Reference · EAA enforcement
EAA fines by country: what businesses actually risk in 2026
Last verified: · maintained table, not a blog post
The European Accessibility Act (Directive (EU) 2019/882) sets no fines itself — each member state writes its own penalties. The numbers below separate what national law allows (statutory maximums) from what has actually happened so far. Both matter; they are not the same thing.
The honest summary, first
- As of June 2026, no regulator fine under an EAA transposition law has been publicly reported anywhere in the EU.
- Real enforcement so far is private: cease-and-desist letters (Abmahnungen) in Germany — typically €500–3,000 in legal fees per letter — and the first civil lawsuits in France.
- The Netherlands' authorities (ACM and others) moved to active enforcement from mid-2026, after a mandatory self-reporting window opened in October 2025.
- Statutory maximums range from €7,500 per infraction (France) to €600,000 (Spain, very serious violations).
Statutory maximum penalties by country
| Country | Transposition law | Maximum penalty | Enforcement reality (June 2026) |
|---|---|---|---|
| Germany | BFSG (Barrierefreiheitsstärkungsgesetz) | Up to €100,000 per violation; up to €10,000 for information/documentation failures | Private Abmahnung letters (€500–3,000 legal fees each); e-commerce providers got attention first; no regulator fine reported |
| France | Consumer Code amendments | €7,500 per infraction; €15,000 for repeat offences (confirmed in primary legislation — some vendor tables cite higher unconfirmed figures) | First civil injunctions filed by disability organisations; cases pending, no ruling yet |
| Spain | Ley 11/2023 | €30,000 minor / €150,000 serious / €600,000 very serious; repeat offenders risk up to a 2-year activity ban | No EAA-specific fine reported; Spain has historically fined large companies under prior accessibility law |
| Netherlands | EAA implementation decrees | Reported up to ~€103,000 (vendor reports range €100,000–250,000; primary statute citation varies by sector) | Mandatory self-reporting since October 2025; ACM, RDI, CvdM, ILT and AFM split enforcement by sector; active checks from mid-2026 |
| Austria | BaFG (Barrierefreiheitsgesetz) | Reported up to ~€80,000 for severe violations (lower tiers for documentation failures; SME reductions apply) | No fine publicly reported |
| Poland | Ustawa o zapewnianiu dostępności (2024 transposition) | Reported up to ~€200,000 equivalent (vendor-compiled figure; verify against the act for your case) | No fine publicly reported |
How enforcement actually reaches a business
- A letter, not a fine. In Germany the realistic first contact is an Abmahnung from a law firm acting for a competitor or association — a settlement demand with a deadline, not a regulator decision.
- A complaint to a market-surveillance authority. Authorities must first demand corrective action; fines come after non-cooperation, which is why none have been reported yet.
- A civil claim. France's pending cases show disability organisations using courts directly.
That sequence is why dated audit evidence matters: the cheapest moment to show effort is when the letter arrives — corrective-action windows reward businesses that can document what they found and fixed, and when.
Sources
- Directive (EU) 2019/882 — EUR-Lex (primary)
- Fieldfisher: EAA risks of non-compliance and key authorities
- Level Access: EAA penalties for non-compliance
- Auditsu: EAA fines — confirmed vs. reported figures
- Deque: EAA country compliance data
This page is maintained context, not legal advice. Figures marked "reported" come from vendor compilations where we could not verify the primary statute — treat them as indicative. If you spot an error, email hello@getaccessproof.com and we will correct it.
What agencies do with this
Clients forward these numbers and ask "are we exposed?" AccessProof exists for that moment: a free WCAG 2.1/2.2 scan mapped to EN 301 549, and a €29 white-label audit report with an accessibility-statement draft — the dated document that shows your client took this seriously. Add it to Chrome or see pricing.