# European Accessibility Act in Belgium: What Must Your Webshop Do? | Fokuus

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# European Accessibility Act in Belgium: What Must Your Webshop Do?

Since 28 June 2025, Belgian webshops for consumers must be accessible; microenterprises only from 2030. Who is covered, and what actually helps?

[Anton Pycarelle](https://fokuus.be/en/about/)  25 September 20267 min read time

## In this article

- [What the law requires of your website](https://fokuus.be/#wat-de-wet-van-je-website-vraagt)
- [Webshop, showcase site or microenterprise: who is covered](https://fokuus.be/#webshop-vitrinesite-of-micro-onderneming-wie-eronder-valt)
- [What happens if you do nothing](https://fokuus.be/#wat-er-gebeurt-als-je-niets-doet)
- [Why an overlay plug-in is not a solution](https://fokuus.be/#waarom-een-overlay-plug-in-geen-oplossing-is)
- [Fix what is there, or rebuild](https://fokuus.be/#aanpassen-wat-er-staat-of-opnieuw-bouwen)
- [Our decision rule](https://fokuus.be/#onze-beslisregel)

Your webshop scores 100 on accessibility in Lighthouse or PageSpeed. Does that mean you comply with the European Accessibility Act? No. An automatic score does not prove that a site complies with the European Accessibility Act.

Our own homepage also scored 100 in Lighthouse on mobile on 25 September 2026. The tool ran 28 automated checks and all of them passed. It set aside ten other points, because software cannot judge them: whether the tab order is logical, whether your keyboard focus ever gets stuck anywhere. The [W3C](https://www.w3.org/WAI/test-evaluate/)  is clear: no single tool can determine on its own whether a site complies with accessibility standards.

The rules have applied since 28 June 2025, and for most websites in Belgium it comes down to one question: can a consumer buy from you online? Microenterprises get time here until 28 June 2030, but no exemption.

## What the law requires of your website

The European [Directive 2019/882](https://eur-lex.europa.eu/legal-content/NL/TXT/?uri=CELEX:32019L0882)  applies to a range of services provided to consumers after 28 June 2025, including e-commerce services. These are services provided at a distance, through websites or apps and at the individual request of a consumer, "with a view to concluding a consumer contract". Put simply: a consumer can buy something through your site, make a paid booking or take out a subscription.

Belgium transposed the part on banking and e-commerce services with the [Act of 5 November 2023](https://www.ejustice.just.fgov.be/eli/wet/2023/11/05/2023046827/justel) . This adds the rules to the Belgian Code of Economic Law (WER) and has been in force since 28 June 2025.

The core requirement for websites is set out in Annex I of the directive: they are made accessible "by making them perceivable, operable, understandable and robust". Webshops also make identification, security and payment accessible, and provide information on the accessibility of what they sell if their supplier provides it. You also explain, in your terms and conditions or an equivalent document such as an accessibility statement, how your service works and how you apply the rules, including both the possibilities and the limitations. This is set out in the [FPS Economy guidelines for e-commerce services](https://economie.fgov.be/nl/themas/ondernemingen/guidance/toegankelijkheid/toegankelijkheid-guidelines-0) .

The European Accessibility Act and the Belgian law do not mention WCAG 2.2 by name. But those four words are exactly the four principles on which WCAG, the international guideline for web accessibility, is built. As the [W3C](https://www.w3.org/WAI/standards-guidelines/wcag/)  notes, most organisations use WCAG and the European standard EN 301 549 to comply with the European Accessibility Act, and the 2026 version of that standard is based on WCAG 2.2.

## Webshop, showcase site or microenterprise: who is covered

The FPS Economy set out in those guidelines (February 2026 version) what is and is not covered. The test is always the same: can a consumer conclude a contract through your site or app? A webshop that sells to private individuals: yes. A site where only businesses can order, and that actually restricts this: no, but as soon as a consumer can order there, yes. A site with information only: no. Booking a table or appointment online is only excluded if there is no payment obligation whatsoever: nothing paid in advance, and nothing charged or withheld. If you ask for a deposit on a card or a no-show fee, that exception no longer applies under the FPS test.

A showcase site with information and a contact or quote form is not covered, even if you work for private individuals: no contract is concluded online. Whether you actually need a webshop, you can read about in [our webshop decision guide](https://fokuus.be/en/blog/webshop-laten-maken-belgie/) .

If you do have a webshop, more than the payment page counts: according to the FPS, so do all pages a consumer needs in order to decide, such as your product pages and your withdrawal procedure. Purely editorial pages do not.

Then the Belgian derogation. The directive exempts microenterprises providing services (Article 4(5)). Belgian law turns that into a postponement: until 28 June 2030, companies with fewer than ten employees and an annual turnover or balance sheet total of at most 2 million euros fall outside the law (Article 40). Not after that. The King, meaning the government, may still fully or partially exempt microenterprises later (Article VIII.59, § 2 of the Belgian Code of Economic Law (WER)). I found no decree on this as of 25 September 2026.

When the Belgian rules for e-commerce services apply to you. Simplified, not legal advice.

## What happens if you do nothing

In Belgium, the Economic Inspection supervises compliance. Anyone can file a complaint free of charge. As the [FPS guidelines](https://economie.fgov.be/sites/default/files/Files/Entreprises/Guidelines-toegankelijke-e-handelsdiensten.pdf)  explain, the inspection can either issue a warning first or immediately draw up an official report (PV). That report can go to the public prosecutor's office, or result in an out-of-court settlement (transactie) or an administrative fine. The law links an infringement to a fine of 26 to 10,000 euros, increased by the statutory surcharge (opdeciemen), or up to 4 percent of annual turnover if that is more ([Articles XV.101/1 and XV.70 of the Belgian Code of Economic Law (WER)](https://www.ejustice.just.fgov.be/eli/wet/2013/02/28/2013A11134/justel) ). That brings the FPS to an administrative fine of 260 to 100,000 euros, and higher in case of bad faith.

A detail that concerns us as a web agency: a maintenance contract you signed with your web designer before 28 June 2025 does not, according to the FPS, give you extra time.

## Why an overlay plug-in is not a solution

An accessibility overlay is a script you add to your site. It adds a toolbar for larger text, more contrast or read-aloud, or tries to automatically fix problems on the site itself. At [accessiBe](https://accessibe.com/pricing)  the smallest package costs 490 dollars per year or 59 dollars per month, for sites up to 5,000 visits per month (pricing page checked on 25 September 2026).

The European Disability Forum and the professional association IAAP say in their [joint statement](https://www.edf-feph.org/publications/joint-statement-on-accessibility-overlays/)  that overlays do not make a website accessible or compliant with European accessibility legislation, and that they can actually interfere with users' assistive technology. In April 2025, the US Federal Trade Commission finally approved a [settlement](https://www.ftc.gov/news-events/news/press-releases/2025/04/ftc-approves-final-order-requiring-accessibe-pay-1-million)  under which accessiBe pays 1 million dollars and may no longer claim without evidence that its automated products make every website WCAG-compliant.

Our position: we advise against overlays. The problem lies in the code and content of your site, and that is where you fix it.

## Fix what is there, or rebuild

Real fixes start with the basics the FPS itself offers as tips: everything works with the keyboard, text has enough contrast, colour is never the only signal, information in an image (think of a size chart as a photo) gets a text version, forms do not impose a time limit, and there is no graphical CAPTCHA. The first test I recommend costs nothing: try to get from your homepage to the payment step using only your keyboard.

The [webshops we build](https://fokuus.be/en/webshop-laten-maken/) , we put on Shopify. [Shopify](https://www.shopify.com/accessibility)  says it tests its own components, including the checkout, against WCAG 2.2 level AA, and leaves the theme code entirely to the merchant. In the [compliance report for that checkout](https://www.shopify.com/accessibility/vpat-checkout)  (March 2026), it also states that the merchant remains responsible for compliance with the EAA. So the work lies in your theme, your product pages and your own text and images.

We charge individual adjustments at our ad-hoc rate, 80 euros per hour excl. VAT; how many hours it takes depends on what is wrong. If the problem sits in the foundation of an old site, rebuilding can work out cheaper than continuing to patch it. That is a custom price, agreed in advance, with accessibility included in the brief. On our own site, the build even stops if an image in a blog article has no alt attribute.

Even after delivery, the law requires procedures that keep your service compliant with every change. Accessibility is therefore simply [maintenance](https://fokuus.be/en/blog/website-onderhoud-hoeveel-nodig/) , just like updates and backups.

Fixing or rebuilding are the only options that actually solve the problem.

## Our decision rule

- You sell online to consumers and you are not a microenterprise: the rules have applied since 28 June 2025. Have your webshop checked, start with the purchase flow and publish an accessibility statement. 
- You are a microenterprise with a webshop: you have until 28 June 2030. Build accessibility into your next redesign, rather than bolting on a quick fix later. 
- On your site, a consumer cannot buy anything or make a paid booking, or only businesses can order there and you screen that off: these rules do not apply to you. 
- An overlay plug-in: not in any scenario.

This article is not legal advice. If you are unsure whether your site is covered, read the [FPS Economy guidelines](https://economie.fgov.be/nl/themas/ondernemingen/guidance/toegankelijkheid/toegankelijkheid-guidelines-0)  or put your situation to a lawyer. And that 100 on Lighthouse? We are happy to take it into account, but we call it a good start, not proof.

Accessibility Webshop Legislation WCAG

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## Anton Pycarelle

Founder of Fokuus

Anton builds and optimizes websites for Belgian SMEs from Kortrijk. He writes about choices and experiences from real projects.

[More about Fokuus](https://fokuus.be/en/about/)

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