Accessibility is not a project, it is a status you earn

Imagine your organisation launches a new website. The build was handled with care, the developer ran WCAG checks, and at delivery the code is sound. A year later someone publishes a new news item, a colleague adds a PDF without tags, and an editor uploads a video without subtitles. The website is still "built to be accessible". But for a user with a screen reader, it stopped being so a long time ago.

That is exactly the pattern the figures show. Of all government websites with an accessibility statement, only 4% demonstrably hold status A. And 32% of those statements have not been updated in the past year, even though that is a legal requirement (Digimonitor 2025). Not because those organisations built carelessly, but because they treated accessibility as a one-off build project instead of a status you earn afresh every year.

Legislation sets the clock, for the private sector too

Government organisations have been bound since 2018 by the Dutch Decree on digital government accessibility, which sets WCAG 2.1 AA as the standard and requires a published accessibility statement. That is no longer news.

What is new: as of 28 June 2025 the European Accessibility Act (EAA) is in force, and it widens the obligation considerably. Web shops, banks, telecoms, transport and other consumer-facing private services now fall within its scope too. In the Netherlands the ACM supervises compliance. Fines can run up to 900,000 euro or 10% of annual turnover (Cardan, 2026). So the question is no longer whether accessibility is mandatory, but for whom, and how demonstrably.

The process in four steps, not in one go

Here lies the misconception many organisations make: they see accessibility as a final destination. Full WCAG 2.1 AA, or it does not count. In reality it is a journey with four statuses, and the law expects you to be somewhere on that ladder, not at the very top straight away.

Status D is where you start by doing nothing. No statement, no investigation, not compliant with the law. It is also where you fall back if you let validity periods lapse.

Status C is granted as soon as you publish a statement on the central register (found via toegankelijkheidsverklaring.nl). No investigation needed, just an honest description of where you stand. This status is valid for six months and is meant as a starting point: you indicate that you know you need to do something, and you have set it in motion. For many organisations this is the first step within the legal framework.

Status B is reached when, within those six months, you have an accessibility audit carried out by a recognised agency and publish an improvement plan. In practice, most government organisations sit in this phase: there is a statement and an audit, but the path to full compliance is still under way. Status B therefore does not mean you are not yet compliant with the law, it means you are transparent about where you stand.

Status A is the end goal: demonstrably fully compliant with WCAG 2.1 AA, backed by an audit with no outstanding points. Only 4% of government sites achieve this (Digimonitor 2025), and that is understandable. It is a high bar.

The deadlines that protect this status

Keeping accessibility up to standard is not a matter of getting it right once. The law works with validity periods, and anyone who lets them lapse automatically falls back to status D.

An audit (the basis for status A or B) is valid for three years. After that, a re-investigation is mandatory. The statement itself must be updated at least once a year, and you do not need to have that annual update carried out by the audit agency. There must, however, be visible progress: accessibility issues resolved, progress on the improvement plan, updated information on where you stand. A statement that says exactly the same thing for a year does not comply with the law, even if its content is still correct.

Status C, without an investigation, is valid for six months. After that there must be an audit in place, otherwise you lose your spot within the legal framework.

So that 32% of statements that have not been updated are not sites that have got worse. They are sites that skipped the annual update, and in doing so have slipped back below the legal radar.

WCAG rests on four principles, not on a checklist

WCAG 2.1 AA is the international standard that determines the content of the audit. The framework is built around four principles: perceivable, operable, understandable and robust. Together they determine whether a website is usable for everyone, including people who use a screen reader, navigate with a keyboard alone, or struggle with fast-moving or small text.

Each principle translates into concrete requirements. Perceivable means, among other things, that images have alt text, that videos are subtitled, and that colour contrast is sufficient (4.5:1 for ordinary text). Operable means that all functions are reachable via the keyboard, with visible focus indicators. Understandable calls for readable language, error messages that explain what went wrong, and consistent navigation. Robust is about semantic HTML and correct ARIA attributes, so that assistive technology can interpret the page correctly.

What many organisations underestimate: more than 80% of the mandatory WCAG requirements cannot be tested automatically. Automated tools detect only a fraction of the barriers users actually encounter (Digitoegankelijk, 2025). A Lighthouse score or an automated scan gives you a starting point, not a final verdict. The audit, carried out by people who also test manually, is what substantiates status B or A.

Where most organisations fall back

The law distinguishes between an accessible delivery and an accessible website. The first is a build quality, the second is a maintenance status. And that is precisely where the leak is.

A careful design process gets the technical layer in order. Semantic HTML, correct heading structure in the templates, accessible content blocks, sufficient colour contrast in the brand style: those are the conditions editors can build on. A CMS with well-configured content blocks helps enormously, because it offers editors structure without them having to rethink the technical setup every time.

But that is the floor, not the ceiling. Most accessibility issues after delivery do not arise in the code, but in the content: missing alt text on new images, broken heading structures because someone used an H3 where an H2 belonged, jargon that is incomprehensible to a broad audience, and videos placed without subtitles because that is simply quicker.

Most enforcement cases from the first EAA year therefore have nothing to do with technical code. In November 2025, French regulators opened proceedings against four major retailers, including Carrefour and Auchan, because users could not complete the checkout (Cardan, 2026). Not because the pages looked bad, but because they were unusable for people relying on assistive technology. Barriers of that kind rarely come from the delivery. They arise in maintenance.

What this asks of an organisation

An audit typically costs between 1,500 and 5,000 euro and is valid for three years (Proper Access, 2026). That is manageable money for a three-year period. The real investment lies elsewhere: in how you set up the publishing process, so that the status you reach through the audit does not leak away in the CMS within three months.

Concrete measures that make the difference: an editor checklist at publication (alt text present? heading structure logical? reading level checked?), periodic sampling of new content, training in accessible writing and image use, and a clear agreement on who is responsible if someone files a complaint. That last point matters more than it sounds: the EAA also obliges organisations to have a complaints procedure.

And, not to be forgotten: one person in the organisation who reviews the statement every year, documents the progress, and publishes the update. Without that role the deadline passes unnoticed, and you are back at status D.

A phased route is more realistic than a big bang

Bringing accessibility up to AA level in one go is rarely feasible and rarely necessary. A phased approach delivers more results per euro, and fits better with how the law is built up.

Start with what browsers already offer: semantic HTML that is correctly structured, alt text on all images, a logical heading structure. Those are quick wins that cost little and deliver a lot, for search engines too. A page built to be accessible is more readable for search engines and AI systems than a page full of images and JavaScript blocks, which directly contributes to discoverability.

Then publish a statement (status C), schedule the audit within six months (status B), and use the improvement plan as a prioritisation list. Which criteria deliver the most user gain, and which call for a larger technical intervention? Document choices and exceptions, so that during an inspection you can account for what you did and why. That is exactly what an accessibility statement asks for: not perfection, but transparency about where you stand and what you are doing to move forward.

Status A then follows as the final piece, at the moment the outstanding points have been resolved. Not as a starting point, but as a reward for a process that works.

The difference between complying and earning

Back to that website from the opening. The problem was not in the build. It was in what happened afterwards: content added without anyone knowing what accessible publishing requires, and a statement that was not updated.

The law does not expect perfection at delivery. It expects a statement that is accurate, an audit that follows within six months, an improvement plan that is carried out, and an annual update that shows you are still at it. That is a different brief than finishing a build project. It calls for editors who know what they are doing, agreements that structure the publishing process, and someone who guards the deadlines.

Anyone who organises that well does not only comply with the law. They also keep the status the audit delivered.

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Further reading

Schwung | agency for web design and web development Tilburg, on how Schwung builds websites with accessibility as a built-in way of working, not as an afterthought.

Schwung | brand development, activation, growth and monitoring, on brand work that stays right at every stage, including day-to-day maintenance after delivery.