The Dutch regulator tested whether people could buy something

The accessibility number I keep coming back to this year comes from a consumer regulator. The question behind it fits in one line: can a person using assistive technology place an order?

For the largest webshops in the Netherlands, mostly not. Germany enforces the same EU law. What it has measured so far is not the same.

Ordering with assistive technology

Since 28 June 2025 the European Accessibility Act covers webshops, and in the Netherlands the consumer authority ACM supervises it for e-commerce and communication services. In March 2026 the ACM published the results of a check: about 100 of the largest Dutch webshops, plus the sites of the largest telecom and energy providers. It tested together with people with lived experience of disability, and with Stichting Accessibility it sent a questionnaire to the people affected to find the biggest problems.

On 61 percent of the webshops, placing an order with assistive technology was impossible. On 33 percent of the checked sites, ordering worked, with serious problems, because users couldn't perceive all of the content.

(I wanted to subtract and say that about six percent work. The press release uses "webshops" for one number and "checked websites" for the other, and the telecom and energy sites were checked too. I can't tell whether the two share a base, so no six percent.)

The ACM named two examples. An order button that can't be pressed with the keyboard. A puzzle that is supposed to prove the user is human, which some people can't solve, so they can't use the site at all.

One zero in the checkout

Those two examples sit at different layers. The button is a component failure, the kind an audit catches: one control, one missing behavior. The puzzle is a design decision. Someone put it between the customer and the payment on purpose.

The ACM number doesn't care which layer failed. It counts customers who got through. That is the task-level measurement I argued for in the compliance post, run by a regulator across a whole market.

It also does the arithmetic the way a customer does. A checkout with nine accessible steps and one broken button is not 90 percent accessible. Completion multiplies along the path, and one step at zero makes the whole path zero. A criteria score averages the steps. The customer has to pass every one of them.

Germany, same law

Germany implemented the act as the Barrierefreiheitsstärkungsgesetz (BFSG), in force since the same day. Enforcement sits with the MLBF, a joint market surveillance authority of the 16 federal states in Magdeburg, fully responsible since 26 September 2025. Its board adopted surveillance strategies on 29 January 2026. The public page about them is a teaser that stops after one sentence.

The newest status I can find is a press release from 1 June 2026. It describes an authority that is still finishing its organizational and technical setup and has received nearly 700 reports. It works from reports by consumers and businesses, and from multi-year strategies. Fines go up to 100,000 euros. The MLBF's news page lists no results, no procedures and no fines. Not none. None published.

So far the visible route in Germany starts with the person the checkout failed. They can report the barrier to the MLBF or apply for proceedings under section 32 of the BFSG. That is a reasonable right to have. It also means that person has to notice the barrier, find the authority and write it down before anyone counts anything.

Running the same test yourself

The Dutch method is cheap to copy. Pick the one task your site exists for. Put something in the cart and pay, first with only the keyboard, then with a screen reader. If the order goes through, you have the number the ACM measured. If it doesn't, you know which step to fix first.

The ACM says it will point the worst performers among the largest companies to what they need to fix, and that companies that don't improve risk enforcement. For a large Dutch webshop, the test has already been run once, by someone else.