The Netherlands - Regulatory

The European Accessibility Act (‘EAA’), as transposed into Dutch law, entered into force on 28 June 2025. As of that date, consumers should be able to rely on accessible and understandable information. The scope of the EAA extends to ‘banking activities’, including the investment services of MiFID II, and to ‘e-commerce services’ being any electronic contract entered into on request of a consumer. The EAA aims to ensure that consumers with a disability, such as a visual or mental disability, have access to services. Therefore, contracts offered to consumers should, among other things, be written in B2-level language, be transmittable in a non-textual format (e.g. an auditive format), and contain information on how the financial entity handles the accessibility of its services.

As the EAA has entered into force, the Dutch authority for the financial market, also known as AFM, has updated the information page on the EAA. The webpage emphasises the four main principles of the EAA:

• Operability: information is easy to operate—not only with a mouse but also with a keyboard, screen reader, or voice commands
• Perceivability: text size, font and contrast ensure readability, and the content is accessible to users who are blind or visually impaired
• Understandability: information is easy to navigate and to achieve goals, such as finding information or placing an order
• Robustness: content can be reliably interpreted by various technologies, such as screen readers and other assistive tools

The Dutch Central Bank (‘DNB’) has published the outcomes of its industry-wide survey on the implementation of DORA. The results show that financial entities have realised over 70% of the implementation of DORA. Most entities expect to need at least the remainder of 2025 to realise full implementation. Even though entities should have been compliant with DORA as of 17 January 2025, entities are still addressing residual IT risks and updating their contractual agreements on IT services.