TRDigital accessibility in Dutch healthcare, 2026
An automated WCAG 2.2 assessment of 29 hospital and care provider homepages in the Netherlands, as Parliament asks which providers fall outside the accessibility rules.
Dutch public bodies have had to make their websites accessible since 2018, but whether hospitals and private care providers are bound by the same rules is not settled; in September 2026 a parliamentary motion asked the government to find out. We scanned the homepages of 29 healthcare providers, 24 hospitals and clinics and 5 care organisations, against WCAG 2.2 and classified every automatically detected barrier by criterion, principle and level. 25 homepages have at least one barrier at Level A or AA, 292 in total. Low-contrast text is the most common problem, and seven providers hold 68% of all barriers.
1Key findings
- 39%
Contrast is the most common problem. 114 of 292 barriers are low-contrast text, found on 17 of 29 sites.
- 17 / 29
Screen reader users get stuck on 17 sites. Unnamed buttons and links, and ARIA attributes that do not fit their role, account for 109 barriers.
- 68%
Barriers concentrate in a few providers. The 7 sites with the most barriers hold 68% of the total, while 4 sites showed no A or AA barrier at all.
- 76%
Barriers are mostly repetition. On 21 of the 25 affected sites, a single error type makes up at least half of the barriers; one fix goes a long way.
- 29 / 29
Touch areas are tight on mobile. Six sites fail the AA target size; at the stricter AAA level, every site has targets below 44 × 44 px.
2Methodology
- STEP 01Select29 healthcare providers in the Netherlands: 24 hospitals and clinics, including university medical centres, and 5 care organisations.
- STEP 02ScanEach homepage against WCAG 2.2 on 6 November 2026, with the same tool version.
- STEP 03ClassifyEvery barrier tagged by criterion, principle and level.
- STEP 04AnalyseResults grouped by topic and sector. No provider is named or ranked.
Scope note. The accessibility data in this report is calculated from each provider's homepage only. Pages behind login, such as patient portals, subpages, mobile apps and documents are out of scope; results do not represent a provider's digital channels as a whole.
Standard disclosure
Automated testing in this study detects only a subset of WCAG 2.2 failures. A clean automated result does not mean a site is accessible or conformant. Barriers under the Understandable principle, such as unclear instructions or unhelpful error messages, and the real behaviour of interactive components can only be assessed through manual review, which is outside the scope of this report. Findings describe detectable barriers, not legal compliance.
3Results
3.1 Barriers by WCAG principle
WCAG groups its requirements under four principles. On Dutch healthcare homepages, 58% of barriers are Perceivable, driven mainly by contrast, and 28% are Robust: controls that assistive technology cannot identify.
58% of barriers are Perceivable
Share of 292 barriers, with the number of sites affected
43% are Level AA
Level A is the most basic level of WCAG
Contrast is 90% of AA barriers
Composition of the 126 Level AA barriers
3.2 Barriers by topic
Six in ten providers have contrast or screen reader barriers
Provider homepages failing each topic, shown per 10 sites
Contrast. 114 contrast barriers on 17 sites make up 39% of all barriers. Two sites alone hold 56 of them.
Screen readers. 109 barriers on 17 sites are unnamed buttons and links, and ARIA attributes that do not fit their role. A screen reader announces them only as "button" or "link".
Images. 26 barriers on 7 sites are images and embedded objects without a text alternative. One site holds 14 of them.
3.3 Distribution across providers
4 providers show no barriers, 4 have more than 20
Number of provider homepages by count of A and AA barriers
of all barriers are held by the 7 providers with the most
of barriers repeat an error already present on the same site
median barriers per 100 elements examined (range 0 to 16.0)
4Priorities for remediation
Five targeted fixes cover 286 of the 292 barriers detected. The coverage column shows the cumulative share once each fix is added to those above it.
| # | Fix | Barriers · sites | Who benefits | Cumulative coverage |
|---|---|---|---|---|
| 1 | Fix weak contrastWCAG 1.4.3 | 114 · 17 sites | Low vision, older users | |
| 2 | Give buttons and links an accessible nameWCAG 4.1.2 · 2.4.4 | 109 · 17 sites | Screen reader users | |
| 3 | Add text alternatives to imagesWCAG 1.1.1 | 26 · 7 sites | Blind users | |
| 4 | Code page structure correctlyWCAG 1.3.1 | 26 · 8 sites | Screen reader users | |
| 5 | Make touch targets at least 24 pxWCAG 2.5.8 | 11 · 6 sites | Mobile, motor impaired |
The same fixes pay off beyond compliance: better contrast improves readability for every patient in sunlight and at low brightness, and meaningful names and clean structure help search engines and software tools interpret a page.
Beyond Level AA
Level AAA is not required by most regulations and is kept out of the main figures. It shows whether a site that passes AA is truly comfortable to use.
sites have touch targets below 44 × 44 px; 689 targets in total.
sites with no barriers still carry AAA warnings, 22 to 66 per site.
sites open links in a new tab without warning.
5Regulatory context
Dutch healthcare sits in a grey zone. Public bodies are bound by WCAG-based rules, but many hospitals and care providers are private foundations, and Parliament has now asked which of them fall outside.
From public bodies to the question of care providers
Milestones for digital accessibility in Dutch healthcare
- Oct 2016
EU adopts the Web Accessibility Directive for public bodies
- Jan 2017
Equal treatment act adds a general accessibility duty
- May 2018
Public-sector digital accessibility decree adopted
- Jun 2025
EAA applies; healthcare as such is not in scope
- Sep 2026
EN 301 549 v4.1.1 published, moving to WCAG 2.2
- Sep 2026
Parliamentary motion on hospitals and private care providers
- Oct 2026
New model accessibility statement applies
Public-sector decree
Public bodies and public-law institutions must apply EN 301 549 and publish an accessibility statement; a new model statement applies from 1 October 2026. Whether a hospital counts depends on how it is funded and governed.
Parliament
Notes that not all hospitals and private care providers are public-law institutions, so WCAG does not necessarily apply to them, and asks the government to investigate which institutions fall outside the rules.
Equal treatment and EAA
Since 2017, the equal treatment act requires general accessibility of goods and services, realised step by step. The EAA, in force since June 2025, does not cover healthcare as such.
Unlike banking or telecom, the legal duty for Dutch healthcare websites depends on how each provider is organised, and Parliament is now asking the question. Meanwhile 25 of 29 homepages have automatically detected barriers at Levels A and AA, the levels EN 301 549 builds on. This is not a compliance judgement.
6Implications for executives
Measure the patient journey
Appointment booking, the patient portal, forms and route information matter more than the homepage. Patients with impairments rely on these channels more than most; measure them first.
Assign a single owner
Barriers span design, content and engineering. Without an executive owner and a quarterly target, fixes lose to the campaign calendar.
Start with contrast and names
Contrast and unnamed controls make up 76% of barriers. One update to the colour palette and the shared icon buttons removes most of them across every page.
Do not wait for the rules to settle
Whether or not the public-sector decree applies, patients already depend on these sites. Publishing an accessibility statement and a remediation plan now prepares you for either outcome.
References
- Tijdelijk besluit digitale toegankelijkheid overheid, 3 May 2018. Officiële bekendmakingen.
- Staatscourant 2026, 515: model accessibility statement. Officiële bekendmakingen.
- Tweede Kamer. Motion El Boujdaini and Vervuurt on WCAG for hospitals and care providers, 26 643, 24 September 2026.
- Besluit algemene toegankelijkheid voor personen met een handicap of chronische ziekte, Stb. 2017, 256. Officiële bekendmakingen.
- Rijksinspectie Digitale Infrastructuur. European Accessibility Act: start date and supervision.
- AccessibleEU. “The European accessibility standard EN 301 549 has been updated”, 7 September 2026.
- W3C. Web Content Accessibility Guidelines (WCAG) 2.2.
- World Health Organization. Disability and health, fact sheet, March 2023.
Dutch healthcare sector: digital accessibility report 2026
Complete data, methodology, WCAG criteria table and appendix.
