EAA for Belgian Small Businesses: What Your Website Must Do Since 28 June 2025
Steven | TrustYourWebsite · 4 May 2026 · Last updated: May 2026
Your Brussels webshop, your Antwerp booking system, your Ghent customer portal: if any of them take transactions or handle consumer accounts, they are potentially subject to Belgium's national EAA transposition. The Wet van 19 juli 2022 / Loi du 19 juillet 2022 has applied to private sector services since 28 June 2025, with the Koninklijk Besluit / Arrêté Royal of 21 September 2023 setting the technical detail.
This guide answers the three questions most Belgian SMB owners ask: does it apply to me, what does it mean for my website in practice and where do I start?
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Does it apply to your business?
The microenterprise exemption
The EAA includes an exemption for microenterprises providing services. In Belgian law, you are exempt if your business meets both thresholds simultaneously:
| Criterion | Threshold |
|---|---|
| Headcount | Fewer than 10 full-time equivalents |
| Annual turnover | Under €2 million |
Both must apply. Some examples in a Belgian business context:
| Situation | Exempt? |
|---|---|
| Freelancer, no employees, turnover €70,000 | Yes |
| BV, 4 employees, turnover €900,000 | Yes |
| Webshop, 7 employees, turnover €2.4 million | No (exceeds turnover threshold) |
| Retailer, 14 employees, turnover €800,000 | No (exceeds headcount threshold) |
| VZW/ASBL training provider, 12 employees, turnover €700,000 | No (exceeds headcount threshold) |
Check your status annually based on the previous financial year. The exemption does not protect you from GDPR or Belgian anti-discrimination law, which continue to apply regardless of company size.
VZW/ASBL and non-profit organisations
Belgian non-profits do not receive automatic exemption. The legal form of VZW/ASBL is irrelevant to whether the law applies. What matters is whether the organisation provides digital services to consumers and whether it exceeds both size thresholds. A VZW running an online training platform with 15 staff and €1.5 million in course revenues is fully in scope.
B2B versus B2C
The Wet van 19 juli 2022 targets services provided to consumers. A platform sold exclusively to businesses falls largely outside the law. But a webshop that accepts orders from both businesses and private individuals is subject to EAA requirements for the consumer-facing portion, which in practice means the entire website, since you are not going to build a separate version.
KBO/BCE number and mandatory identification
Before reaching EAA requirements, note that Belgian businesses have an identification obligation that predates the EAA. Under the Wetboek van Economisch Recht / Code de droit économique (WER/CDE), every commercial Belgian website must display the KBO/BCE number, the Belgian company register number (KBO in Dutch, BCE in French), a 10-digit identifier in the format 0123.456.789.
It must appear in the footer and on your legal notices page. For VAT-registered businesses, the VAT number in Belgian format (BE followed by the KBO/BCE number: BE 0123.456.789) must also be visible. The FOD Economie / SPF Économie checks both during any accessibility inspection.
What WCAG 2.1 AA requires in practice
The technical reference standard in Belgium is WCAG 2.1 level AA, applied directly through the harmonised European standard EN 301 549. Unlike France, Belgium has not developed a national accessibility framework. The FOD Economie expects a WCAG 2.1 AA audit, not a national alternative.
In practice, WCAG 2.1 AA requires four groups of changes.
Perceivable
Content must be perceivable regardless of how users access the site.
- All informative images have descriptive alt text. Decorative images use an empty alt attribute (
alt="") - Text and background have at least a 4.5:1 contrast ratio for normal text and 3:1 for large text. Light grey on white nearly always fails
- Videos with spoken content have accurate, manually verified captions
- Information is not conveyed through colour alone
Operable
All functions work without a mouse.
- Every interactive element (menus, buttons, form fields, links) is reachable by Tab key
- Keyboard focus is visible at all times: a visible outline or highlight shows the active element
- No time limits that cannot be extended or turned off
- No flashing content above seizure-safe thresholds
Understandable
Content and behaviour are predictable.
- Page language is declared in the HTML (
<html lang="en">or"fr"or"nl"as appropriate) - Error messages in forms are clear and specific ("Please enter a valid email address" not "Invalid input")
- Navigation is consistent across pages
Compatible with assistive technologies
Code is clean enough to be interpreted correctly by assistive technologies.
- Form fields have programmatically associated labels, not just visible placeholder text
- Buttons are semantic
<button>elements, not styled<div>tags - ARIA roles are used correctly and sparingly
The accessibility statement
The KB/AR of 21 September 2023 requires businesses subject to the EAA to publish an accessibility statement. It must be reachable from every page, typically via a footer link.
Required content:
- Conformance status: fully conformant, partially conformant, or non-conformant with WCAG 2.1 AA
- List of inaccessible content: for each unresolved issue, a description and reason (technical limitation or disproportionate burden)
- Contact channel: an email address or form where users can report accessibility barriers. This must be monitored and responded to
- Recourse procedure: if a user reports an issue and receives no satisfactory response, they need to know how to escalate. In Belgium, the FOD Economie / SPF Économie is the appeal body
- Date of last review
A statement declaring "non-conformant" status is better than no statement at all. It demonstrates awareness of the obligation and active engagement. The FOD Economie assesses effort and transparency, not instant perfection.
The disproportionate burden exception
For specific requirements where the cost of implementation is genuinely disproportionate relative to the benefit for users with disabilities, the law allows a documented exception. This must be:
- Claimed per specific requirement, not as a blanket site-wide exemption
- Supported by a documented cost estimate and assessment of the number of affected users
- Recorded in the accessibility statement
- Reviewed periodically
It is almost never applicable to cheap fixes: adding alt text costs nothing, so the exception cannot be claimed for missing alt text. It is more relevant to reconstructing a complex legacy application from scratch, or captioning an extensive archive of historical videos.
The Brussels bilingual layer
For businesses based in the Brussels-Capital Region, or whose website targets a Brussels audience, a regional language obligation applies on top of the EAA requirements. Under Brussels language legislation covering commercial relations, businesses that address the Brussels public must provide consumer information in both French and Dutch.
For a website this covers:
- Legal notices (name, address, KBO/BCE number, VAT number)
- General terms of sale or service
- Essential product or service information
- The accessibility statement
A Brussels-based tech startup with an English-only website faces three potential compliance gaps at once: EAA, Brussels bilingual obligation for NL+FR content and potentially GDPR. Each is audited separately but can be flagged during the same inspection visit.
Walloon businesses without a Brussels presence do not carry this bilingual requirement, only the EAA accessibility obligations in the language(s) in which they communicate with customers.
A practical four-week plan
If your website currently has no accessibility work done, this is a workable sequence for a typical Belgian SMB webshop.
Week 1: baseline and quick wins
Scan your website with an automated tool or our free scanner. Add your KBO/BCE number to the footer if it is missing. Fix missing alt text on product images via your CMS admin panel. Set the correct page language attribute in your HTML (<html lang="en">).
Week 2: keyboard and navigation
Navigate your entire website without a mouse, using only Tab. Can you reach every button and link? Can you complete a purchase or booking? Check that dropdown menus and modals respond to keyboard input.
Week 3: forms and error handling
Associate labels with every form field. Test error messages: are they specific and helpful? Remove any pre-checked marketing consent boxes.
Week 4: publish the accessibility statement
Publish an accessibility statement even if it declares non-conformant status. Add a contact channel for reports. Document what has been fixed and what is in progress. This is precisely what the FOD Economie / SPF Économie looks for: structured engagement and honest documentation, not instant perfection.
What to do if the FOD Economie contacts you
If you receive a notice from the FOD Economie / SPF Économie:
- Respond within the stated deadline (typically four to eight weeks)
- Acknowledge accurate findings and challenge inaccurate ones with documented evidence
- Submit a concrete remediation plan with a timeline per issue
- Maintain contact and report progress
For a detailed look at the fine structure and enforcement process, see our EAA penalties guide for Belgium.
This article is technical analysis, not legal advice. Consult a specialist in Belgian digital compliance law for advice on your specific situation.
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