Web Accessibility in Belgium: Legal Obligations and Best Practices

Introduction

Web accessibility is a fundamental right and, since 2019 in Belgium, a legal obligation for many organisations. In 2026, with the entry into force of the European Accessibility Act (EAA), which extends obligations to the private sector, web accessibility now concerns every Belgian business.

In Belgium, 15% of the population lives with a disability (according to the FPS Social Security), around 1.7 million people. Add to that older people (25% of the Belgian population is over 60), people with a temporary disability, and users with contextual limitations (bright light, noise, a slow connection). In total, nearly 30% of users directly benefit from an accessible website.

This guide details the Belgian legal framework, the technical standards to meet, verification tools and best practices for making your website compliant and inclusive.

The legal framework for web accessibility in Belgium

European Directive 2016/2102 (public sector)

The European directive on the accessibility of the websites and mobile applications of public sector bodies (Directive 2016/2102) has been transposed into Belgian law. It requires Belgian public bodies to make their websites and mobile applications accessible in line with the EN 301 549 standard, which is based on WCAG 2.1 level AA.

Organisations concerned:

• Federal, regional and community authorities
• Municipalities and public social welfare centres (CPAS)
• Public hospitals and universities
• Intermunicipal companies and public enterprises
• Any body financed mainly by public funds

Obligations:

• Websites published after 23 September 2018: compliant since 23 September 2020
• Websites published before 23 September 2018: compliant since 23 September 2020
• Mobile applications: compliant since 23 June 2021
• Publication of an accessibility statement on each site
• A feedback mechanism allowing users to report problems

The European Accessibility Act (EAA) – Directive 2019/882

The European Accessibility Act (EAA) is the major shift of 2025. Transposed into Belgian law, it extends accessibility obligations to the private sector from 28 June 2025.

Sectors covered by the EAA:

• Banking services: online banking services, banking apps, ATMs
• E-commerce: all online shops and shopping apps
• Telecommunications: telephone services, messaging, internet access
• Transport: passenger transport services (ticketing, traveller information)
• Audiovisual: audiovisual media services (streaming, VOD)
• E-books and e-readers
• Computers, smartphones and tablets (for manufacturers)

Exceptions:

• Microenterprises (fewer than 10 employees AND less than EUR 2 million turnover): exempt from the EAA for services
• The "disproportionate burden" exception: if compliance would represent an excessive cost relative to the benefits, an exemption is possible (to be documented and justified)

Penalties in Belgium:

• The FPS Economy is the supervisory authority for the EAA in Belgium
• Administrative fines of up to EUR 87,000 (under the relevant royal decree)
• Compliance orders with set deadlines
• The possibility of legal action by people with disabilities (Anti-discrimination Act of 10 May 2007)

The complementary Belgian framework

• Anti-discrimination Act of 10 May 2007: prohibits discrimination based on disability, including in access to goods and services (an inaccessible website can constitute discrimination)
• UN Convention on the Rights of Persons with Disabilities (ratified by Belgium): Article 9 on accessibility, Article 21 on access to information
• Regional decrees: the regions have their own additional provisions

The technical standards: WCAG 2.1 and 2.2

What are the WCAG?

The Web Content Accessibility Guidelines (WCAG) are the international web accessibility standards published by the W3C (World Wide Web Consortium). They are organised around four core principles (POUR):

1. Perceivable: information must be presentable in a way that all users can perceive.

• Text alternatives for images
• Subtitles for videos
• Adaptable content (reflow, orientation)
• Sufficient contrast between text and background

2. Operable: interface components must be usable by everyone.

• Keyboard navigation must be possible
• Enough time to read and interact
• No content that triggers seizures (flashing)
• Easier navigation and orientation

3. Understandable: information and the interface must be understandable.

• Readable, understandable text
• Predictable page behaviour
• Input assistance (forms with clear error messages)

4. Robust: content must be robust enough to be interpreted by a wide range of user agents.

• Compatibility with assistive technologies
• Valid, semantic HTML
• Component states and properties correctly communicated

Conformance levels

The most important WCAG 2.1 AA criteria

Here are the criteria most frequently breached by Belgian websites:

WCAG 2.2: what's new (2023)

WCAG 2.2, published in October 2023, adds 9 new criteria, including:

• 2.4.11 Focus Not Obscured (Minimum): keyboard focus must not be completely hidden by other elements
• 2.4.13 Focus Appearance: the focus indicator must be sufficiently visible (level AAA)
• 2.5.7 Dragging Movements: alternatives to drag gestures (swipe)
• 2.5.8 Target Size (Minimum): clickable targets must be at least 24x24 CSS pixels (level AA)
• 3.3.7 Redundant Entry: do not ask for the same information more than once
• 3.3.8 Accessible Authentication: authentication mechanisms must not rely on cognitive tests

How to make your website accessible: a practical guide

Phase 1: Accessibility audit (1-2 weeks)

Step 1: Automated audit

Automated tools detect around 30-40% of accessibility issues:

Step 2: Manual audit

Automated auditing is not enough. A manual audit is essential:

• Keyboard navigation: browse the whole site using only the keyboard (Tab, Shift+Tab, Enter, Escape, arrow keys). Check that the focus is visible, the order is logical, and every function is reachable.
• Screen reader: test with VoiceOver (macOS/iOS), NVDA (Windows, free) or JAWS (Windows, paid). Check that the content is announced correctly.
• Zoom: enlarge the page to 200% and check that the content stays readable and functional.
• Contrast: check contrast ratios with the Color Contrast Analyser (CCA, free).

Step 3: Testing with users

If possible, have your site tested by people with disabilities. In Belgium, several associations can help:

• AnySurfer (Brussels-based, the Belgian reference in web accessibility)
• Eqla (formerly the National Work for the Blind)
• Brailleliga (the Braille League)
• Blindenzorg Licht en Liefde (Flanders)

Phase 2: Priority fixes (2-6 weeks)

Quick wins:

1. Add alternative text to images: <img src="photo.jpg" alt="Description of the image">
2. Fix the heading hierarchy: use h1 > h2 > h3 in order, without skipping levels
3. Improve contrast: ensure a minimum ratio of 4.5:1 for text
4. Add the page's language: <html lang="fr"> (or "nl" for Dutch, "de" for German)
5. Make forms accessible: associate every field with a label, and provide clear error messages
6. Add a skip link: "Skip to main content" at the top of the page
7. Make links explicit: replace "click here" with "Read our privacy policy"

Structural fixes:

8. Keyboard navigation: ensure every interactive element is focusable and can be activated by keyboard
9. Visible focus indicator: never remove outline: none without a visible alternative
10. ARIA landmarks: use ARIA roles and semantic HTML5 elements (nav, main, header, footer, aside)
11. Video captions: add captions and a transcript to every video
12. Responsive and reflow: content must be accessible at a width of 320px (reflow, no horizontal scrolling)

Phase 3: Building it into your development process (ongoing)

Accessibility should not be a one-off project but a core part of your process:

• Accessible design system: build accessibility rules into your brand guidelines and components
• Automated tests in CI/CD: integrate axe-core or Pa11y into your deployment pipelines
• Team training: train designers, developers and content writers on accessibility
• Accessibility review: include an accessibility check in every code review
• Continuous monitoring: use tools such as SiteImprove or Monsido to track your score over time

Belgian specifics: multilingualism and accessibility

As Belgium is trilingual, web accessibility must account for language specifics:

• The lang attribute: every page needs the correct lang attribute (fr, nl, de). If a section is in another language, use lang on the containing element.
• Accessible language navigation: the language switcher must be accessible by keyboard and to screen readers.
• Equivalent content: if your site is available in several languages, the level of accessibility must be identical across all versions.

The accessibility statement

Legal obligation

Public-sector websites and, since the EAA, many private companies must publish an accessibility statement:

Required content:

• The date of the statement and the date of the last audit
• The declared level of compliance (full, partial, non-compliant)
• A list of inaccessible content, with justification
• Alternatives offered
• Contact details for feedback
• The complaints procedure

Template: the Belgian oversight body provides a template accessibility statement. For the public sector, the template is available on the BOSA website (FPS Policy and Support).

AnySurfer: the Belgian accessibility label

AnySurfer is the leading Belgian initiative on web accessibility. It offers:

• The AnySurfer label: an accessibility certification for websites and apps, based on WCAG 2.1 AA
• Accessibility audits: carried out by certified experts
• Training: for designers, developers and content writers
• Advice: support to help you reach compliance

Cost of an AnySurfer label:

• Initial audit: EUR 1,500 – 5,000 depending on the size of the site
• The label is valid for 3 years (with a mid-term re-audit)
• Contact: info@anysurfer.be / anysurfer.be

Budget for compliance

Estimate by type of site

Note: it is always cheaper to build in web accessibility from the design stage than to fix an existing site afterwards. The extra cost of designing an accessible site from the start is estimated at only 10-15% of the total budget.

Belgian providers specialised in accessibility

• AnySurfer (Brussels): audits, label, training
• Eleven Ways (Ghent): audits and accessible development
• Wieni (Mechelen): a web agency specialised in accessibility
• Emakina (Brussels): a digital agency with accessibility expertise
• Espero-Soft: accessible web development for Belgian businesses

The ROI of web accessibility

Web accessibility is not just a legal obligation, it is also a profitable investment:

• Improved SEO: accessibility best practices (alt text, heading hierarchy, semantic HTML) improve organic search rankings
• A wider audience: reach an additional 15-30% of users
• A better user experience: an accessible site is a better-designed site for everyone
• Reduced legal risk: avoid fines (up to EUR 87,000) and legal action
• Brand image: inclusivity is a differentiator and a reputational asset
• Better performance: clean, semantic code is often faster

Conclusion

Web accessibility is a growing legal obligation in Belgium, extended to the private sector since the EAA in 2025. But beyond compliance, it is an investment in the quality, inclusiveness and performance of your online presence.

Start with an audit of your existing site, fix the most critical issues (alternative text, contrast, keyboard navigation), then build accessibility into your design and development process. Free tools such as WAVE and axe DevTools let you get started right away.

Belgium has a mature web accessibility ecosystem, with AnySurfer, available training and regional grants to help fund your compliance work. Do not wait for a complaint or an audit to act: make your site accessible today.

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This article was written by the Espero-Soft team for the blog dedicated to entrepreneurs in Belgium. For an accessibility audit or accessible website development, contact our experts.