European Accessibility Act

EAA penalties and sanctions, country by country

The European Accessibility Act has applied since 28 June 2025, and it does not set a single European fine. Directive 2019/882 delegates penalties to the member states, requiring only that they be effective, proportionate and dissuasive. The result is a range from roughly €18,000 to €500,000 — plus powers that are often more damaging than the money: ordering a service suspended or a product withdrawn from the market.

How EAA enforcement actually works

Enforcement is complaint-driven. A consumer who cannot complete a purchase, book a ticket or read an e-book raises it with the national market surveillance authority. That authority can demand your conformity documentation, set a deadline to remediate, and escalate to a fine or a suspension order if the deadline passes. The fine is the visible part; the deadline is the expensive one, because it arrives with no notice and a remediation programme takes months.

Two documents decide how that conversation goes. The first is a dated accessibility statement declaring your conformance level honestly. The second is evidence — scan results, an audit, a remediation log — showing the claim is measured rather than asserted. Organisations that have both are usually given time to fix. Organisations that have neither are the ones that get fined.

Penalties by member state

Country	National law	Penalties	Enforcement body
Austria	BaFG	Administrative fines up to €80,000.	Sozialministeriumservice and the consumer protection ministry
Belgium	Loi 19/07/2018 + Loi-EAA	Administrative fines and corrective orders; amounts vary by region.	BOSA (federal) and regional digital agencies
Bulgaria	EGA + EAA	Administrative fines per the EAA-implementing legislation.	Ministry of e-Government
Croatia	Zakon 17/2019 + EAA	HRK-denominated administrative fines under the EAA implementing act.	Središnji državni ured za razvoj digitalnog društva
Cyprus	Law 6(I)/2018 + EAA	Administrative fines under EAA-implementing legislation.	Department of e-Communications, Deputy Ministry of Research, Innovation and Digital Policy
Czechia	Zákon 99/2019 + EAA	Up to CZK 5 million for repeated breach of consumer-protection provisions.	Digitální a informační agentura (DIA)
Denmark	Tilgængelighedsloven	Penalty payments and corrective orders; Digitaliseringsstyrelsen publishes a list of monitored sites.	Digitaliseringsstyrelsen
Estonia	PIA + EAA	Administrative penalties under EAA implementation.	Ministry of Economic Affairs and Communications
Finland	Digipalvelulaki	Periodic penalty payments; AVI may publish enforcement decisions.	Etelä-Suomen aluehallintovirasto (AVI)
France	RGAA	Up to 4% of total annual turnover for serious or repeated non-compliance; €25,000 fixed penalty for missing accessibility statement.	DGCCRF (consumer protection) and ARCOM
Germany	BFSG	Up to €100,000 per infringement; market surveillance can also order products withdrawn from sale.	Marktüberwachungsbehörde (state-level market surveillance authorities)
Greece	Law 4727/2020 + EAA	Administrative penalties per the EAA implementing law.	Ministry of Digital Governance
Hungary	Act LXXV/2018 + EAA	Administrative fines per the EAA implementing law; corrective orders by DKÜ.	Digital Government Agency (DKÜ)
Ireland	EAA Regulations 2023	Up to €60,000 or 12 months imprisonment for repeated non-compliance.	CCPC (Competition and Consumer Protection Commission) and NDA (National Disability Authority)
Italy	Stanca + DL 82/2022	Up to 5% of annual turnover; AgID can mandate corrective action and publicly list non-compliant operators.	AgID (Agenzia per l'Italia Digitale)
Latvia	CR 445/2020 + EAA	Administrative penalties; VARAM publishes monitoring results.	VARAM (Ministry of Environmental Protection and Regional Development)
Lithuania	PSIR Act + EAA	Administrative penalties per EAA-implementing act.	Ministry of the Economy and Innovation
Luxembourg	Loi 28/05/2019 + EAA	Administrative penalties per the EAA-implementing act.	Service Information et Presse (SIP) and the Ministry for Digitalisation
Malta	LN 138/2018 + EAA	Administrative penalties under the EAA-implementing act.	MITA (Malta Information Technology Agency)
Netherlands	Tijdelijk Besluit + EAA Wet	Up to 10% of annual turnover for repeat offenders.	Logius (public sector) and ACM (private sector)
Poland	Ustawa 4/2019 + Ustawa EAA	Up to PLN 10,000 per infringement under public-sector law; EAA brings turnover-linked penalties.	Ministerstwo Cyfryzacji and UOKiK
Portugal	DL 83/2018 + EAA	Administrative fines per DL 83/2018; EAA-specific penalties added by transposition.	AMA (Agência para a Modernização Administrativa)
Romania	GD 1112/2018 + EAA	Administrative fines under EAA-implementing law.	ADR (Romanian Digitalisation Authority)
Slovakia	Act 95/2019 + EAA	Administrative penalties per the EAA implementing act.	Ministry of Investments, Regional Development and Informatization
Slovenia	ZDSMA + EAA	Administrative fines for non-compliance.	Ministry of Public Administration
Spain	RD 1112/2018 + Ley 11/2023	Up to €600,000 (very serious infringements) under Ley 11/2023.	OAW (Observatorio de Accesibilidad Web) and consumer protection bodies
Sweden	DOS + EAA-lag	Penalty payments tied to annual turnover; DIGG can issue cease-and-desist.	DIGG (Myndigheten för digital förvaltning) and Konsumentverket
United Kingdom	Equality Act + PSBAR	Civil claims under the Equality Act; uncapped damages on individual claims.	Equality and Human Rights Commission (EHRC) + Cabinet Office GDS

Figures reflect each national transposition of Directive 2019/882 and any pre-existing accessibility law. Amounts are maxima per infringement unless stated otherwise, and national authorities retain discretion. This is a summary for planning, not legal advice — confirm with counsel in your market.

What the fine is calculated against

Most member states treat each non-conforming service — not each WCAG violation — as one infringement, which is why a single inaccessible checkout can carry the full maximum. Aggravating factors that recur across national laws are the duration of the breach, whether the operator was warned before, whether the barrier was disclosed in the accessibility statement, and the size of the business. Voluntary disclosure and a documented remediation plan are the standard mitigating factors.

The cheapest way to stay out of this

Establish a baseline, fix the critical and serious findings, publish an honest statement, and re-scan on a schedule so a theme update does not silently reintroduce a barrier. Start with a free accessibility scan to see where you stand against WCAG 2.1 AA — the standard EN 301 549, and therefore the EAA, points at.

Frequently asked questions

How much is the fine for European Accessibility Act non-compliance?

The EAA itself sets no figure. Directive 2019/882 requires each member state to lay down penalties that are "effective, proportionate and dissuasive", so the amounts are national. In practice they range from roughly €18,000 in Ireland to €500,000 in Italy and Spain, with Germany at up to €100,000 per infringement. Several states additionally allow a service to be suspended or a product withdrawn from sale, which usually costs more than the fine.

Who enforces the EAA?

Market surveillance authorities designated by each member state — for example the state-level Marktüberwachungsbehörden in Germany, AGCM-adjacent bodies in Italy, and national accessibility authorities elsewhere. They act on consumer complaints as well as their own monitoring, and they can demand your conformity documentation.

Can a consumer sue directly under the EAA?

The directive requires member states to give consumers a route to take action before the courts or a competent administrative body. So a complaint typically starts with the market surveillance authority, but national law usually also allows a consumer or a representative organisation to bring proceedings.

Does the EAA apply to small businesses?

Microenterprises providing services — fewer than 10 staff and under €2M annual turnover — are exempt from the service obligations. That exemption does not extend to microenterprises that manufacture, import or distribute covered products, and it does not exempt anyone from national accessibility laws that predate the EAA.

What triggers an enforcement action in practice?

Almost always a consumer complaint about a specific barrier — an unusable checkout, an inaccessible ticketing flow, a PDF-only statement — followed by a request for your accessibility statement and conformity records. An organisation that can produce a dated statement, scan evidence and a remediation plan is in a materially different position from one that cannot.

Next: the EAA compliance hub for platform-specific checklists, or the country law guides for the full national picture.