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EAA Enforcement Tracker

EAA Enforcement Tracker

Every verified accessibility-related enforcement action against private operators in Europe since the EU Accessibility Act became enforceable on 28 June 2025. Confirmed fines, pending lawsuits, and the German Abmahnung pattern — with citable sources.

Last updated: 23 May 2026
5 cases tracked
Next review: 23 August 2026

We track verified, publicly-sourced cases only. Cases under pre-EAA national laws (like Spain's Royal Decree 1112/2018) are included when the substance is equivalent — these are clearly labelled. For maximum fine ceilings in every EU country, see our EAA Fines by Country reference. For the deeper analysis, read the full breakdown.

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Showing 5 of 5 cases

Spain

January 2026

Confirmed

Vueling Airlines

€90,000 + public-funds ban

Authority

Audiencia Nacional (National High Court)

Legal basis

Royal Decree 1112/2018 (pre-EAA; mirrors WCAG 2.1 AA)

Spain's National High Court found that disabled customers could not independently complete bookings, check in online, or manage reservations on Vueling's website. The court imposed a €90,000 fine plus a temporary ban on receiving public funds — the secondary sanction often dwarfs the headline figure for airlines that receive aviation subsidies.

booking flow
checkout
screen-reader
keyboard navigation

* Pre-EAA legal basis; substance equivalent to EAA requirements.

Norway

ongoing since late 2025

Ongoing

HelsaMi (public health portal)

NOK 50,000/day (~€4,500/day)

Authority

Norwegian Equality and Anti-Discrimination Tribunal

Legal basis

Norwegian Equality and Anti-Discrimination Act (EAA-equivalent)

A national public health portal failed multiple WCAG 2.1 AA criteria around form labeling, focus management, and assistive-technology compatibility. Norwegian authorities imposed a continuous daily penalty of NOK 50,000 (~€4,500) that accrues until the portal is compliant. The cumulative running total is in the mid-six figures and growing.

form labels
focus management
assistive tech compatibility
public sector

France

filed November 2025

Pending

Auchan · Carrefour · E.Leclerc · Picard

Up to €37,500/violation + astreinte

Authority

DGCCRF (Direction générale de la concurrence)

Legal basis

EAA-transposed French law (Décret n° 2023-931)

The first EAA-specific lawsuits filed in the EU. France's consumer protection authority targeted four very large retailers for non-compliant e-commerce checkout flows. As of May 2026 the cases remain pending — no rulings, no fines. The strategic choice of household-name targets signals that mid-market operators are next.

checkout
e-commerce
cart flow

Germany

continuous since August 2025

Pattern

Hundreds of e-commerce SMBs (private settlements)

Typically €1,500–€4,000 per Abmahnung + Vertragsstrafe

Authority

Private law firms (UWG framework — not regulatory)

Legal basis

UWG (Gesetz gegen den unlauteren Wettbewerb), not the BFSG itself

Within weeks of the BFSG taking effect, specialist law firms began sending Abmahnungen to German e-commerce operators on the legal theory that an inaccessible competitor gains an unfair advantage. Individual settlements are typically €1,500–€4,000 plus a contractual penalty for repeat violations. Estimated 1,000–3,000 cases in the first nine months — the aggregate cost across the German SMB market exceeds every regulatory EAA fine combined.

contrast
missing alt text
form labels
keyboard navigation
WCAG-A obvious failures

† Aggregate of private settlements; individual amounts not publicly recorded.

Netherlands

reporting active since October 2025

Reporting active

(no individual cases public yet — mandatory reporting active)

Up to €110,000/violation

Authority

ACM (Autoriteit Consument & Markt) + 5 sector enforcers

Legal basis

Implementatiewet Toegankelijkheidsvoorschriften

The Netherlands has the highest single-violation fine ceiling in the EU at €110,000 and the most mature reporting infrastructure — ACM publishes a non-compliance list. Six sector-specific enforcers (ACM, AFM, ILT, RDI, CvdM, NVWA) coordinate enforcement. No individual fines published yet, but the reporting phase is producing a target list. Expect first cases later in 2026.

mandatory reporting
sector-coordinated enforcement

Run a free scan against the same failure patterns

Every case above failed on patterns automated tools catch — keyboard navigation, form labels, focus management, checkout flow. Webply scans your real pages against WCAG 2.1 AA and prioritises findings by EAA legal risk. No credit card.

FAQ

What counts as an EAA enforcement action?

Any verified penalty, lawsuit, or formal regulatory action against a private operator related to digital accessibility (web, app, or e-commerce) in an EU/EEA country since the EAA became enforceable on 28 June 2025. We include cases under pre-EAA national laws (like Spain's Royal Decree 1112/2018) when the substance is functionally equivalent — and we clearly label these.

How often is this tracker updated?

Quarterly, with ad-hoc updates when a major case lands. Each entry shows the source we verified it against. The "Last updated" date at the top is the source of truth — if it's more than 6 months old when you read this, the data may be stale.

Why isn't there a case for my country?

Either no public enforcement action has happened yet, or one happened but we haven't verified it. For the maximum fine ceilings and the enforcement authority in every EU country, see our EAA Fines by Country reference. If you know about a case we missed, tell us — we'd rather track it than guess.

Are German Abmahnungen really enforcement?

The German Abmahnung pattern is private litigation under unfair-competition law (UWG), not direct BFSG enforcement by a regulator. We include it because the practical effect on the operator is similar to a regulatory fine — settlement plus a remediation deadline — and because in aggregate the Abmahnung wave has moved more money than every EU regulatory fine combined.

About this tracker

  • What we track: verified accessibility enforcement actions in EU/EEA jurisdictions against private operators — regulatory fines, civil lawsuits, and recurring private-litigation patterns where the aggregate effect is meaningful.
  • What we don't track: US ADA cases, public-sector procurement disputes, soft warnings without monetary or legal consequence, individual Abmahnungen (we report the pattern, not every letter).
  • Sourcing: every case must have at least one citable public source. Some sources are secondary (compliance trackers, vendor research) where primary court documents are not yet publicly indexed — we flag this.
  • Spot a case we missed? Email us with a link. We'd rather track it than guess.

This page is informational and not legal advice. National regulators interpret the EAA-transposed laws differently and the picture is evolving — if you face a specific complaint, consult a qualified accessibility lawyer in your jurisdiction.