The European Accessibility Act (EAA) became enforceable on 28 June 2025. Nine months later, enforcement is no longer theoretical. Regulators across the EU have begun issuing formal notices, conducting investigations, and in some cases levying fines. If your business serves customers in the European Union, you need to understand what non-compliance costs in your specific markets.

This guide breaks down the penalty structure and enforcement status for every major EU economy.

How EAA Penalties Work

The EAA itself does not set a single fine amount. Instead, it requires each EU member state to define “effective, proportionate, and dissuasive” penalties through national legislation. This means the same violation could cost you very different amounts depending on which country is enforcing.

Penalties typically follow a graduated enforcement model. First comes a notification or warning. Then corrective action is required within a set timeframe. If the business fails to comply, financial penalties are imposed. In severe or repeated cases, products and services can be ordered withdrawn from the market.

Most countries distinguish between different types of violations. Selling a non-compliant product or service typically carries the highest fines. Failing to provide accurate accessibility information (such as a conformity declaration) carries separate, usually lower penalties. Repeat offenses universally result in escalated penalties.

Germany

Enforcement authority: Bundesnetzagentur (Federal Network Agency) and market surveillance authorities at the state level.

Maximum fines: Up to 100,000 euros for placing non-compliant products or services on the market. Up to 10,000 euros for failing to provide accurate information about the accessibility of products and services.

Enforcement status: Germany has been among the most proactive enforcers. The Bundesnetzagentur launched an online complaint portal in mid-2025 and has been investigating complaints since. Multiple formal investigations were opened in the e-commerce and banking sectors by the end of 2025. Germany’s enforcement approach focuses on market surveillance, meaning authorities actively check products and services rather than waiting for complaints.

Key risk: Germany’s large consumer market and proactive enforcement posture make it one of the highest-risk countries for non-compliance. If you serve German customers, compliance should be a priority.

France

Enforcement authority: DGCCRF (Direction Generale de la Concurrence, de la Consommation et de la Repression des Fraudes).

Maximum fines: Up to 250,000 euros for repeat violations of accessibility requirements. Initial violations typically result in formal notices with corrective deadlines.

Enforcement status: France was one of the first countries to take visible enforcement action. The DGCCRF issued formal notices to several major retailers before the end of 2025, signaling that enforcement is serious and not just symbolic. France has a strong history of consumer protection enforcement, and accessibility is being treated as a consumer rights issue.

Key risk: France’s enforcement follows a “formal notice first, fine second” approach, but the DGCCRF moves quickly. Businesses that ignore initial notices face escalating penalties and potential market restrictions.

Italy

Enforcement authority: AgID (Agenzia per l’Italia Digitale) for digital services.

Maximum fines: Up to 5 percent of annual turnover for large companies. For smaller businesses, fines range from 5,000 to 40,000 euros. Italy’s turnover-based penalty model makes it one of the most potentially expensive countries for large companies.

Enforcement status: Italy had existing digital accessibility legislation (the Stanca Act) before the EAA, so enforcement infrastructure was already in place. AgID has been monitoring compliance for public sector websites for years and expanded its scope to private sector services following the EAA transposition.

Key risk: The 5 percent of turnover figure makes Italy the highest-risk country for large enterprises. A company with 10 million euros in annual revenue could face fines of up to 500,000 euros.

Spain

Enforcement authority: Ministry of Social Rights and the 2030 Agenda, along with regional consumer protection authorities.

Maximum fines: Up to 1,000,000 euros for the most severe violations. Spain has one of the highest maximum penalty amounts among EU member states.

Enforcement status: Spain transposed the EAA into national law before the deadline and has been building enforcement capacity. Regional consumer protection offices handle complaints at the local level, while the national ministry coordinates enforcement policy. Spain categorizes violations as minor, serious, and very serious, with fines scaled accordingly.

Key risk: Spain’s million-euro maximum fine, combined with regional enforcement that can vary in intensity, creates uncertainty. Businesses operating across multiple Spanish regions may face multiple enforcement actions simultaneously.

Netherlands

Enforcement authority: ACM (Authority for Consumers and Markets).

Maximum fines: Up to 250,000 euros per violation.

Enforcement status: The ACM publicly stated it would prioritize e-commerce and banking platforms for early enforcement checks. The Netherlands has a reputation for pragmatic but firm regulatory enforcement. The ACM has been conducting sector-wide studies and publishing guidance documents to help businesses understand their obligations.

Key risk: The Netherlands’ focus on e-commerce and banking means online retailers and fintech companies face the highest immediate risk. The ACM’s transparent enforcement priorities make it relatively predictable where action will come first.

Austria

Enforcement authority: Federal competition authority and consumer protection offices.

Maximum fines: Up to 80,000 euros for non-compliance, with higher amounts for repeated violations.

Enforcement status: Austria transposed the EAA on time and enforcement has begun through consumer complaint mechanisms. Austrian enforcement tends to follow the German model given the close regulatory relationship between the two countries.

Belgium

Enforcement authority: FPS Economy (Federal Public Service Economy) and regional authorities.

Maximum fines: Penalties up to 80,000 euros, with potential for criminal sanctions in cases of deliberate non-compliance.

Enforcement status: Belgium’s federal structure means enforcement is split between national and regional levels. The Flemish, Walloon, and Brussels-Capital regions each have some enforcement responsibility, which can create complexity for businesses.

Sweden

Enforcement authority: The Swedish Consumer Agency (Konsumentverket).

Maximum fines: Administrative fines are set based on the severity and duration of the violation. Maximum amounts are determined on a case-by-case basis but can reach several hundred thousand euros for serious violations.

Enforcement status: Sweden’s consumer protection agency has integrated accessibility into its broader digital market surveillance program. The Scandinavian countries generally have high compliance expectations and well-resourced enforcement bodies.

Ireland

Enforcement authority: Competition and Consumer Protection Commission (CCPC).

Maximum fines: Up to 60,000 euros per offense, with potential for criminal prosecution in cases of persistent non-compliance.

Enforcement status: Ireland has been relatively measured in its enforcement approach, focusing initially on guidance and awareness campaigns. However, given that many US tech companies are headquartered in Ireland for EU operations, the CCPC may face pressure to take more visible action.

Poland

Enforcement authority: Office of Competition and Consumer Protection (UOKiK).

Maximum fines: Up to 10 percent of annual turnover for persistent violations, though typical penalties for individual offenses are lower. The turnover-based maximum makes Poland potentially very costly for repeat offenders.

Enforcement status: Poland has been building its enforcement infrastructure and has published accessibility guidelines for businesses. Enforcement activity is expected to increase throughout 2026.

Summary Table

Country	Maximum Fine	Enforcement Status
Germany	100,000 euros	Active investigations
France	250,000 euros	Formal notices issued
Italy	5% of turnover	Existing enforcement expanded
Spain	1,000,000 euros	Regional enforcement active
Netherlands	250,000 euros	E-commerce/banking prioritized
Austria	80,000 euros	Complaint-based enforcement
Belgium	80,000 euros	Split federal/regional
Sweden	Case-by-case	Integrated with consumer protection
Ireland	60,000 euros	Guidance-focused initially
Poland	Up to 10% of turnover	Building capacity

What Should You Do Now?

If you serve customers in any of these countries, here is a practical action plan.

Step 1: Understand your exposure. Run a free accessibility scan at a11yfix.dev/audit to see how many WCAG 2.2 violations your site currently has. This takes seconds and gives you a clear starting point.

Step 2: Get a professional audit. A free scan catches automated issues, but a full compliance assessment requires a professional report. Order one at a11yfix.dev/report starting at $149, delivered as a PDF within 24 hours. The report includes prioritized fixes with code examples so your development team can act immediately.

Step 3: Fix and re-test. Address the most critical issues first. Focus on issues affecting navigation, forms, and core user flows. Then re-scan to verify.

Step 4: Document your compliance efforts. Keep records of your audits, fix timelines, and ongoing monitoring. This documentation is your strongest defense if a regulator comes knocking.

Step 5: Monitor continuously. Accessibility is not a one-time fix. Use automated monitoring tools and schedule professional audits at least annually.

The EAA is here. Enforcement is real. The fines are significant. But with a clear understanding of the requirements and a systematic approach to compliance, they are entirely avoidable. Start with an audit today.