out of scope
- Micro-enterprises, until 28 June 2030: fewer than ten people, and an annual turnover or balance sheet total not exceeding 2 million euros
That second point deserves a careful read. The European directive exempts micro-enterprises that provide services. Belgian law only grants them a delay: from June 2030, they come into scope like everyone else, unless the King excludes them by royal decree, which the law allows. A small online shop rebuilding its website today therefore has every reason to make it accessible from the start, rather than betting on a possible exemption and having to rework everything by 2030.
There is no grace period for existing sites
It is the most widespread misconception: existing websites supposedly have until 2030 to comply. That is not what the law provides for services. Since 28 June 2025, a consumer-facing e-commerce service must meet the accessibility requirements, whether it launched before or after that date. The only flexibility concerns contracts concluded with consumers before that date, which may continue unchanged for five years at most, and some equipment already in use. None of it applies to your website or app as such.
What the standard actually requires
The technical reference is the European standard EN 301 549, which carries over the WCAG 2.1 level AA criteria for the web. Behind the acronyms are very concrete things: being able to navigate entirely with a keyboard, providing text alternatives for images, ensuring sufficient contrast, allowing text to be enlarged without breaking the page, giving form fields clear labels, making the checkout usable with a screen reader. Nothing exotic: these are the foundations of a well-made interface.
On top of this comes a duty to inform: the provider must explain how its service meets, or does not meet, the accessibility requirements, in a form that is itself accessible. This is commonly called the accessibility statement. Enforcement lies with the Federal Public Service Economy, and breaches are subject to the penalties set out in the Code of Economic Law.
Accessibility is built in, not bolted on
You can fix an existing website, and it is often necessary. But accessibility added after the fact is expensive and decays quickly: every new page, every new component reintroduces the same flaws. It lasts when it is written into the basic building blocks of the interface: a button made accessible once and for all, a form field labelled correctly everywhere it is used. It is one of the best arguments for a design system: it turns a legal requirement into a property of the product.
Be wary, while you are at it, of overlays promising instant compliance through a widget added to the page. They do not fix the interface code, and they do not replace work on the interface itself.
An accessible interface is not a watered-down version for a few. It is a better-made interface, for everyone.
Where to start
The sensible approach comes in three steps. First, check whether you are in scope: consumer-facing service, company size, presence of a purchase or booking journey; if in doubt, legal advice will settle it. Next, have the journeys that matter audited, starting with the one that leads to payment, because that is where exclusion costs the most, for users and for you. Finally, plan the fixes and publish an honest statement of where you stand, rather than waiting for a perfection that will never arrive in one go. As with e-invoicing, the legal constraint is also a chance to straighten out what was shaky.
Accessibility is part of how we design interfaces, not an option ticked at the end. If you are launching or redesigning an online service, it is the best moment to build it in, and it is exactly what we do in interface design. If your website already exists and you do not know where it stands, write to us: a first review of your main journey is often enough to see clearly.