Short answer
If you operate a web shop or service in multiple EU countries, the same technical standard applies in each of those countries: EN 301 549, in practice WCAG 2.1 level AA. What does differ is what happens when someone wants to report an accessibility issue. Each country has transposed the European Accessibility Act into its own national legislation, and in doing so has determined which authority supervises compliance, what form or channel exists for reporting, and in which language this must take place. There is therefore no central European contact point where a complaint arrives and is automatically forwarded to the correct supervisory authority.
For a business operating in multiple countries, this means above all that you cannot assume the Dutch situation applies once a customer, employee or supervisory authority from another country gets in touch. The standard against which compliance is assessed is the same everywhere, but the route through which a report, complaint or investigation proceeds is not.
Why it differs by country
The European Accessibility Act is a directive, not a directly applicable regulation. This means that each Member State had to incorporate its content into its own national law, with its own designated supervisory authority, its own procedure for complaints and its own way of assessing an accessibility statement. One supervisory authority works with an online form, another expects a written report; one responds within a fixed deadline, another has no fixed response time. These differences are not coincidental, but the direct consequence of how directives work in the EU.
What remains the same everywhere
Three things are the same in all Member States. The technical standard is identical: EN 301 549, based on WCAG 2.1 AA, applies everywhere as the benchmark. The rationale behind the obligation is the same: an accessibility statement, a way to report problems, and an improvement plan when something goes wrong. And the exemption for micro-enterprises providing services applies in every country under the same two conditions. What differs, then, is not the standard itself but the framework around it.
What does differ
The supervisory authority is designated differently in each country, and is not always an authority with the same name or remit as in the Netherlands. Some countries have one central supervisory authority for digital accessibility, others distribute this responsibility across multiple authorities by sector. The reporting form varies in format and language: where one uses a simple web form, another requires a letter with specific attachments. The deadlines and escalation procedures also vary; not every country, for example, has the same sequence of first issuing a warning and only then starting a formal process.
In addition, in some countries there is a practice that exists outside the official supervisory authority. In Germany, competitors or consumer organisations can send what is known as an Abmahnung themselves when they identify a breach, even before a supervisory authority becomes involved. This is a different mechanism from official supervision and deserves its own explanation, but it does show how varied the practice can be from one country to another.
What this means if you operate in multiple countries
If your webshop accepts orders from multiple EU countries, or if your service targets customers in multiple countries, it is useful to know that a report from Germany follows a different route than a report from the Netherlands or France. Which supervisory authority is competent in a specific case and which procedure applies depends on the circumstances and the national legislation of the country in question. This is not something this article can determine for your specific situation; for that, the competent supervisory authority in that country or a legal professional is the right contact.
What you can do yourself is prevent this from becoming an issue only when a report arrives. If you know in advance which supervisory authority, which form and which declaration format apply in each country, you can respond faster and with more confidence. That overview per country is exactly what the axessia.eu subscription provides, alongside the mandatory accessibility statement and improvement plan for your own website. In the knowledge base by situation you can first read how the directive has been implemented in your country of establishment and your main sales markets.
First, determine whether this applies to you
Before diving into differences between countries, it is worthwhile to first establish whether the directive applies to your business at all and which pages must then be assessed. You can have this checked for free in a few questions. If you are still uncertain about concepts such as supervisory authority, reporting route or declaration format, the page with answers to the most frequently asked questions provides a first point of reference, and you can use the overview of what the subscription includes per country to see what is further explained.
In summary
The core remains simple: the technical requirement is the same throughout Europe, but the path to a supervisory authority and the form of a report are not. For a business that only sells in the Netherlands, that difference is usually not a problem. For a webshop that operates in multiple Member States, it is something worth knowing in advance rather than discovering when a letter arrives in the mail.