Yes, it does differ. The European Accessibility Act is a directive, not a regulation, and that distinction is exactly what this article is about: a directive sets a goal and a standard, but each Member State implements it into its own national legislation and designates its own supervisory authority. The technical requirement — EN 301 549, in practice WCAG 2.1 at level AA — is the same across the entire EU. What happens next if something is not in order varies by country: the authority that supervises, the way you file a report, and the system of penalties.
For a web shop that only sells in the Netherlands, that difference is mostly theoretical. For a business that serves customers in Germany, Belgium or France through its own site or a marketplace, it is relevant: the question "to whom am I accountable" then has not one answer but several, depending on where the service is offered.
What remains the same everywhere
The substantive standard is not negotiable per country. A checkout step that cannot be operated with the keyboard, or a form without linked labels, is just as much a gap in Germany as it is in the Netherlands. The directive describes the same functional requirements for web shops, apps and business sites with an account environment, and the exemption for micro-enterprises providing services applies with the same two conditions — fewer than ten employees and a turnover of at most two million euros — in every Member State. What an accessibility statement must substantively contain is also largely fixed in the European standard.
What differs is in the layer around it: who receives or checks the statement, which form is used for it, and what happens if someone files a complaint.
Where the differences actually are
Each Member State designates its own supervisory authority for the EAA, and that is not the same type of body everywhere. In one country it lies with a market authority, in another with a telecom supervisor or a separately designated service. The reporting route — where and how you file a complaint or a statement — therefore runs per country through a different office, with its own form and its own response deadlines.
The penalty system is also filled in at national level. The directive requires that penalties be effective, proportionate and dissuasive, but leaves the precise implementation — the type of measure, the amount, the build-up on repeat — to the Member States. Concrete amounts are therefore not fixed at European level but regulated differently per country; for the current state of this, the national legislation or the designated supervisory authority is the right source, not an estimate in advance.
The German Abmahnung as a particular example
Germany, alongside regular government supervision, has an additional mechanism that does not exist in the same way elsewhere in the EU: the Abmahnung, a written warning that need not come from a supervisory authority but can also be sent by competitors or interest groups due to an alleged breach of consumer protection rules, including accessibility requirements. This makes enforcement in the German market less dependent on whether a supervisory authority happens to come by, and more a matter of private parties who can act on their own initiative. For businesses selling to German consumers, that is a practical fact to know, not a reason to panic — and certainly not a substitute for obtaining your own legal advice if such a letter actually arrives.
What this means for a web shop with customers in multiple countries
If you only operate in the Netherlands, the Dutch supervisory authority and notification route are your only point of contact. If you also sell across borders, which country is relevant may depend on where the service is offered — and that is precisely the kind of question where a general explanation is not sufficient and a lawyer or the competent supervisory authority is the right party to ask.
What is genuinely useful across the board: knowing that the standard is the same everywhere means that work on accessibility does not need to be repeated per country. A checkout step that works well with a screen reader meets the same requirement in every EU country. It is mainly the paperwork around it — declaration, notification route, enforcement framework — that takes a different form in each country. Identified per country which supervisory authority, notification route and declaration format apply provides an overview of this, without you having to lay the statutory texts of five countries side by side yourself.
If you do not yet know whether and how the European Accessibility Act applies to your situation, you can find out quickly with the free quick-scan that gives a first indication in a few questions For the country-specific components — the correct declaration format, the deadlines for each obligation and notification as soon as something changes that affects your situation — that is organized in the subscriptions with the country-specific blocks per market in which you operate. And if you run into a question that is not answered here, then an overview of frequently asked questions about supervision and enforcement is ready as your next step.