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European Accessibility Act in Belgium: Compliance, Complaints & Penalties

The European Accessibility Act (EAA) came into effect on June 28th, 2025. In Belgium, accessibility compliance is regulated by multiple government agencies, depending on the product or service type and the region. There’s no single official overview, which makes it challenging for companies to know which rules apply. This guide brings the information together, outlining obligations, complaint procedures, and enforcement measures for each type of product or service.

Wout Thielemans & Gijs Veyfeyken

Accessibility Specialist & Lead Accessibility Specialist

August 20, 2025
•
8 min read

Disclaimer: we are not lawyers. Please speak to your legal team about the EAA’s impact on your business.

Scope

The EAA applies if your service is aimed at consumers in an EU member state and falls under one of the following categories:

  • Telephony services

  • Services that provide access to audiovisual media

  • Certain elements of air, bus, rail, and water transport — such as websites, mobile apps, electronic tickets, and passenger information

  • Consumer banking services

  • E-books

  • E-commerce

Note: E-commerce is much broader than just a typical webshop. Any website or app that targets consumers with the intention to enter into a consumer contract falls within the scope — regardless of how that transaction takes place.

The EAA does not apply to your service:

  • If you operate in a business-to-business (B2B) context

  • If you are a micro-enterprise: fewer than 10 employees and an annual turnover or balance sheet total below €2 million

Important: micro-enterprises offering e-commerce are not exempt under current Belgian legislation. Instead, they benefit from a transitional period until 2030.

Compliance with the European standard

Companies within scope must:

  • make their products and services accessible;

  • publish information about their accessibility;

  • and demonstrate how they monitor and improve accessibility over time.

The Belgian government(s) will not actively monitor and audit companies on accessibility. Some providers, such as e-commerce platforms and consumer banks, must notify the relevant government authority themselves if they do not comply with accessibility requirements.

Products and services that comply with the European standard EN 301 549: Accessibility requirements for ICT products and services are presumed to meet the legal obligations. This standard incorporates, but is not limited to, the Web Content Accessibility Guidelines (WCAG).

All providers must publish an accessibility statement indicating the extent to which they meet these requirements.

Exceptions

  • There is a transition period for existing physical products until 28 June 2030. This does not apply to services, despite many online sources suggesting otherwise.

  • In Belgium, micro-enterprises offering e-commerce also have until 2030 to comply. In other EU member states, micro-enterprises are generally out of scope.

  • If content was published before 28 June 2025 or comes from a third party outside your control, it may be out of scope — this includes pre-recorded media, office files, archives, and online maps.

  • If making a service accessible imposes an excessive cost or effort, this may be considered a disproportionate burden — but it must be properly assessed and justified.

  • If making your product or service accessible would change its core nature or functionality, you may be exempt under the principle of fundamental alteration.

User complaints

People that experience accessibility problems can file a complaint directly with a company, or via a government authority. This can also be done by organisations acting on their behalf. The government must investigate every complaint and respond within 30 days. The exact process depends on the responsible government authority.

For example, complaints regarding e-commerce can be submitted through the UserConnect website of FPS Economy.

Penalties

If the authority finds the complaint admissible, it will contact the product or service provider directly. For example, an e-commerce provider may receive a warning with a deadline to fix the issue, or the authority may draw up an official report. This can result in an administrative fine of up to €200,000 or 6% of the provider’s annual turnover (whichever is higher), or the case may be forwarded to the public prosecutor’s office.

Sanctions not only vary between different types of products and services, but also between member states. In Hungary, non-compliance can lead to fines of up to €1,265,000. In Ireland even a prison sentence of up to 18 months is possible.

Responsible government authorities

Belgium doesn’t have one single authority for regulating accessibility laws. Responsibilities are scattered amongst the official Regions, language Communities, and Federal level.

The following list includes the responsible authorities, regulations, and complaint procedures that we could find and confirm, grouped by type of product or service.

Physical products and telephony services

All products and electronic communication services are monitored on a Federal level:

Audiovisual media services

Audiovisual media is monitored by the three Communities and the Brussels Capital Region.

Flemish Community

French Community

German-speaking Community

Brussels Capital Region

Transportation tickets

Concerns ticket terminals and services for airplane, bus, train, and water transport. Non-regional transport, like NMBS-trains and air travel, is monitored on a Federal level. Regional and (sub)urban transport, like busses and trams, are monitored by the Flemish Community and Walloon and Brussels Capital Regions.

Federal (non-regional transport)

Flemish Community (sub-urban, urban, and regional transport)

Walloon Region

Brussels Capital Region

E-commerce and consumer banking

“E-commerce services” includes every service via a website or application with the goal of concluding a consumer agreement. Monitored on a Federal level.

E-books and associated software

Accessibility requirements for e-books only apply for books published after June 28th, 2025. Monitored by the three Communities.

Flemish Community

French Community

German-speaking Community

“112” emergency communication

Contacting emergency services needs to be accessible to all. Apart from voice-communication, “112” has to be reachable through electronic messages, too. Monitored on a Federal level.

Need help?

To comply with the European Accessibility Act, companies should start by reviewing their current products and services for accessibility gaps. Establish clear processes to monitor and report on accessibility, and be prepared to handle complaints promptly.

Beyond legal compliance, investing in accessibility opens your products and services to a wider audience, and demonstrates social responsibility. Companies that prioritise accessibility not only meet regulatory demands, but also build lasting customer loyalty and a stronger brand reputation.

Wherever you are in your digital accessibility journey, our Inclusion team can help. Contact us for guidance on compliance, accessibility audits, or tailored support for your teams.

By Wout Thielemans

Wout is an accessibility specialist with ten years of experience in front-end development, focused on making our digital society inclusive for everyone.

By Gijs Veyfeyken

Gijs is a certified accessibility specialist helping organizations improve their services for all people, including those with disabilities. Making it work. For everybody.