EAA Fines by Country: Statutory Maximums vs. What Has Happened

Correction (2026-07-31): An earlier version of this post said that EU regulators had begun “levying fines” under the European Accessibility Act, and attributed specific investigations and formal notices to named authorities in Germany, France, and the Netherlands. We could not substantiate any of it. No EAA fine has been publicly reported anywhere in the EU. The figures below are statutory maximums written into national law — ceilings that exist on paper — not penalties that have been imposed on anyone. We have removed the enforcement claims rather than restate them. We regret the error.

The European Accessibility Act (EAA) became enforceable on 28 June 2025. Each EU member state was required to write its own penalty regime into national law, and most of them did. Those penalty ceilings are real, they are on the books, and they are what a regulator would be working from if it decided to act.

What has not happened, as far as any public record shows, is a fine. Not in Germany, not in France, not anywhere. That gap between “the law has teeth” and “the teeth have been used” is the single most important thing to understand about EAA risk right now, and it is the thing most compliance marketing gets wrong — usually on purpose.

This guide gives you the statutory maximums by country. It does not tell you that enforcement is imminent, because we do not know that. If you are earlier in the process and want the obligations rather than the penalties, start with the EAA compliance checklist, or the 15-minute compliance check if you just want to know whether you are in scope.

Nothing here is legal advice. Penalty regimes are set by national transposition law, which varies in structure and which several states amended after initial transposition. Verify the current figures for your own markets with a qualified lawyer in that jurisdiction before making decisions based on them.

How EAA Penalties Are Structured

The EAA itself does not set a single fine amount. It requires each member state to define “effective, proportionate, and dissuasive” penalties through national legislation. The same violation can therefore carry very different exposure depending on which country is enforcing.

The structures share a common shape. Enforcement begins with a notification or warning. Corrective action is required within a set timeframe. Financial penalties come into play if the business fails to act. In severe or repeated cases, national law generally allows a product or service to be ordered withdrawn from the market.

Most countries also distinguish between types of violation. Placing a non-compliant product or service on the market typically sits at the top of the range. Failing to provide accurate accessibility information — a conformity declaration, for instance — is usually a separate and lower category. Repeat offenses escalate.

Note what this structure means in practice: the maximum is the ceiling for the worst case after a business has ignored the process. It is not the opening bid.

Statutory Maximums by Country

These are penalty ceilings in national law. None of them has been applied to a company under the EAA.

Germany — Enforcement sits with the Bundesnetzagentur and state-level market surveillance authorities. 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 accessibility information.

France — Enforcement sits with the DGCCRF. Up to 250,000 euros for repeat violations. French consumer-protection practice generally issues a formal notice with a corrective deadline before any financial penalty.

Italy — AgID has responsibility for digital services. Up to 5 percent of annual turnover for large companies; 5,000 to 40,000 euros for smaller businesses. Italy had digital accessibility legislation (the Stanca Act) before the EAA, so the supervisory infrastructure predates it. The turnover-based ceiling makes Italy the largest theoretical exposure for a big company.

Spain — The Ministry of Social Rights and the 2030 Agenda, alongside regional consumer protection authorities. Up to 1,000,000 euros for the most severe violations — one of the highest ceilings in the EU. Spain grades violations as minor, serious, and very serious, with the ceiling reserved for the top band.

Netherlands — The Authority for Consumers and Markets (ACM). Up to 250,000 euros per violation.

Austria — Federal competition authority and consumer protection offices. Up to 80,000 euros, with higher amounts available for repeated violations.

Belgium — FPS Economy and regional authorities. Up to 80,000 euros, with criminal sanctions available in cases of deliberate non-compliance. Belgium’s federal structure splits enforcement between national and regional levels, which makes the process harder to predict than the number suggests.

Sweden — The Swedish Consumer Agency (Konsumentverket). Administrative fines are set case-by-case on severity and duration rather than against a fixed statutory ceiling.

Ireland — The Competition and Consumer Protection Commission (CCPC). Up to 60,000 euros per offense, with criminal prosecution available for persistent non-compliance.

Poland — The Office of Competition and Consumer Protection (UOKiK). Up to 10 percent of annual turnover for persistent violations, with typical penalties for individual offenses considerably lower.

Summary Table

Country	Statutory maximum	Authority
Germany	100,000 euros	Bundesnetzagentur + state authorities
France	250,000 euros	DGCCRF
Italy	5% of turnover	AgID
Spain	1,000,000 euros	Ministry of Social Rights + regions
Netherlands	250,000 euros	ACM
Austria	80,000 euros	Federal competition authority
Belgium	80,000 euros	FPS Economy + regions
Sweden	Case-by-case	Konsumentverket
Ireland	60,000 euros	CCPC
Poland	Up to 10% of turnover	UOKiK

Every figure in this table is a ceiling in national law. The table does not record a single penalty that has been imposed, because there is not one to record.

So How Much Should You Actually Worry?

Here is the honest version.

The absence of fines so far is not a reason to ignore the EAA, but it is also not nothing. We looked at the same question a year into the regime in the EAA one year later, and the answer has not changed. Two things are true at once. The obligation is live — it took effect on 28 June 2025 and it applies to your business today regardless of whether anyone has been penalised yet. And the enforcement wave that compliance vendors have been predicting since 2024 has not arrived on the schedule they predicted.

What that argues for is doing the work on a sensible timeline rather than a panic timeline. The failures that would actually put you in front of a regulator — a checkout a screen reader user cannot complete, a booking flow that traps keyboard focus, forms with no labels — are the same failures that are costing you customers right now, with no regulator involved. That is the better reason to fix them, and it does not depend on a prediction about enforcement that we cannot make honestly.

If a regulator does come knocking, the thing that helps you is a documented record: what you assessed, what you found, what you fixed, and when. A business that can show a good-faith remediation programme is in a very different position from one that cannot, under every one of the graduated enforcement regimes above.

A Practical Sequence

Understand your exposure. Run a free accessibility scan at a11yfix.dev/audit to see what WCAG 2.2 violations an automated pass finds on your site. It takes seconds. It will not find everything — automated tools catch roughly a third of real issues — but it gives you a floor.

Get a manual audit for the flows that matter. Automated scanning cannot tell you whether your checkout is completable with a screen reader, because that is a question about a journey rather than a page. Our audit report covers that.

Fix in order of consequence. Navigation, forms, and core purchase or booking flows first. A missing alt attribute on a decorative image is not the thing that generates a complaint.

Document as you go. Keep the assessments, the fix timeline, and the dates. This is the record that matters if you are ever asked.

Re-test after changes. Accessibility regressions ship with ordinary feature work. A site that was clean in March is not necessarily clean in September.

The EAA obligation is real and it is in force. Whether the fines follow is something nobody can tell you yet, and you should be sceptical of anyone who claims otherwise.