Back to Blog
EU Accessibility Act fines in 2026: what every SMB and agency needs to know
The European Accessibility Act has been in force since June 2025. Here is what you can be fined in Germany, France, Austria, the Netherlands, Belgium, and Ireland — with real enforcement examples and what to do this quarter.
The EU Accessibility Act (EAA) has been enforceable since 28 June 2025. Maximum fines range from €60,000 (Ireland) to €200,000 or 6% of annual turnover (Belgium, bad-faith violations).
France filed its first enforcement actions in November 2025. Ireland is the only EU member state with criminal sanctions — up to 18 months in prison for deliberate non-compliance.
If you sell goods or services to EU consumers and have ≥10 employees or ≥€2M turnover, this applies to your website, your checkout, your customer-facing app, and your PDFs.
Fine data verified against primary sources (national transposition acts, official authority websites, EUR-Lex) — last verified 16 May 2026. Not legal advice; consult a lawyer for your specific situation.
What is the European Accessibility Act?
The European Accessibility Act (Directive (EU) 2019/882) is the EU-wide law that requires a long list of products and services — including e-commerce websites, banking, e-books, ticketing, and consumer-facing telecom services — to meet a baseline of accessibility for people with disabilities.
The technical baseline is EN 301 549, which maps almost directly to WCAG 2.1 Level AA. If your site passes a clean WCAG 2.1 AA audit, you are very close to EAA-compliant on the digital side.
The directive was adopted in 2019 and gave member states until 28 June 2022 to transpose it into national law, with a three-year grace period before it took effect. That grace period ended on 28 June 2025. Enforcement is now active in all 27 member states.
For a deeper breakdown of how WCAG, EN 301 549, and the EAA relate to each other, see our guide to the three standards.
Who has to comply?
The EAA primarily targets economic operators placing products or services on the EU market. In practice, that means:
- E-commerce sites selling to EU consumers — full stop.
- Consumer banking, payments, and fintech apps.
- Booking and ticketing platforms (transport, events).
- Audio-visual media services and e-readers.
- B2B agencies whose clients are subject to the EAA — your client inherits the obligation, and it almost always rolls back to the agency that built the site.
There is a microenterprise exemption: companies under 10 employees and under €2M annual turnover are exempt from the service obligations (but not the product obligations). Most of our customers do not qualify for this exemption.
Maximum fines, country by country
Each EU member state set its own penalty regime when transposing the directive. The six markets below were chosen for the complexity of their enforcement regimes — multiple authorities, dual fine tracks, criminal exposure, or sector-specific rules that trip up cross-border operators. Wherever you operate in the EU, the deadline was 28 June 2025 and the obligation applies to you. For every country — ranked by fine ceiling, with enforcement authority and official source — see our EAA Fines by Country reference.
| Country | Max fine | Notable detail |
|---|---|---|
| 🇩🇪 Germany | €10,000 – €100,000 per violation | Plus competitor lawsuits via the Abmahnung system — rivals can sue you for unfair advantage from non-compliance. |
| 🇫🇷 France | Up to €50,000 (ARCOM, public sector + companies >€250M revenue) · up to €37,500/violation (DGCCRF, other private sector) | ARCOM adds a separate €25,000/year fine for missing accessibility statement. DGCCRF can layer daily astreinte up to €300,000 cumulative. First enforcement actions Nov 2025 against major retailers (Auchan, Carrefour, E.Leclerc, Picard). |
| 🇦🇹 Austria | Up to €80,000 (large enterprises ≥250 employees) · up to €50,000 (SMEs <250 employees) | 14-day response window after a complaint. Micro-enterprises (<10 employees, ≤€2M turnover) are largely exempt from service obligations under §6 BaFG. |
| 🇳🇱 Netherlands | Up to €110,000 per violation (5th category fine; indexed from €103,000 in Jan 2024 to €110,000 from Jan 2026) | Six sector-specific enforcers: ACM (e-commerce), AFM (finance), ILT (transport), RDI (telecoms), CvdM (media), NVWA (products). Mandatory reporting since October 2025. |
| 🇧🇪 Belgium | €208–€80,000 or 4% of annual turnover (standard violation) · up to €200,000 or 6% of turnover (bad faith/intentional) | Enacted Nov 2023 (CDE Books VIII/XV). Enforced by DGIE (SPF Economie) for e-commerce and banking. Belgium's complex federal structure means linguistic versions (FR/NL/DE) can be assessed separately. |
| 🇮🇪 Ireland | Up to €60,000 + up to 18 months prison | The only EU member state with criminal sanctions for deliberate non-compliance. |
A side note for cross-border operators: Norway (EEA, not EU) imposes continuous daily fines of roughly €400/day until compliance is achieved — a model that several EU regulators have indicated they may copy.
How does enforcement actually work?
Fines are not usually imposed cold. The typical pattern across member states is:
- A regulator, consumer advocacy group, or competitor files a complaint.
- The regulator notifies the operator and gives a window to fix the issues — typically 14 to 90 days.
- If the issues are not resolved (or are systemic), formal penalty proceedings begin.
- In Spain, regulators can impose immediate penalties for serious violations without a prior warning period.
The takeaway: you almost always have time to fix things after notification — but not very much, and complaints are not a hypothetical scenario anymore.
Real enforcement examples (Nov 2025 – Apr 2026)
The eight months since the EAA went live have produced more enforcement activity than the previous decade combined:
- France, Nov 2025: First EAA enforcement actions filed against Auchan, Carrefour, E.Leclerc, and Picard for inaccessible e-commerce checkouts.
- Netherlands, Oct 2025: Mandatory accessibility reporting kicked in; ACM began publishing a non-compliance list.
- Germany: A wave of Abmahnungen (cease-and-desist letters) from competitors targeting smaller e-commerce shops with obvious WCAG failures.
What to do this quarter
You do not need a six-figure consultancy engagement to make meaningful progress. A pragmatic plan:
- Run an automated scan across your real templates — home, product, checkout, account, contact. Automated tools catch about 30–40% of issues; that is enough to find the load-bearing problems (colour contrast, missing alt text, form labels, ARIA misuse).
- Triage by severity. Critical and serious WCAG 2.1 AA issues are what gets you fined. Minor issues are noise.
- Fix the load-bearing pages first — checkout and account flows are the single most likely source of a complaint.
- Publish an accessibility statement on your site. France specifically fines for missing this; most member states require it.
- Schedule monthly re-scans. Compliance is a state, not a project — code changes break things.
See where your site stands today
Webply runs an automated WCAG 2.1 AA scan across your site, ranks issues by EAA legal risk, and gives you a developer-ready fix-list. Free QuickScan, no credit card required.
Sources and references
- European Commission — Directive (EU) 2019/882 on accessibility requirements for products and services.
- ETSI/CEN/CENELEC — EN 301 549 v3.2.1 Accessibility requirements for ICT products and services.
- German BFSG — Barrierefreiheitsstärkungsgesetz; single market-surveillance authority MLBF AöR.
- France DGCCRF — Décret n° 2023-931; first enforcement actions filed November 2025 against Auchan, Carrefour, E.Leclerc, Picard.
- Netherlands ACM — Autoriteit Consument & Markt; Implementatiewet Toegankelijkheidsvoorschriften (mandatory reporting since October 2025).
- Ireland S.I. 636/2023 — Accessibility of Products and Services Regulations 2023 (criminal sanctions under Reg. 32).
- Belgium CDE — Books VIII/XV enacted November 2023; DGIE (SPF Economie) enforcement authority.
This article is informational and not legal advice. National regulators interpret the directive differently and the picture is still evolving — if you face a specific complaint, consult a qualified accessibility lawyer in your jurisdiction.