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EAA for media and publishing sites in Netherlands — compliance checklist

Operating a media & publishing business in Netherlands after 28 June 2025 means complying with the country's national EAA transposition (Implementing Act on Accessibility Requirements) layered on top of EN 301 549 — and addressing media & publishing-specific failure modes including auto-generated captions of poor quality and missing audio descriptions for visual content.

Lin Chen · IAAP CPACC · Mobile accessibility lead3 min readPublished · Updated

EAA in Netherlands

Transposition: Implementing Act on Accessibility Requirements. Surveillance: Authority for Consumers and Markets (ACM). Max penalty: €900,000 or 1% turnover.

Media & Publishing accessibility — what is in scope

Media organisations face dual obligations: WCAG accessibility for their digital surfaces and CVAA-style captioning rules for video. The EAA explicitly covers "audiovisual media services" and ebooks; streaming platforms operating in the EU must comply by 28 June 2025.

Common failures in media and publishing sites

• Auto-generated captions of poor quality

• Missing audio descriptions for visual content

• Inaccessible paywalls and subscription flows

• Inaccessible ebook formats

• Video players without keyboard control

EAA compliance checklist

1. Confirm in-scope status. 2. Map to EN 301 549. 3. Audit and remediate. 4. Publish a localised accessibility statement (Article 13). 5. Maintain technical documentation for market surveillance.

FAQ

Frequently asked questions

Cited answers. Sourced. Updated as standards and case law change.

  • Does the EAA apply to non-EU media and publishing sites selling into Netherlands?

    Yes. The EAA applies to any product or service placed on the EU market or offered to EU consumers, regardless of vendor headquarters.

  • What is the maximum penalty in Netherlands?

    €900,000 or 1% turnover

  • Are auto-captions enough for WCAG compliance?

    Not consistently. WCAG 1.2.2 requires accurate captions. Auto-generated captions typically miss the accuracy bar (industry studies place YouTube auto-caption accuracy at ~70%) and are not considered sufficient by themselves. Human review or hybrid captioning is the standard remediation.

  • What does the CVAA require for online video?

    The 21st Century Communications and Video Accessibility Act requires full-length video programmed for TV and posted online to be captioned within prescribed timeframes. The FCC has issued implementing rules; video without captions can trigger enforcement.

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