European Accessibility Act in Belgium: Loi du 5 novembre 2023, who must comply, what's required
Updated 2026-08-07 · European Accessibility Act · Belgium
The Loi du 5 novembre 2023 (n° 2023046827), modifying several books of the Code de droit économique, is how Belgium partially transposes the European Accessibility Act — Directive (EU) 2019/882 — into national law. Its accessibility requirements for covered products and services apply from 28 June 2025, the same date as every other EU transposition. This guide covers who the law binds, what it requires, and where to read the official text.
What the law does
Rather than a single standalone act, Belgium implements the directive by amending existing economic law: the Code de droit économique (the country's main body of business and consumer law) and the 2002 law on financial-sector supervision. The published title itself frames this as a "transposition partielle" of the directive — Belgium folds the EAA's requirements into its existing legal architecture instead of creating a parallel one, but the substantive obligations businesses face are the same harmonised requirements that apply across the EU.
Who is covered
- Products: consumer computer hardware and operating systems, self-service terminals (payment terminals, ATMs, ticketing and check-in machines, interactive information kiosks), consumer terminal equipment for telecoms and audiovisual media, and e-readers.
- Services: e-commerce, consumer banking services, electronic communications services, services providing access to audiovisual media, elements of air, bus, rail and waterborne passenger transport, and e-books.
Because the amendments sit inside the Code de droit économique, Belgian e-commerce and consumer-facing financial services in particular are folded into rules businesses are typically already used to complying with for other consumer-protection purposes.
The microenterprise exemption
Service providers with fewer than 10 staff and an annual turnover or balance sheet total not exceeding EUR 2 million are exempt from the service obligations — the same EU-wide threshold set by the directive, not a Belgian-specific carve-out. Microenterprises dealing in covered products remain in scope, with reduced documentation duties.
The statement obligation
As under every EAA transposition, providers of covered services must make available information on how the service meets the accessibility requirements — the Belgian counterpart to what Germany documents through Anlage 3 of the BFSG. It needs to sit where a consumer can actually find it and stay current as the service changes.
How Belgian businesses demonstrate compliance
There is no separate Belgian certification scheme. As across the EU, conformance with EN 301 549 — the harmonised ICT accessibility standard, which for web content converges with WCAG 2.1 AA — creates a presumption of conformity. See our EN 301 549 guide for what it actually tests. An independent audit against that standard, plus the published statement above, is the evidence base that holds up under scrutiny.
Where to find the primary source
The official, consolidated text is published via Justel, the Belgian federal government's legal database — the source to cite for the exact wording, not a secondary summary. We do not quote a specific penalty figure for Belgium here: this amendment sits across several existing statutory frameworks with different enforcement routes, and quoting one figure out of that context would misstate what a given business is actually exposed to.
Next step
Run a free scan against the Belgian rule set to see how your accessibility statement and technical conformance measure up today, then compare against providers who audit specifically for EN 301 549 / EAA compliance.
FAQ
- Why does the guide say Belgium's transposition is "partial"?
- The Loi du 5 novembre 2023 itself describes its purpose as the "transposition partielle" of Directive (EU) 2019/882 — it amends the Code de droit économique and the 2002 financial-sector-supervision law to bring in the directive's requirements, rather than enacting one single standalone accessibility act the way Germany's BFSG or Austria's BaFG do. The substance for businesses is the same: covered products and services must meet the requirements from 28 June 2025.
- Is a Flemish-only or French-only business website exempt from anything special?
- No. The accessibility requirements are functional and apply regardless of the language a service is offered in. Belgium's linguistic regime governs which language a company must offer a service in, not whether the service has to be accessible — those are separate legal questions.
- Are small Belgian businesses exempt?
- Microenterprises providing services — fewer than 10 staff and annual turnover or balance sheet total not exceeding EUR 2 million — are exempt from the service requirements. This is the threshold the directive itself sets EU-wide, unchanged by the Belgian transposition.
- Where is the official text of the law published?
- The Moniteur belge / Belgisch Staatsblad, via the Justel database (ejustice.just.fgov.be), publishes the official consolidated text — that is the source to check, not a summary from a law firm or accessibility-tool vendor.