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The European Accessibility Act (EAA) has been in full effect across the EU since June 28, 2025 — but not every country has implemented it the same way. We've already broken down the nuances of EAA compliance in Portugal and what's different in the Netherlands, and if you haven't read those yet, they're worth a look. We've also put together a free EAA eBook to help businesses get ready according to the requirements across the EU.
Belgium, however, is a chapter of its own.
As of January 2026, the EAA is fully in force in Belgium — but the story here isn't just about what the law requires. It's about who enforces it, where, and under which rules. For businesses operating in or selling to Belgian consumers, the complexity of the country's federal structure makes this one of the most layered compliance landscapes in the EU.
Belgium's federal structure divides power between federal, regional, and community levels — and the EAA was transposed accordingly. Rather than a single national law, Belgium integrated the Act through 14 different laws and decrees.
Here's how that breaks down in practice:
Federal Level — covers banking, e-commerce, and telecommunications, primarily through the Code of Economic Law. If your business operates in any of these sectors, federal rules apply regardless of which region you're in.
Regional and Community Level — covers media and local transport, with a clear split between communities. Flemish media falls under Flemish regulation; French-language media falls under French community rules. Local transport operators — Brussels Mobility, De Lijn, TEC — are governed at the regional level.
The practical consequence is significant: if you operate a business in Belgium, you may be answerable to different regulators depending on where your office is located and what type of service you provide. A company with operations in both Flanders and Wallonia, providing both digital media and e-commerce services, could find itself navigating multiple overlapping frameworks simultaneously.
Belgium has set some of the most severe financial penalties for EAA non-compliance anywhere in the European Union. Businesses found to be in violation face:
To put this in context: Portugal's maximum fine sits at €44,891. Belgium's ceiling is more than four times higher, and that's before the 6% of turnover clause comes into play for larger businesses.
One of the more useful points of clarity to emerge from Belgian regulators in late 2025 is the confirmation that the EAA applies strictly within a B2C (Business to Consumer) scope.
If your software or platform is sold exclusively to other businesses with no consumer-facing element, EAA requirements generally do not apply. However — and this is where many businesses trip up — if a consumer can use your platform to purchase a product, you are in scope. The test isn't what your primary business model is; it's whether the end user is a consumer.
In parallel, the FPS Economy (FOD Economie) has launched a centralised reporting portal called ConsumerConnect, where Belgian citizens can now formally report inaccessible webshops or banking apps. This has meaningfully lowered the barrier for consumer complaints and should be taken seriously as an early warning indicator for businesses.
The FPS Economy has also issued sector-specific guidelines for e-commerce, with one important clarification: the entire purchase funnel must be accessible — from product selection through to the final payment and invoice PDF. Partial compliance isn't enough if key steps in the buying journey remain inaccessible.
For businesses deploying or selling physical hardware in Belgium — ATMs, ticketing machines, self-service kiosks — the rules are clear but contain an important distinction.
Any new device placed on the market after June 28, 2025 must be fully compliant. There is no grace period for new hardware.
Existing devices, however, fall under what's referred to as a 'long-tail' exemption: older machines already in use may remain operational until the end of their economic life, but no longer than 20 years from their initial deployment. This gives businesses time to plan hardware transitions without being forced into immediate replacement — but the clock is running, and any new purchases or deployments must meet compliance requirements from day one.
Belgium's EAA landscape rewards businesses that take a structured, proactive approach. The fragmented enforcement model means that getting compliance right isn't just about meeting a single standard — it's about understanding which regulator applies to your specific context.
The penalties for getting it wrong are among the steepest in the EU. The consumer reporting infrastructure is live and accessible. And the B2C scope means that if any part of your service touches end consumers in Belgium, you are firmly in scope.
If you're operating across multiple EU markets, the differences between how Portugal, the Netherlands, and Belgium have each implemented the EAA make a strong case for treating compliance on a country-by-country basis — not as a single blanket exercise.
Our free EAA eBook is a practical starting point to help you understand the requirements and prioritise what to address first.
If your company is struggling with these regulations, we're here to help — just reach out.
