A customer complains that my webshop is not accessible — what should I do?

A complaint is usually the starting point of a file, not a fine

A customer complaining that a webshop is not accessible means in practice that there is now a concrete signal on which a business operator can act, and that is different from a sanction or an ongoing procedure. The complaint itself establishes nothing; what matters is what is done with it. Recording what the customer precisely reports (which page, which step, which problem — a button that cannot be operated with the keyboard, a form without a label, text that a screen reader skips) is the first useful step, followed by a check whether that complaint stands alone or points to a broader pattern in the site.

From that point on, the complaint in most cases runs in two directions: internal assessment of whether the problem can be remedied, and external assessment of whether the customer escalates the complaint to a supervisory authority. The ACM calls on businesses to prepare for this and supervises the accessibility of websites and apps in the Netherlands; a complaint that reaches the ACM can be grounds for investigation, but what that investigation specifically yields cannot be said in advance. Whether the webshop is actually subject to the law — some micro-enterprises are exempt — is a question that can be answered separately via the test of whether the accessibility law applies to the webshop, separate from how the complaint itself is handled. If no action has been taken for some time, it is also relevant whether an accessibility statement already exists, because a complaint without any documented improvement plan carries different weight than a complaint that arrives while demonstrable work is already underway.

Legal basis: the directive sets the requirement, the ACM supervises

The substantive standard against which a complaint is assessed follows from Directive (EU) 2019/882, which in practice applies EN 301 549 / WCAG 2.1 AA as the benchmark; who supervises and handles complaints in the Netherlands is described on the ACM's page on supervision of the accessibility of websites and apps.