Self-Reporting Is the Future of Accessibility Compliance

Three Months Of The EAA

Since June 28, 2025, the European Accessibility Act (EAA) has moved from slides to sprint boards. Monitoring bodies are in place, and penalties are on the table. But the real question is: Who checks compliance, and how does enforcement actually work?

Compliance starts with owning your accessibility gaps

Early signals point to two complementary forces. For one thing, users and advocacy groups are pushing cases into the open. On the other hand, regulators are leaning into structured self-reporting, asking companies to disclose accessibility gaps and fix them on the clock.

Together, they’re setting a new baseline: accessibility you can prove.

Advocacy groups stepping up in France

Disability and advocacy groups have formally notified several major retailers of inaccessible online shopping experiences. It’s one of the first signs that strategic, plaintiff-led actions will quickly surface non-compliance.

These groups acted as soon as the EAA came into effect, and that timing says a lot: people have waited a long time to be heard. For many, this is about daily independence—buying groceries, managing time, living life.

This also hits the heart of digital commerce. People with disabilities shop online more often than the general population. Inaccessible flows don’t just violate rights, they block real demand.

One 2025 survey found that 50% of disabled consumers shop online weekly, and 6% daily, compared to just 22% of the general population (Fable, 2025).

Once a notice goes public, the impact is immediate. Headlines move faster than fixes. Legal teams scramble. Roadmaps derail. The French cases show that fixing accessibility early avoids this spiral.

You’ll need to meet the requirements anyway—so why not do it ahead of the curve and turn a potential legal or PR issue into a competitive advantage.

The Netherlands’ bold bet on self-reporting

The Dutch have taken a different, rather pragmatic approach. Instead of waiting for complaints to pour in, companies serving Dutch consumers must self-report any WCAG 2.1 AA breaches and explain how they’ll fix them.

Self-reporting builds evidence, reduces risk, and embeds accessibility into your process rather than leaving it to a one-time push.

We believe this is the future: transparent, scalable, and fair. Other countries will follow.

Although the first deadline for self-reporting has just passed in the Netherlands (October 15), late reporting is still encouraged and a far better choice than silence and pasivity.

Who must self-report in the Netherlands?

Short answer: any company serving Dutch consumers with a product that isn’t fully accessible.

It doesn’t matter where your HQ is, the EAA applies to the markets you serve.

If you are a Dutch company and your service was inaccessible on June 28, and you didn’t report by October 15, your legal and financial risk has increased, but late reporting is still the right move.

What should be reported?

If an update introduces an accessibility issue later from October 15 onwards, report it by severity:

Critical or serious

report within 1 week

Moderate or minor

report within 1 month

Note that if it’s detected and fully fixed within that window, you don’t need to report.

Which regulator do you report to?

That depends on your sector:

ACM

e-commerce, platforms, electronic communications

AFM

financial and banking services

CvdM

audiovisual media and e-books

ILT

transport and online bookings

What the report should include

A clear, plain-language audit

List accessibility issues in your website or app. Include screenshots, examples, and user journeys (like search, checkout, or login). Use WCAG 2.2 AA as your working standard. It’s future-proof and improves UX, even if 2.1 AA is the current legal baseline.

Impact and severity

Tag each issue as critical, serious, moderate, or minor. Describe the user impact in a sentence. If possible, estimate how many users are affected—it strengthens your case.

A remediation plan

For every issue, note the owner, fix approach, and target date. Group fixes that can be solved through your design system so they scale across products.

Any exceptions

If you claim disproportionate burden or a fundamental alteration, explain why. Also, share what support you’ll provide in the meantime.

Evidence and updates

Link to tickets and shipped fixes. Update the plan when timelines shift. Keep it centralized and current so you can demonstrate progress when asked.

Penalties & cooperation

Dutch regulators can issue fines up to €900,000, or 1–10% of annual turnover for larger companies. Media fines are typically lower (up to €90,000).

But proactive self-reporting and visible progress reduce exposure and signal control.

Why self-reporting is the future of EAA enforcement

Even outside the Netherlands, this model applies. It provides documentation, reduces risk, and turns accessibility into a repeatable operational habit.

Most importantly, it addresses the scale problem.

No regulator can manually inspect every product, release, or patch. But asking companies to name gaps, commit to fixes, and show progress? That can scale.

The Dutch model rewards honesty and progress. You disclose issues, prioritize by impact, and work on a visible timeline. This directs effort to where it matters most: unblocking logins, checkouts, and support flows, and building system-level improvements across shared components.

Finally, it’s fair and portable. Whether you’re local or global, the rules and expectations are the same. Publish your current status. Maintain a severity-based backlog. Show ownership and updates.

That gives users access they can feel, provides regulators with proof of progress, and offers you a system that holds up over time.

Action points based on your product maturity

If your product is live

1

Run a proper audit

Don’t rely solely on scanners; include manual tests with assistive tech and map findings to WCAG 2.2 AA

2

Prioritize by impact and effort

Mark critical/serious issues for immediate work to meet reporting timelines

3

Self-report with a remediation plan

Self-report to the right authority with your remediation plan

4

Update your Accessibility Statement

Reflect actual status, fixes in progress, and feedback channels

5

Track progress and update

Report newly-found matters on time. and log new issues as they surface

If you’re launching a new product

1

Accessibility in the SDLC

Include it from day one in requirements, designs, components, QA, and content

2

WCAG 2.2 AA as your baseline

Ship the productwith WCAG 2.2 AA as the baseline, aligned with EN 301 549

3

Accessibility Statement

Publish your Accessibility Statement at launch

4

Maintain documentation

Document decisions, exceptions, and test results from the start; you’ll need the receipts later

Need help getting started? We’ve published foundational EAA resources and a practical accessibility handbook.

Start there, then go deeper with an audit and hands-on guidance.

Better late than passive

Self-reporting is the future of EAA enforcement because it scales, creates evidence, and gets fixes where they matter most. It turns accessibility from a scramble into a steady rhythm, with clear owners and trackable dates.

If you lead product, now’s the time to set the cadence. Publish your current status, tackle the top blockers, and update on a schedule. Keep it simple, visible, and repeatable.

If you want support, we can help you start this week. Infinum can run the audit, shape the plan, prep the self-report, and keep it moving.

Let’s make accessibility something you can prove, and be proud of.