Digital accessibility in Belgium: which law applies and who monitors your website

Digital accessibility in Belgium does not rest on a single law: the federal State, the Regions and the Communities have each transposed the European directive for their own public bodies, and each has appointed its own monitoring body. Since 28 June 2025, the European Accessibility Act has added obligations for part of the private sector, once again through several texts. This guide explains, entity by entity, which text applies to your websites and apps, who monitors them, what your accessibility statement must contain and where to start, whether your organisation is a Belgian administration, a company or an institution based in Brussels.

Digital accessibility in Belgium: one obligation, several legislators

Directive (EU) 2016/2102 of 26 October 2016 requires public sector bodies to make their websites and mobile applications accessible to people with disabilities. In a federal State such as Belgium, each level of government has transposed it for the bodies that fall within its own powers: the federal State for its federal public services, the Walloon Region for its municipalities and inter-municipal bodies, Flanders for its administration and local authorities, and so on. The FPS Policy and Support (BOSA) keeps the official list of these texts and of the monitoring bodies on the missions and complaints page of the Belgian Web Accessibility Office (available in French, Dutch and German).

For a public body, the first question is therefore institutional rather than technical: which entity do you belong to? What decides is neither the language of your website nor the address of your head office, but the authority on which you depend. A Brussels municipality falls under the Brussels ordinance, a federal public service located in Namur falls under the federal law, and an institution of the Wallonia-Brussels Federation based in Brussels falls under the decree of the French Community.

The good news is that all of these rules transpose the same directive. The substantive requirements are identical from one entity to the next: the same four principles (perceivable, operable, understandable, robust), the same technical reference standard, the same European model accessibility statement and the same deadlines. What changes is the body that monitors you, the route a complaint follows and the ombudsman who can be approached.

For the many organisations that have an office in Brussels without being a Belgian administration, the same reasoning applies in reverse. The public-sector texts below only matter if your organisation depends on a Belgian authority; the question for everyone else is whether you offer consumers one of the products or services covered by the European Accessibility Act, which is dealt with later in this article.

• Your monitoring body depends on the entity you belong to, not on your web agency or your hosting provider;
• a single supplier may manage websites that fall under three different entities, with three different monitoring contacts;
• hybrid organisations (a non-profit association funded by several authorities, an inter-municipal body, a para-regional agency) need to check which entity they belong to before drafting their statement;
• the private sector is not covered by these texts, but since 28 June 2025 it has been covered by the laws that transpose the European Accessibility Act for certain products and services.

The law of 19 July 2018: the federal foundation of web accessibility

At federal level, the directive was transposed by the law of 19 July 2018 on the accessibility of the websites and mobile applications of public sector bodies. Despite its general title, it only covers federal bodies: federal public services (FPS), federal public planning services (PPS) and other public bodies that depend on the federal State. Municipalities, provinces and regional or community administrations fall under their own texts.

The law follows the timetable of the directive. Websites published after 23 September 2018 had to be accessible from 23 September 2019, older websites from 23 September 2020, and mobile apps from 23 June 2021. All of these deadlines have passed: a federal website that is not accessible today is not “running late”, it is in breach.

Two Royal Decrees complete the law. The Royal Decree of 5 September 2019 designates the monitoring body, the FPS BOSA, and organises the monitoring method laid down by the directive. A Royal Decree of 3 September 2019 governs the complaints procedure. In practice, a user who cannot complete a federal online form with a screen reader first contacts the person responsible for the website, then the administration through the belgium.be complaints portal, and finally the Federal Ombudsman if there is no answer or the answer is unsatisfactory.

What the law requires in practice

• Design, develop, maintain and update websites and apps so that they are perceivable, operable, understandable and robust;
• comply with the harmonised European standard, currently EN 301 549, conformity with which creates a presumption of compliance;
• publish a detailed accessibility statement for each website and each app;
• provide a mechanism that allows anyone to report an accessibility problem or to request information in an accessible form;
• justify, in a documented way, any exemption based on a disproportionate burden, weighing the cost for the organisation against the benefit for people with disabilities.

Excluded content, and its limits

The Belgian texts repeat the exclusions in the directive, which can be found for example in Article 3 of the Walloon decree: office file formats published before 23 September 2018, unless they are needed for active administrative processes; pre-recorded time-based media published before 23 September 2020, and live time-based media; certain maps and mapping services; reproductions of items in heritage collections; archives that have not been updated after 23 September 2019; and third-party content that the body neither funds, develops nor controls. Extranets and intranets published before 23 September 2019 are also excluded until they undergo a substantial revision.

These exclusions are narrower than many people assume. A PDF application form for a grant, published in 2017 but still used to submit a file, is not excluded, because it serves an active process. Likewise, an appointment booking module supplied by a software vendor, but selected, paid for and configured by the administration, is not “third-party content”: the body funds it and controls it.

Digital accessibility in Wallonia and the Wallonia-Brussels Federation

Walloon Region: the decrees of 2 May 2019

The Walloon Region transposed the directive through the decree of 2 May 2019 on the accessibility of the websites and mobile applications of public sector bodies (French text), published in the Belgian Official Gazette (Moniteur belge) on 5 September 2019, with effect from 23 September 2018. A second decree adopted on the same day covers, in particular, public social welfare centres (CPAS) and the associations they form. Together, they cover the Region, the provinces, the municipalities, autonomous municipal companies, inter-municipal bodies, project associations, public housing companies and the legal persons governed by public law that depend on the Region.

The Walloon decree contains two useful details. Article 6 requires every body to respond to reports and requests for accessible information within thirty days of receiving them. Article 7 requires the accessibility statement, drawn up according to the European model, to be updated every year. The monitoring body must present an annual report to the Government on the results of the checks it carries out (Article 10). According to the list kept by the FPS BOSA, this monitoring is carried out by the Agence du Numérique, the Walloon digital agency.

For a municipality, this has very concrete consequences: the application form for a parking permit, the PDF of a local tax regulation, the video of a municipal council meeting and the app for reporting fly-tipping are all in scope. An “accessibility” contact address that does not reply within thirty days already amounts to a breach of the decree.

Wallonia-Brussels Federation: the decree of 3 May 2019 and monitoring by ETNIC

The French Community adopted the decree of 3 May 2019 on the accessibility of the websites and mobile applications of public bodies. Its implementation was organised later by the order of the Government of the French Community of 14 July 2022 (French text), published in the Belgian Official Gazette on 3 August 2022. This order designates ETNIC, the French Community’s public enterprise for digital technologies, as the monitoring body, and requires it to apply the monitoring methodology set out in Implementing Decision (EU) 2018/1524.

The order also provides for accessibility training for staff, covering design and user experience, development, content production and project management. The complaints procedure has two stages: the user first contacts the manager of the website or app; if no satisfactory answer is received within thirty days, they may refer the matter to the Ombudsman service shared by the French Community and the Walloon Region.

Digital accessibility in Brussels: the Region, the COCOF and the COCOM

The Brussels-Capital Region was the first federated entity to legislate, with the ordinance of 4 October 2018 on the accessibility of the websites and mobile applications of regional public bodies and municipalities. It covers regional administrations and public bodies as well as the nineteen municipalities. The official list kept by the FPS BOSA names equal.brussels as the monitoring body for the Region. The accessibility statements of regional bodies refer users to the Brussels Ombudsman for redress.

The Brussels picture becomes more complex with the community commissions. The French Community Commission (COCOF) adopted its own decree of 9 May 2019 on the accessibility of the websites and mobile applications of the COCOF’s public institutions. A draft decree tabled in September 2022 in the French-speaking Brussels Parliament aimed to supplement it with the monitoring required by Article 8 of the directive: designation of the monitoring body by the College, and an annual report by that body. To date, the FPS BOSA list does not mention any monitoring body specific to the COCOF.

For the Joint Community Commission (COCOM), which is responsible in particular for bicommunity institutions in the fields of personal assistance and health, the official list does not cite any specific transposing text. If your organisation falls under the COCOM, we recommend checking with your supervisory administration which text and which monitoring arrangements apply, and in the meantime building your approach on the EN 301 549 standard and the European model statement, which are common to all entities.

A final point specific to Brussels: Community institutions based in the capital follow their own Community. A public body of the Wallonia-Brussels Federation located in Ixelles falls under the decree of 3 May 2019; a Flemish institution located in Brussels in principle falls under the Flemish decree. For a reader working in the European quarter, this means that two neighbouring public buildings on the same street may answer to two different monitoring bodies.

Digital accessibility in Flanders and the German-speaking Community

Flanders: the Governance Decree of 7 December 2018

Flanders incorporated the rules of the directive into its Governance Decree (Bestuursdecreet) of 7 December 2018, in a section devoted to the accessibility of websites and mobile applications. The text covers the Flemish administration, the provinces, cities and municipalities, as well as organisations closely linked to the public authorities: those funded for more than half by a Flemish authority, or whose management is controlled by one. Non-profit associations are only covered if they provide essential services, such as social assistance, care or education, or services intended for people with disabilities. For schools, only essential online administrative functions are concerned: home page, navigation, contact details, curriculum, school rules and enrolment information.

Monitoring has been entrusted to Inter, the Toegankelijk Vlaanderen agency, which since 2025 has acted as the support and monitoring body for digital accessibility in Flanders (OCODT). According to its official presentation page (in Dutch), Inter audits more than 200 websites and apps every year, with advice from NOOZO, the Flemish advisory council of people with disabilities, and has in-depth checks of a smaller number of websites carried out by external experts. It reports every year to the FPS BOSA, which coordinates Belgium’s report to the European Union. Inter states that it has no monitoring role under the European Accessibility Act.

German-speaking Community: a broader decree

The German-speaking Community chose to incorporate the directive into a broader text: the decree of 15 October 2018 on electronic communication, public or addressed to individuals, by the authorities of the German-language region. Article 24 entrusts the monitoring of websites and apps to the Government, and the FPS BOSA list names the Ministry of the German-speaking Community as the monitoring body. Article 23 requires authorities to respond to notifications “appropriately and within a reasonable time”, without setting a number of days as the Walloon decree does; Article 27 extends the remit of the Ombudsman of the German-speaking Community (Ombudsdienst der DG) to complaints about those responses and about the assessment of a disproportionate burden. For the nine German-speaking municipalities and the bodies of the Community, the substantive obligation is the same as elsewhere, with a specific challenge: producing accessible content in German, whereas many of the tools and templates available in Belgium exist first in French and Dutch.

Summary table: entity, text, bodies covered, monitoring

The table below sets out, for each entity, the text transposing Directive (EU) 2016/2102 and the monitoring body, as they appear in the official list kept by the FPS BOSA and in the texts themselves. It concerns the public sector only; the European Accessibility Act is covered by a separate table further down.

For an overview of Belgian obligations and of our services on the ground, see our page on digital accessibility in Belgium. If your organisation falls under several entities, for example an inter-municipal body with some services funded by the Region and others by the Community, document your analysis of which entity you belong to in the statement itself: it is the first question a monitoring body will ask.

EN 301 549 and WCAG: the web accessibility standard applied in Belgium

Belgium has not created a national framework comparable to the French RGAA or the Luxembourg RAWeb. All entities rely directly on the European standard EN 301 549. In its FAQ on the accessibility statement (in French), the FPS BOSA states that the criteria to be met correspond to version 3.2.1 (2021) of this standard. For web content, this version incorporates the WCAG 2.1 success criteria at levels A and AA, that is 50 criteria grouped under the four principles; the Flemish pages for their part point out that WCAG 2.1 level AA is the legal minimum for public websites.

EN 301 549 goes beyond the web. It contains requirements for non-web documents, such as PDFs and office files, for software and mobile apps, and for the hardware features of equipment. That is what makes it relevant both to the public sector and to companies subject to the European Accessibility Act. The chapters of the standard, and how they relate to WCAG, are explained in our article on digital accessibility standards.

Version 4.1.1 and the move to WCAG 2.2

A new version, EN 301 549 V4.1.1, was published by the European standardisation organisations in early September 2026. It aligns the web, document and software requirements with WCAG 2.2 level AA. Until it is cited in the Official Journal of the European Union, version 3.2.1 remains the basis for the presumption of conformity. In practical terms, an audit carried out today against WCAG 2.1 AA is still the reference, but it is wise to add the criteria introduced by WCAG 2.2 straight away: minimum target size for touch controls, keyboard focus that must not be hidden by a sticky banner, an alternative to dragging movements, consistent help, no unnecessary re-entry of information, and authentication without a cognitive function test.

That last point illustrates what is at stake. A captcha that asks users to copy distorted characters, on the login page of an online government counter, already blocks many people under WCAG 2.1. Under WCAG 2.2, the accessible authentication requirement makes this pattern even harder to defend: it is better to plan, from the next redesign onwards, for login via electronic identity, via a sign-in link sent by email, or in a way that works with password managers.

Is a French RGAA audit valid in Belgium?

RGAA is also based on WCAG, and a well-conducted RGAA audit covers a large share of the web requirements of EN 301 549. But the Belgian legal reference remains the European standard: your statement must express a level of conformity with EN 301 549, not an RGAA compliance rate. For an organisation present in both France and Belgium, the most cost-effective solution is often to have the same sample of pages audited once, with the results reported against both frameworks.

The accessibility statement in Belgium: content, placement and pitfalls

All entities require an accessibility statement drawn up according to the model set out in Implementing Decision (EU) 2018/1523. The FPS BOSA specifies the expected content and offers an online wizard that guides drafting step by step and produces an HTML file. Our article on the accessibility statement explains the European logic in detail; here is what is expected in Belgium.

• The scope: the website or app concerned, including all platforms in the case of an app;
• the level of conformity with EN 301 549 version 3.2.1;
• the evaluation method: a simplified audit carried out by the monitoring body, or an in-depth audit;
• a link to a formal audit report;
• the list of non-compliant pages or sections, what is being done to fix them, the planned deadline and the alternative offered in the meantime;
• the date on which the statement was drawn up and the date of its last update;
• the contact details of the person responsible for accessibility, to whom problems can be reported;
• the enforcement procedure and the competent body, depending on the entity to which the organisation belongs.

Where to publish it

The FPS BOSA recommends publishing the statement as a web page rather than as a downloadable document, and placing the link in a logical location, typically in the footer. For a mobile app, the statement must be available within the app, on the associated website if there is one, and on the download platforms. An organisation that offers a website and an app must therefore publish two separate statements. In Wallonia, the decree also requires an annual update.

The most common mistakes

• A statement published as an untagged PDF, which is itself inaccessible;
• a claim of full compliance without an audit to support it, or a reference to an audit several years old that predates the website’s redesign;
• a single statement for both a website and an app, when two are expected;
• a generic contact address that never replies, or a contact form that is itself protected by a visual captcha;
• a single language version, when the website exists in French, Dutch and German, and often in English as well;
• the wrong redress body, for example the Federal Ombudsman cited on the website of a Walloon municipality.

Monitoring, complaints and reporting to the European Commission

Belgian monitoring is based on the European methodology laid down by Implementing Decision (EU) 2018/1524, which distinguishes two levels. A simplified audit covers a limited number of criteria and only part of each website; it is used to measure the overall state of the estate. An in-depth audit examines a larger sample in detail and gives a precise picture of what needs to be fixed.

At federal level, the figures are public. According to the FPS BOSA’s publication of the 2025 monitoring results (in French), 259 websites of federal public services underwent a simplified audit and nine an in-depth audit, and 246 websites declare themselves partially compliant, close to 95% of the total. For 2026, the list of websites to be audited in 2026, published in December 2025, announces 275 simplified audits and 12 in-depth audits, selected to cover the different areas of federal responsibility, websites intended for people with disabilities and the most visited websites. In Flanders, Inter audits more than 200 websites and apps every year.

One detail changes the picture for website owners: the FPS BOSA’s simplified audit reports are published online and linked from the accessibility statements. A defect on your contact form or your home page is therefore not only reported to your team; it can be read by any citizen, journalist or advocacy organisation.

How a complaint proceeds

1. Contact the person responsible for the website. Their contact details must appear in the accessibility statement. Most requests are resolved at this stage, for example by sending a document in an accessible format.
2. Contact the administration concerned. At federal level, through the belgium.be complaints portal; elsewhere, through the complaints service of the body concerned.
3. Refer the matter to the competent ombudsman. The Federal Ombudsman, the Ombudsman of Wallonia and the Wallonia-Brussels Federation, the Brussels Ombudsman or the Ombudsman of the German-speaking Community, depending on the entity.
4. Report a missing statement. If a non-federal public website has no statement, the FPS BOSA accessibility team forwards the report to the competent monitoring body.

Belgium’s reports to the European Union

The directive requires each Member State to submit a monitoring report to the Commission, first on 23 December 2021 and then every three years. Belgium submits a single report, coordinated by the FPS BOSA on the basis of contributions from the monitoring bodies of each entity, which meet in an interfederal steering group. The Commission publishes these national reports on its page of Web Accessibility Directive monitoring reports, where the Belgian report is available in French and Dutch, together with a machine-translated English version; the next series was due in December 2024.

The texts reviewed for this article mainly organise monitoring, publication of results and means of redress, rather than a system of fines comparable to that of the European Accessibility Act. For a public body, the main risk is therefore reputational and legal: an unfavourable public audit, repeated complaints, intervention by the ombudsman, and the difficulty of justifying inaccessible services to users who have no alternative.

The EAA in Belgium: a transposition spread across several texts

Directive (EU) 2019/882 of 17 April 2019, known as the European Accessibility Act, sets accessibility requirements for a range of products and services intended for consumers, applicable since 28 June 2025. As with the public sector, Belgium has transposed it in several pieces, with each authority acting within its own field of competence. Our reference article on the European Accessibility Act sets out the full scope of the directive; here is how it has been implemented in Belgian law.

The law of 5 November 2023: banking and e-commerce

The central text for businesses is the law of 5 November 2023 amending several books of the Code of Economic Law and the law of 2 August 2002 on the supervision of the financial sector, as regards certain services. It inserts into Book VIII of the Code of Economic Law a new Title 5, devoted to accessibility requirements for services, which covers two categories of services provided to consumers: consumer banking services and e-commerce services. According to the text adopted in committee in the Chamber of Representatives (French and Dutch), the law entered into force on 28 June 2025.

Service providers must design and provide services that meet the requirements of Annex 1 to Book VIII, including where they subcontract all or part of the service: using an e-commerce platform or a payment service provider does not relieve them of this duty. They must prepare the information provided for in Annex 2, make it available to the public in writing and orally, and keep it for as long as the service is offered. For banking services, information must not exceed level B2 of the Common European Framework of Reference for Languages. Where a service does not comply, the provider must immediately inform the inspectors, describing the non-compliance and the corrective measures taken.

Enforcement is entrusted to the Directorate-General for Economic Inspection of the FPS Economy. The FSMA is given no monitoring role: the law merely amends Article 75 of the law of 2 August 2002 so that the FSMA can pass information on these accessibility requirements to the competent authorities of other Member States. Infringements of Articles VIII.59 to VIII.62 are punishable by a level 2 sanction on the scale of the Code of Economic Law, and by a level 3 sanction where they are committed in bad faith. The law also opens the way to the collective redress action provided for in Book XVII of the same Code.

Exceptions and transitional periods

Like the directive, the law allows two exceptions: a fundamental alteration of the nature of the service, and a disproportionate burden, which must be demonstrated by a documented assessment based on the criteria in Annex 3. Service contracts concluded before 28 June 2025 may continue unchanged until they expire, for a maximum of five years. Until 28 June 2030, service providers may continue to provide their services using products they were lawfully using before that date, and self-service terminals already in use may remain in service until the end of their economically useful life, for no longer than twenty years after they were put into service.

The other transposing texts

The rest of the directive’s scope is spread across other legislation. The law of 20 July 2023 amends the law of 13 June 2005 on electronic communications for the radio equipment and terminals concerned (consumer computers and their operating systems, payment terminals, automated teller machines, ticketing and check-in machines, interactive information terminals, e-readers) and for electronic communications services, under the supervision of the BIPT, the Belgian telecoms regulator. Another law of the same date amends the law of 5 May 2017 on audiovisual media services in the bilingual region of Brussels-Capital. The Communities and Regions have adopted their own texts for the matters within their competence, such as audiovisual media, urban and regional transport and e-books.

Private companies in Belgium: are you covered by digital accessibility rules?

For a company, the starting rule is simple: the 2016 directive does not cover it, but the European Accessibility Act may, if it offers consumers one of the products or services within scope. Inter’s page on obligations in Flanders sums up the situation well: a company that sells online, with payment or a binding booking, falls under the EAA; a purely informational website of a private company has no legal obligation, even though accessibility remains strongly recommended.

E-commerce

For an online shop, the entire purchase journey is concerned: product page, choice of variants, basket, account creation, payment, confirmation, tracking and cancellation. The most frequent defects are well known: a size selector built with a custom drop-down list that cannot be opened with the keyboard, an error message indicated only by a red border, a payment session that times out without warning, an invoice sent as an untagged PDF, a chat widget that traps the focus. These defects are your responsibility even when they come from a third-party theme or plug-in.

Banking and financial services

A bank must make its consumer banking services accessible, whether account opening, payments, credit or electronic money, on the web and in its apps alike. The B2 language-level requirement means rewriting information texts: credit terms, explanations of fees, the error messages of a loan simulator. Terminals, cash machines and payment terminals, for their part, fall under the law of 20 July 2023.

Transport, telecoms and other services

Passenger transport operators, telecoms operators and audiovisual service providers need to identify the text that applies to them, which is often different from the one governing e-commerce, and the authority that supervises them. A rail operator, for example, may be concerned at the same time by the rules applicable to booking websites and apps, to electronic tickets, to real-time information and to self-service ticket machines.

What is not covered

Title 5 of Book VIII covers services provided to consumers. A platform aimed exclusively at professionals, such as an ordering portal for resellers, therefore falls outside its scope, unless it is also open to individuals. Micro-enterprises in banking and e-commerce are excluded until 28 June 2030, but they have every reason to prepare: a redesign decided in 2027 will still be online in 2030. For SMEs, our page on accessibility for SMEs sets out a proportionate approach.

Multilingual websites in French, Dutch, German and English: requirements specific to Belgium

Most federal and Brussels public websites, and many company websites, exist in two, three or four languages, and organisations based in Brussels frequently add English to the national languages. Multilingualism does not create any additional legal obligation, but it multiplies the points of failure. WCAG requires the language of each page to be identified in the code (success criterion 3.1.1), and passages in another language to be identified too (criterion 3.1.2). Without this, a screen reader set to French will read a Dutch page with French pronunciation, and the text becomes incomprehensible. The same applies to an English page read with a Dutch voice.

• Declare the language of each version on the html element, for example fr-BE, nl-BE, de-BE or en, and check it on every template, including error pages and modal dialogs;
• in the language switcher, write each language in its own language (“Français”, “Nederlands”, “Deutsch”, “English”) and mark it with the lang attribute; avoid flags on their own and “FR | NL” abbreviations without an accessible name;
• translate text alternatives, captions, transcripts and labels that are invisible on screen (aria-label, frame titles, error messages), which translation tools often miss;
• keep the same structure and navigation from one language to another, so that a user who switches language can find their way;
• publish the accessibility statement in each language of the website, with a contact who can reply in that language;
• check PDFs in every language: a document tagged in French does not mean its Dutch or English version has been tagged too.

The Belgian context also raises the question of sign language. For important video content aimed at the general public, interpretation into French Belgian Sign Language (LSFB) or Flemish Sign Language (VGT) significantly improves access, beyond the captions required by the standard. User testing works best when it is carried out in the real languages of the service: our testing with users with disabilities can be conducted in French or Dutch.

Who is who in digital accessibility in Belgium

Beyond the texts, a handful of public bodies shape the Belgian landscape. Knowing them tells you who to ask a question, where to find a tool and who can step in if there is a dispute.

• The Belgian Web Accessibility Office of the FPS BOSA, which monitors federal websites, publishes audit reports and provides a wizard for drafting the statement, a register of public websites under development and central purchasing arrangements;
• the interfederal steering group, which brings together the monitoring bodies of the various entities and prepares Belgium’s report to the European Commission;
• the regional and community monitoring bodies: the Agence du Numérique, ETNIC, equal.brussels, Inter and the Ministry of the German-speaking Community;
• NOOZO, the Flemish advisory council of people with disabilities, which is involved in Inter’s monitoring;
• the National Higher Council for Persons with Disabilities, which the EAA inspectors must consult on their general guidelines;
• the Economic Inspection of the FPS Economy and the BIPT for the European Accessibility Act;
• the ombudsmen: the Federal Ombudsman, the Ombudsman of Wallonia and the Wallonia-Brussels Federation, the Brussels Ombudsman and the Ombudsman of the German-speaking Community.

For public bodies, the central purchasing arrangements mentioned by the FPS BOSA make it possible to use services already awarded through public procurement, which lightens the procedure. For companies, there is no official compliance certification: proof rests on the documentation you build up, namely audits, statements, remediation plans and disproportionate burden assessments.

Action plan: bringing your services into compliance in eight steps

For a public service and for a company subject to the EAA alike, the process follows the same order. What varies is the text you cite and the body to which you are accountable.

1. Establish your legal position. Identify the entity to which each website and app belongs or, for a company, the EAA service concerned and the applicable Belgian text. Record this analysis: it will form the basis of the statement.
2. Map the scope. List websites, subdomains, apps, logged-in areas, forms, downloadable documents and third-party modules. The most common omissions are appointment booking, payment and registration platforms.
3. Prioritise the essential journeys. Start with whatever prevents a user from completing a procedure or a purchase: login, forms, payment, confirmation, contact. One defect on these steps weighs more than a dozen defects on news pages.
4. Commission an audit against EN 301 549. A compliance audit on a representative sample, with keyboard testing, screen readers on desktop and mobile, and checks on documents, gives you a defensible baseline. Add the WCAG 2.2 criteria now.
5. Plan and fix. Turn the report into a dated remediation plan, shared between developers, content editors and suppliers. Require a compliance commitment from third-party vendors in your contracts and specifications.
6. Publish the statement. Draft one statement per website and per app, as a web page, in each language, with a contact who replies and the correct route of redress. In Wallonia, plan for its annual update.
7. Train your teams. Regressions mostly come from content published after the audit: PDFs, videos, tables, new pages. Targeted training for content editors, developers and project managers avoids starting from scratch with every redesign.
8. Monitor continuously. Build an accessibility acceptance test into every significant release, follow up user reports and respond to them on time, for example within thirty days in Wallonia and the Wallonia-Brussels Federation.

For public bodies, our public sector page describes the support available; to compare with a neighbouring country that made the opposite choice of a national framework, see our article on digital accessibility in Luxembourg. And if you would like to take stock of your situation, you are welcome to contact us.

Frequently asked questions