European Accessibility Act Compliance in Belgium
Belgium transposed the European Accessibility Act through several separate instruments rather than one act. The law of 5 November 2023 covers consumer banking and e-commerce services, the royal decree of 1 October 2023 covers products, and the law of 20 July 2023 covers electronic communications. All three take effect from 28 June 2025. Other parts of the EAA sit elsewhere, with the three Communities for audiovisual media services and with other federal services for the answering of emergency communications, so no single Belgian text gives you the whole picture.
Scan your site freeWho has to comply in Belgium
Under the federal law of 5 November 2023, the covered services are consumer banking services and e-commerce services supplied to consumers in Belgium, wherever the seller is established. Electronic communications services fall under the law of 20 July 2023, supervised by the IBPT/BIPT. Products such as self-service terminals, e-readers and general purpose consumer computer hardware fall under the royal decree of 1 October 2023, which applies to products placed on the market after 28 June 2025. The EU micro-enterprise exemption covers services only, not products: fewer than 10 staff and annual turnover or annual balance sheet total no higher than EUR 2 million. Article 40 of the Belgian law writes this as an exclusion running until 28 June 2030, which reads as time limited, while the directive sets no end date for the services exemption. Public bodies follow a separate regime under the loi du 19 juillet 2018 on the accessibility of public sector websites and mobile applications, which transposes Directive (EU) 2016/2102 and has nothing to do with the EAA.
The deadlines that matter
EU deadline for transposing the EAA. Belgium had adopted no transposing instrument by this date
Law amending the electronic communications act of 13 June 2005 adopted, partial transposition for telecoms (Moniteur belge, 29 September 2023)
Royal decree on accessibility requirements for products adopted (Moniteur belge, 6 November 2023)
Law amending the Code de droit économique adopted, covering consumer banking and e-commerce services (Moniteur belge, 28 November 2023)
The two laws enter into force and the royal decree starts to apply to products placed on the market; EAA obligations bite
End of the transition for service contracts agreed before 28 June 2025, and the date to which article 40 runs the micro-enterprise exclusion
Latest date to which article 40 lets excluded micro-enterprises keep serving customers with products they already used lawfully
Prove your Belgium compliance
Conforma tests your site against WCAG 2.2 AA and EN 301 549, the harmonised standard the Belgian royal decree relies on for presumption of conformity. You get a statement template built from the information points in Annexe 2 to Book VIII of the Code de droit économique, which article VIII.60 requires service providers to make available, plus a dated record of every issue found and fixed. Automated testing covers part of what EN 301 549 asks for and does not by itself make a service compliant, so treat the output as evidence and as a work list for manual review.
Belgium EAA questions, answered
When did the EAA start applying in Belgium, and is there a transition?
The two Belgian laws took effect on 28 June 2025, and the royal decree applies to products placed on the market after that date. Article 39 of the law of 5 November 2023 lets service contracts agreed before 28 June 2025 run to their end for at most five more years, and lets providers keep using products they already used lawfully until 28 June 2030. Self-service terminals already in service may run to the end of their economic life, capped at twenty years from the date they were put into use.
Is my small business exempt?
The EU exemption applies to services only and never to products: fewer than 10 staff and annual turnover or annual balance sheet total of no more than EUR 2 million. Belgium wrote it into article 40 of the law of 5 November 2023 as an exclusion that runs until 28 June 2030, with a further period to 28 June 2035 for continuing to serve customers with products already used lawfully. That reads as time limited, while the directive sets no end date for the services exemption. Take advice before relying on either reading.
Which accessibility standard applies in Belgium?
Belgium works from EN 301 549 and has no national accessibility standard for the private sector, unlike France with the RGAA or Germany with the BITV. Article 12 of the royal decree of 1 October 2023 gives products that meet harmonised standards published in the EU Official Journal a presumption of conformity, and EN 301 549 is the relevant one for ICT. Which WCAG version applies in practice depends on the version of EN 301 549 cited in the Official Journal. AnySurfer is a Belgian private label with no legal status under the EAA.
Who enforces the EAA in Belgium and what are the penalties?
The Inspection économique of the SPF Economie handles e-commerce and consumer banking, the Direction générale de l'Energie handles products, and the IBPT/BIPT handles electronic communications. Anyone may complain free of charge under article XV.18/5 of the Code de droit économique. Articles XV.99/1 and XV.101/1 set a criminal fine at niveau 2, or niveau 3 for bad faith, which article XV.70 puts at EUR 26 to 10,000 and EUR 26 to 25,000. With the statutory surcharge of eight those reach about EUR 80,000 and EUR 200,000.
This page is a plain-English summary, not legal advice. Check the cited national law for specifics.
Common fixes to check
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A free scan against WCAG 2.2 AA, a plain-language fix for every issue, and a Belgium-specific accessibility statement when you need one.