EAA penalties by country: 9 EU countries compared

EAA penalties are the sanctions imposed under national laws implementing the European Accessibility Act, which sets accessibility requirements for specified products and consumer services. There is no single EU-wide fine. Each country sets its own penalties, and EU law requires those penalties to be effective, proportionate and dissuasive, with corrective action to address the non-compliance.^{Source 1}

Researched September 16, 2026. This comparison covers nine selected EU countries, not all 27 member states. It is general information, not legal advice about a particular business.

A list of maximum fines can help a business understand its exposure. The issue, though, is that the number alone tells you very little about which conduct attracts it, whether a regulator must first issue an order, or whether a different law also applies. An administrative fine and a payment imposed to make a company obey a correction order are different things.

That distinction matters when deciding what to do about an inaccessible service. Article 30 of the EAA requires penalties to be accompanied by effective remedial action. Paying a fine does not buy permission to leave the barrier in place.^{Source 1}

EAA penalties by country

The table focuses on consumer-facing digital services, especially e-commerce. It identifies relevant sanctions, not an absolute limit on everything a company could face. Other offenses, multiple-offense rules and sector-specific laws can change the total exposure. Amounts in Swedish and Czech currency are left unconverted rather than tied to a temporary exchange rate.

Relevant sanctions for consumer-facing digital services in nine EU countries. Each figure is qualified in the third column.

Where the headline figures need more explanation

France: identify the law before quoting the fine

The DGCCRF’s November 2025 guidance says violations of the Consumer Code’s accessibility obligations attract fifth-class contravention fines of €7,500, cumulative according to the number of offenses established. It also describes orders to bring products and services into compliance, potentially accompanied by periodic penalty payments and publicity.^{Source 6}

France separately has digital-accessibility obligations under Article 47 of its 2005 disability law. Arcom describes sanctions of up to €50,000 for accessibility failures within its enforcement remit and €25,000 for other specified obligations. Its guidance also explains that its control of actual accessibility requirements under that regime does not extend to private companies in the same way as to public-sector bodies.^{Source 13}

Those figures cannot be collapsed into one universal “French EAA fine.” A retailer needs to identify the obligation and enforcement authority applicable to its service. A smaller number in a comparison table also should not be mistaken for permission to ignore a correction order.

Ireland: criminal liability has specific conditions

Ireland’s €60,000 and 18-month figures come directly from Regulation 32(6)(b). They are the maximum penalties on conviction on indictment, a criminal prosecution route. The regulations separately provide for summary conviction, with a class A fine, up to six months’ imprisonment, or both.^{Source 8}

Regulation 33 addresses individuals behind corporate offenses. It requires proof of consent, connivance, approval or willful neglect by a director, manager, secretary or other relevant officer. Regulation 34 also provides a defense where the accused proves due diligence and all reasonable precautions to avoid the offense.^{Source 8}

Italy: the 5% turnover sanction does not apply to every business

Italy’s principal EAA sanction is €5,000–€40,000 for the breaches identified in Article 24(1). The same provision expressly cross-refers certain large entities to the older Stanca Law. That category includes entities offering public-facing websites or apps with average turnover exceeding €500 million over the preceding three years.^{Source 9Source 14}

Under the Stanca provision, AgID investigates and sets a deadline to eliminate the infringements. Failure to comply with the formal warning can lead to a sanction of up to 5% of turnover.^{Source 14}

Finland and Sweden: distinguish a penalty from an order-backed payment

A conditional fine is intended to induce compliance with an order. In Finland, Traficom describes it as a last resort, with the amount determined case by case. The digital-services enforcement provisions do not supply a fixed national maximum that can honestly be inserted into a simple fine-ranking table.^{Source 15Source 4Source 5}

Sweden has both an administrative sanction fee and conditional fines. Its law also prevents the sanction fee from being imposed for the same breach when that breach is the basis of an application to enforce a conditional fine. These mechanisms should not be added together as if every investigation automatically produces both.^{Source 12}

Regulators have already opened investigations

On March 3, 2026, Sweden’s PTS announced that it had opened 28 e-commerce supervision cases, including 11 additional cases in that announcement. These were investigations, not 28 fines or 28 findings of liability.^{Source 16}

France’s DGCCRF reported on June 25, 2026, that an investigation launched in January covered the accessibility of e-commerce websites and mobile apps. It also included the fairness of practices by businesses providing digital-accessibility audits. The same update said approximately 100 establishments were to be checked during 2026 across three investigations, which also covered multimedia products and passenger transport. That is a planned cross-sector total, not a count of 100 penalized websites.^{Source 17}

A claim that enforcement has not begun is inconsistent with these announcements. Neither announcement, though, tells an individual business how likely it is to be investigated or what fine it would receive.

Check whether the obligation applies to your service

The EAA’s main application date was June 28, 2025. Its scope is defined by product and service categories, not by the fact that a business happens to have a website. Covered services include e-commerce, consumer banking, e-books and specified communications and passenger-transport services.^{Source 1}

An online store can be in scope because it provides an e-commerce service, even if the physical goods it sells are not among the Act’s listed product categories. Conversely, not every SaaS product or B2B website automatically falls within the EAA. A US address does not itself exempt a provider offering a covered consumer service on the EU market.^{Source 1}

Microenterprises providing services are exempt from the directive’s accessibility requirements and obligations relating to compliance with those requirements. The definition requires fewer than 10 employees and annual turnover not exceeding €2 million or an annual balance-sheet total not exceeding €2 million. This is a service-provider exemption, not a blanket exemption for every small manufacturer or importer.^{Source 1}

There are also provisions for fundamental alteration and disproportionate burden, generally requiring an assessment and documentation. “We have not budgeted for accessibility” is not the assessment the directive describes. Other accessibility laws may still apply even where an EAA exemption is available.^{Source 1}

The 2030 transition provisions are narrower than a general website extension. They address specified existing products used to deliver services and certain pre-June 28, 2025 service contracts. Those contracts can continue without alteration until expiry, but no longer than five years from that date. An old website does not, merely because of its age, get a blanket exemption until 2030.^{Source 1}

What to do if your service is not compliant

Suppose a US retailer serves customers in Germany, France and Ireland. Its checkout uses a custom address selector that cannot be operated with a keyboard. Assume the service falls within the EAA and the retailer does not qualify for an exemption.

The inaccessible selector is a specific problem to fix. It is not enough information to calculate three national penalties and add them together. The customer unable to enter an address, meanwhile, still cannot place an order.

I would start by testing that purchase process, including the steps after the broken selector, rather than waiting for someone to estimate the likely fine. A manual accessibility audit should establish what fails, how the failure affects someone using assistive technology, and what evidence a developer needs to reproduce it. For an EAA compliance audit, agree on the applicable service requirements as well as the technical testing scope; a WCAG report alone does not establish that every EAA obligation has been satisfied.

Article 13 requires service providers to explain publicly how their services meet the applicable requirements, maintain procedures for continuing conformity, and take corrective measures when services do not conform. It also requires immediate notification of the competent national authorities where the non-compliant service is provided. Get counsel involved in that notification process rather than assuming the only duty is to answer complaints.^{Source 1}

For the hypothetical retailer, accessibility remediation would include repairing the selector and retesting the purchase flow with a keyboard and screen reader. Keep the finding, the implemented change and the verification result together. If there is already a regulator’s notice, the person managing the fixes also needs its actual response deadline.

Labrador’s audits include manual testing with assistive technology, findings tied to WCAG criteria, and retesting. We can identify and help fix the technical barriers. Counsel should determine the legal obligations and handle any enforcement response; booking an audit is not a suspension of those obligations.

Frequently asked questions

Is there one European Accessibility Act fine across the EU?
No. Article 30 of Directive 2019/882 requires EU countries to set their own penalties. Those penalties must be effective, proportionate and dissuasive, and accompanied by effective remedial action. The amount and procedure depend on the applicable national law and the breach.

Can an EAA violation lead to imprisonment?
Yes, under Ireland’s implementing regulations, conviction on indictment can carry up to 18 months’ imprisonment, a fine of up to €60,000, or both. Corporate officers are personally liable only when the conditions in Regulation 33 are established. Imprisonment is not an automatic consequence of an inaccessible website.

Are small businesses exempt from the EAA?
Microenterprises providing services are exempt from the directive’s accessibility requirements and related compliance obligations. The definition requires fewer than 10 employees and annual turnover not exceeding €2 million or an annual balance-sheet total not exceeding €2 million. Small product businesses do not receive the same blanket exemption, and other accessibility laws may still apply.

Do existing websites have until 2030 to comply?
Not simply because they already existed. Article 32 provides limited transition arrangements for specified existing products used to provide services and certain service contracts agreed before June 28, 2025. It does not create a blanket extension to 2030 for every existing website.

Does paying an EAA fine remove the need to fix accessibility problems?
No. Article 30 requires penalties to be accompanied by effective remedial action. Service providers must also take corrective measures under Article 13. A financial sanction does not replace the obligation to bring a covered service into conformity.

Will an accessibility audit prevent EAA penalties?
An audit cannot guarantee that a business will avoid penalties. It can identify technical barriers and provide evidence for remediation, but unresolved failures, required public information, notification duties and ongoing conformity still need attention. The legal effect of corrective work depends on the applicable law and the facts of the case.

Sources

1. Directive (EU) 2019/882 (European Accessibility Act), EUR-Lex. View source on EUR-Lex (opens in a new tab)
2. Austria, Barrierefreiheitsgesetz (BaFG), Rechtsinformationssystem des Bundes. View source on the Austrian legal information system (opens in a new tab)
3. Czechia, Act 424/2023, e-Sbírka. View source on e-Sbírka (opens in a new tab)
4. Finland, Act on the Provision of Digital Services 306/2019, Finlex. View source on Finlex (opens in a new tab)
5. Finland, Conditional Fines Act 1113/1990, Finlex. View source on Finlex (opens in a new tab)
6. France, DGCCRF guidance for businesses on the accessibility directive. View source on the DGCCRF website (opens in a new tab)
7. Germany, Barrierefreiheitsstärkungsgesetz (BFSG) §37, Gesetze im Internet. View source on Gesetze im Internet (opens in a new tab)
8. Ireland, S.I. No. 636/2023, Irish Statute Book. View source on the Irish Statute Book (opens in a new tab)
9. Italy, Legislative Decree 82/2022, Article 24, Normattiva. View source on Normattiva (opens in a new tab)
10. Spain, Ley 11/2023, Boletín Oficial del Estado. View source on the Boletín Oficial del Estado (opens in a new tab)
11. Spain, Real Decreto Legislativo 1/2013, Boletín Oficial del Estado. View source on the Boletín Oficial del Estado (opens in a new tab)
12. Sweden, Lag 2023:254, Sveriges riksdag. View source on Sveriges riksdag (opens in a new tab)
13. France, Arcom, accessibility of digital sites and services. View source on the Arcom website (opens in a new tab)
14. Italy, Law 4/2004 (Stanca Law), Normattiva. View source on Normattiva (opens in a new tab)
15. Finland, Traficom, tasks of the supervisory authority. View source on saavutettavuusvaatimukset.fi (opens in a new tab)
16. Sweden, PTS announcement, March 3, 2026. View source on the PTS website (opens in a new tab)
17. France, DGCCRF enforcement update, June 25, 2026. View source on the DGCCRF website (opens in a new tab)