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)

In April 2025, the Federal Trade Commission did something the accessibility industry had been waiting years for someone to do. It looked at accessiBe – the largest, loudest seller of one-line-of-code “compliance” – and called the pitch what it was: false.

The order required accessiBe to pay $1 million and barred the company from claiming its automated tool could make any website WCAG-compliant unless it had the evidence to prove it. The specific claim the FTC went after is worth quoting, because you’ve almost certainly seen a version of it: installing “one line of code” makes a website compliant with 30% of WCAG requirements immediately, and an AI process handles the remaining 70% within 48 hours.

It doesn’t. It never did. And if you’re running an overlay on your site right now because someone sold you that promise, this post is for you.

What an accessibility overlay/widget actually is

An accessibility overlay (often referred to as a widget) is a piece of third-party JavaScript you drop onto your site that claims to detect and fix accessibility problems automatically – usually paired with a little floating icon that opens a menu of font-size and contrast controls. accessiBe, UserWay, AudioEye, EqualWeb, and a few dozen others all sell variations on this model.

Here’s the part the marketing leaves out. The overlay runs after your page loads. It injects its changes on top of your existing code rather than fixing the code itself. And that single architectural fact is the reason the whole category fails the people it claims to serve.

Screen readers like JAWS, NVDA, and VoiceOver build their understanding of your page from your HTML source. By the time an overlay’s script wakes up and starts rearranging things, the assistive technology has often already done its work – reading the broken version. The overlay is patching a wall the screen reader already walked through.

So, do accessibility overlays work?

For the question that actually matters – can a disabled person complete what they came to your site to do – the honest answer is: not reliably, and often not at all.

This isn’t one consultant’s grudge. The Overlay Fact Sheet, an open letter signed by contributors to the WCAG, ARIA, and HTML specifications, by code contributors to the JAWS and NVDA screen readers, and by internal accessibility experts at Google, Microsoft, Apple, and Shopify, lays out the technical case in detail. Automated repair of image alt text, form labels, error handling, and keyboard focus is – in their words – not reliable. Modern component-based frameworks like React, Angular, and Vue change the page out from under the overlay entirely.

And the people these tools are supposedly for? In the survey cited by the Fact Sheet, just 2.4% of users with disabilities rated overlays as “very effective.” Many find them so disruptive they install browser scripts specifically to block them. Sit with that number for a second. The product is named after accessibility, and the disabled users it targets are building tools to make it go away.

The lawsuit problem nobody mentions in the sales call

Here’s where it stops being a philosophical debate and starts costing money.

The pitch for an overlay is fundamentally a legal one: install this, avoid a lawsuit. The data says the opposite is happening – and 2025 made that clearer than ever. According to UsableNet’s research team, more than 5,000 digital accessibility lawsuits were filed in 2025, and the cases targeting sites with a widget installed didn’t let up for a single month – they ranged from roughly 95 to more than 150 filings per month, totaling around 1,400 lawsuits against businesses that already had an overlay running. EcomBack’s year-end analysis put it at nearly one in four ADA web lawsuits filed against a site with an accessibility widget live on it.

This wasn’t a fluke year. The 2024 report found the exact same pattern – roughly 25% of that year’s web accessibility lawsuits hit sites already running an overlay. Two consecutive years, same story: the widget that was sold as lawsuit protection shows up in the complaint. And the overall trend is pointing up, not down, with ADA website accessibility filings climbing 37% in the first half of 2025 alone.

What we are seeing here is a market that monetized fear faster than it solved problems. A business owner hears “you could get sued,” panics, reaches for the cheapest, fastest-looking fix, and ends up with both an inaccessible site and a false sense of security. Courts have consistently declined to treat an installed overlay as evidence of compliance. The widget isn’t a shield. In a growing number of cases, it’s a flag.

If you’ve been sued while using an accessibility widget, you are not an unlucky outlier. You are the pattern.

What changed after the FTC fine – and what didn’t

Watch the language. After the April 2025 order, accessiBe’s marketing quietly shifted from “make your website fully compliant” to softer phrasing like “align with WCAG 2.1/2.2 Level AA standards.” That hedge is the FTC compliance position – it’s what a company says when it’s legally barred from promising the thing it used to promise.

The technology didn’t change. The architecture that makes overlays fail at the source-code level is exactly the same as it was in 2024. What changed is that one regulator finally made the biggest player stop saying the quiet part out loud. The marketing got more careful. The product did not get better.

What to do if you’re running an overlay right now

The instinct is to panic and rip the widget off your site this afternoon. Resist that for about a day – just long enough to do it in the right order. Here’s the sane sequence:

1. Capture a baseline. Before you change anything, get a manual WCAG 2.2 AA audit – a human navigating your site with a keyboard and a screen reader, not a script – so you have a documented record of what’s actually broken underneath the overlay. This is the difference between an accessibility overlay and a manual audit: one hides the problems, the other documents them so they can be fixed. It also gives you evidence of good-faith effort if a demand letter is already in your inbox.
2. Remove the overlay. Once you’ve got that baseline, take the widget down. Don’t keep treating it as protection – the data is clear that it isn’t, and every day it stays up is another day of false comfort, a possible privacy liability (overlays that auto-detect assistive technology can expose a user’s disability status, creating GDPR and CCPA exposure), and one more thing a plaintiff’s attorney can point to. You don’t need a finished remediation plan to pull it; you just need the baseline.
3. Remediate at the source. Now do the real work: fix the actual HTML, ARIA, and component code your audit flagged. Those fixes are permanent, they work for every assistive technology, and they don’t depend on a script winning a race against a screen reader.

That’s the whole path. Baseline, remove the widget, fix the site for real.

The bigger picture

The reality is that accessibility was never going to have a one-line-of-code answer, because accessibility isn’t a bug to be patched – it’s a quality of how a thing is built. You can’t bolt inclusion on after the fact any more than you can bolt on trustworthiness or good design. The FTC fine didn’t reveal anything the disability community hadn’t been saying loudly since 2020. It just, for once, made it official.

The good news is that the alternative isn’t mysterious or out of reach. It’s the same thing it’s always been: test your site the way disabled people actually use it, fix what’s broken, and verify the fix. That’s not a widget. That’s just doing the work – and it’s the only thing that’s ever actually worked.

Frequently asked questions

Do accessibility overlays make my website ADA compliant?
No. The FTC fined accessiBe $1 million in 2025 specifically for claiming its automated overlay could make sites WCAG-compliant. Overlays modify your page after it loads rather than fixing the underlying code, so they cannot guarantee compliance – and courts have repeatedly declined to treat an installed overlay as proof of it.

Can I still get sued if I have an accessibility widget installed?
Yes. In 2025, businesses running overlays were sued every single month – roughly 1,400 such cases across the year, and EcomBack found nearly 25% of all U.S. web accessibility lawsuits targeted sites that already had a widget installed. It was the same story in 2024. An overlay does not prevent a lawsuit and is not a legal defense.

What’s the difference between an overlay and a manual accessibility audit?
An overlay is automated JavaScript that attempts to patch issues at page load. A manual audit is a human testing your site with assistive technology, documenting real WCAG failures, and giving your developers code-level fixes. The overlay hides problems; the audit resolves them at the source.

Should I remove accessiBe (or another overlay) from my website?
Yes – and you don’t need to wait long to do it. Get a manual WCAG 2.2 AA audit first so you have a documented baseline of what’s broken underneath it, then take the widget down promptly. You don’t need a finished remediation plan to remove it – leaving it up just preserves the false sense of protection and the privacy and legal exposure that come with it. Once it’s off, fix the issues in your actual source code.

Are overlay font-size and contrast controls useful?
Rarely. Users who need larger text or higher contrast almost always already have those controls built into their operating system or browser, and they work across every site – not just yours. The overlay’s version is, at best, redundant.

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Running an overlay and not sure what’s actually broken underneath it? Get a real audit – we’ll test your site the way your users do, and tell you the truth.

If your business sells products or services to consumers in the European Union, the European Accessibility Act (EAA) almost certainly affects you, even if your company is based outside the EU. The law has applied since 28 June 2025, so this is no longer a future deadline: it is the current rulebook.

Here is a plain-language look at what the EAA covers, who it applies to, and what to do next.

What is the European Accessibility Act?

The EAA (Directive (EU) 2019/882) sets common accessibility requirements for a wide range of everyday products and services, so that people with disabilities can use them on an equal basis. Every EU member state has written it into national law, which means the requirements, and the penalties for ignoring them, apply across the entire EU market.

Who does it apply to?

The EAA applies to businesses of any size that sell covered products or provide covered services to EU consumers, wherever the business itself is based. Covered categories include:

• E-commerce: any website or app selling to EU consumers
• Consumer banking and financial services
• Smartphones, computers, and operating systems
• E-books and e-readers
• Audiovisual media services, such as streaming platforms and their apps
• ATMs, payment terminals, ticketing machines, and other self-service terminals
• Telephone, messaging, and emergency communication services
• Consumer-facing parts of air, bus, rail, and waterborne transport: websites, apps, and e-ticketing

There is one significant carve-out: microenterprises that provide services (fewer than 10 employees and no more than €2 million in annual turnover) are exempt. The exemption only covers service providers, though. If you manufacture, import, or distribute covered products, size does not take you out of scope.

The deadlines that matter

• 28 June 2025: the EAA applies to all new products placed on the EU market and all services provided to EU consumers from this date.
• 28 June 2030: service contracts signed before June 2025 may run unchanged until they expire, but no later than this date.
• Self-service terminals deployed before June 2025 may stay in service until the end of their economically useful life, up to a maximum of 20 years.

In practice: if your website or app is in scope and not yet accessible, you are already late. The transition periods cover pre-existing contracts and hardware, not websites and apps serving customers today.

What does compliance look like?

For websites and apps, conformity is judged against EN 301 549, the European standard harmonized for the EAA, which for web content maps to WCAG 2.1 Level AA (with WCAG 2.2 the sensible target for new work). The EAA also expects documentation: accessibility information in your terms and conditions, conformity documentation for products, and processes that keep things accessible as they change. A workable plan looks like this:

1. Audit your product, website, or app against WCAG 2.1 AA and EN 301 549.
2. Fix what the audit finds, prioritizing blockers for keyboard and screen reader users.
3. Publish the required accessibility documentation.
4. Build accessibility checks into your release process so you stay compliant.

Each member state sets its own enforcement and penalties, and several allow substantial fines. Consumers and disability organizations can also file complaints directly with national authorities.

Not sure where you stand?

An accessibility audit will tell you exactly how your product or site measures up against the EAA’s requirements, and our consulting team can turn the findings into a remediation plan that fits your roadmap. If you need formal documentation for procurement, we prepareVPATs and ACRs as well.