EAA fines by country range from roughly €21,000 in Poland (or 10% of turnover) to €1,000,000 in Spain and a turnover-linked cap of HUF 500 million (around €1.3 million) in Hungary, with enforcement active since 28 June 2025. Every EU member state has transposed the European Accessibility Act (Directive 2019/882) into national law with its own fine ranges, enforcement agencies, and additional sanctions. In France, the disability associations ApiDV and Droit Pluriel sent formal notice to four major retailers in July 2025 and took them to emergency court proceedings in November 2025 over inaccessible e-commerce sites — before any regulator had issued a fine. Sweden's PTS, meanwhile, is reviewing accessibility at 28 named e-commerce platforms. This guide gives you the sourced, country-by-country breakdown of fines, enforcement agencies, real cases, and what to do to stay compliant — every figure below links to the law or regulator that confirms it.
EAA Sanctions, Fines and Penalties at a Glance
Last fact-checked: 2 October 2026 against national transposition laws.
EAA fines by country range from roughly €21,000 (Poland) to €1,000,000 (Spain) and a turnover-linked cap of around €1.3 million (Hungary), with enforcement active since 28 June 2025. Each EU member state sets its own penalties — the Directive requires "effective, proportionate and dissuasive" sanctions.
| Country | Maximum Fine | Enforcement Agency | Additional Sanctions | Source |
|---|---|---|---|---|
| Hungary | HUF 500,000,000 cap (~€1.3M) or 5% of net revenue | Sector regulator (consumer protection authority, NMHH, etc.) | Base fine HUF 15,000–500,000,000 | Act XVII of 2022 |
| Spain | €1,000,000 (muy grave) | Ministry of Social Rights and 2030 Agenda / regional market-surveillance authorities | Three-tier: leve ≤€30,000 / grave €30,001–€90,000 / muy grave ≤€1,000,000 | RDL 1/2013 |
| Netherlands | No EAA-specific amount published by ACM | ACM (e-commerce, electronic communications) | Duty to report non-compliance to ACM within 1 week (critical/serious) or 1 month (moderate/minor) | ACM |
| Sweden | SEK 10,000,000 (~€900,000) | PTS (Post- och telestyrelsen) | Sanction fee range SEK 10,000–10,000,000 | Lag (2023:254) |
| Germany | €100,000 (serious) / €10,000 (other) | MLBF AöR (Magdeburg) | Plus competitor Abmahnung risk under UWG | §37 BFSG |
| Austria | €80,000 (large enterprises) | Sozialministeriumservice | Reduced to €50,000 (SME); €16,000–€40,000 for lesser breaches | §36 BaFG |
| Ireland | €60,000 + up to 18 months (indictment) | CCPC / ComReg | Summary conviction: €5,000 + up to 6 months | S.I. No. 636/2023 |
| France | €7,500 per offence for a company (5th-class contravention), cumulative | DGCCRF | Separate Arcom regime (up to €50,000) covers public-sector websites only | DGCCRF / Décret 2023-931 |
| Portugal | ~€44,891 (very serious, legal entity) | ASAE / sector regulators (ANACOM, Banco de Portugal, CMVM, ERC) | Serious (legal entity): €12,000–€24,000 | Decreto-Lei 82/2022 |
| Italy | €40,000, or 5% of turnover (companies >€500M revenue) | AgID | + €2,500–€30,000 for non-cooperation with the authority | D.Lgs. 82/2022 |
| Poland | ~€21,000 (10× avg wage) or 10% of turnover | PFRON (President) / sector market-surveillance bodies | Compliance call required before any fine | Act of 26 April 2024 |
Grace periods apply for some product categories under Directive 2019/882, Article 32 (self-service terminals already lawfully in service before 28 June 2025 may stay in use for the rest of their economically useful life). Covered services include e-commerce sites, banking apps, transport ticketing, e-books, telephony, and ATMs.
Key Data at a Glance
EAA Fines & Penalties by Country: Verified Breakdown
Sources: national transposition laws (linked in the table above), EU Directive 2019/882
What the European Accessibility Act Actually Requires
The European Accessibility Act (Directive 2019/882) is an EU directive that mandates accessibility for digital products and services sold to or used by EU consumers. It became enforceable on June 28, 2025, after a three-year transition period that many businesses treated as optional. That was a mistake. The technical standard underpinning the EAA is EN 301 549, which maps directly to WCAG 2.1 Level AA. If your website, mobile app, e-commerce platform, banking interface, or transport ticketing system does not meet WCAG 2.1 AA, you are non-compliant with the EAA. Though enforcement currently references WCAG 2.1, WCAG 3.0 is currently in Working Draft status and is expected to revise the compliance baseline over the coming years — factoring it into your remediation roadmap now avoids rework later. The directive covers a broad range of products and services: computers and operating systems, smartphones, self-service terminals like ATMs and ticket machines, e-readers, e-commerce websites and apps, banking and financial services, electronic communications, audiovisual media services, e-books, and transport information and ticketing. If you sell any of these into the EU market, the EAA applies to you regardless of where your company is headquartered. There is one meaningful exemption, set out in Directive 2019/882, Articles 3(23) and 4(5): microenterprises — fewer than 10 persons employed, AND an annual turnover or annual balance sheet total not exceeding €2 million — are exempt from the accessibility requirements for services. Both the headcount test and the financial test must be met. The exemption applies to services only; it does not cover product requirements. The directive requires each EU member state to establish penalties that are "effective, proportionate and dissuasive." That specific legal language matters. It means regulators cannot simply send polite letters indefinitely. They must impose consequences that actually change behavior. And as the cases below show, it isn't always a regulator that moves first — in France, it was disability associations acting through the courts.Country-by-Country Penalty Breakdown
Each EU member state transposed the EAA into national law with its own fine ranges, enforcement agencies, and procedural rules. The result is a patchwork that businesses operating across multiple EU markets must navigate carefully. Below is the breakdown for every country whose fine structure we could verify directly against its national transposition law.
Germany: Fines Up to €100,000 Plus Competitor Lawsuits
Maximum fine: up to €100,000 for serious violations — placing a non-compliant product on the market or providing a non-compliant service — and up to €10,000 for other breaches, under §37 BFSG. Enforcement agency: the Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen (MLBF), a public-law institution based in Magdeburg that began operating on 26 September 2025, under the BFSG (Barrierefreiheitsstärkungsgesetz). What makes Germany distinctive is the Abmahnung risk. Under German unfair competition law (UWG), a competitor that meets accessibility requirements can file a cease-and-desist claim against a non-compliant rival, arguing that the accessibility failure constitutes an unfair competitive advantage. The practical risk in Germany is therefore not just a regulatory fine but competitor litigation — German legal practice already has well-established procedures for Abmahnung claims in other areas of unfair competition law, and accessibility is a natural extension of that. Germany also requires an accessibility statement (Barrierefreiheitserklärung) for all covered services. A missing or inadequate statement falls under the lower, €10,000 fine tier rather than the €100,000 tier reserved for substantive accessibility failures — but it remains the most visible, and easiest to check, compliance gap.France: €7,500 per Offence — and the EU’s First Major Court Case
For private businesses, the EAA requirements for products and consumer services are enforced by the DGCCRF under the Consumer Code. Under Décret n° 2023-931 a breach is a fifth-class contravention: up to €7,500 per offence for a company (€1,500 for an individual), and fines are counted per breach, so they add up. France also has a separate, older regime run by Arcom — up to €50,000, plus €25,000 for a missing accessibility statement, under Ordonnance n° 2023-859 — but it targets public-sector websites, not your webshop. No DGCCRF fine under these rules has been made public yet. The real test case so far has come from civil society, not the regulator. In July 2025, the disability associations ApiDV and Droit Pluriel sent formal notice to four major retailers — Auchan, Carrefour, E.Leclerc and Picard Surgélés — over inaccessible e-commerce platforms. When the retailers didn’t remediate, the associations filed an emergency court petition (référé) on 12 November 2025, citing 31 identified non-conformities including insufficient contrast, missing text alternatives, and keyboard-inaccessible components. This matters beyond France: a low published fine ceiling doesn’t mean low real-world risk. Disability associations with standing under the Consumer Code can take a case to court well before any administrative fine is ever calculated.Spain: Up to €1,000,000 for Very Serious Violations
Fine ranges, under the supplementary regime of Real Decreto Legislativo 1/2013 (applied via Ley 11/2023, Spain’s EAA transposition): minor (leve) violations up to €30,000, serious (grave) violations €30,001 to €90,000, and very serious (muy grave) violations €90,001 to €1,000,000. Enforcement sits with the Ministry of Social Rights and 2030 Agenda at national level, and with the market-surveillance authority each autonomous community designates for products and services within its territory — not, as is sometimes assumed, the data-protection authority (AEPD), which has no role in EAA enforcement. Spain has the highest fixed maximum fine among the countries we verified, though several other member states’ turnover-linked penalties can exceed it for larger companies. Because Ley 11/2023 leans on this pre-existing disability-rights framework, Spain already has institutional experience applying these tiers — just not yet, as far as we could verify, to an EAA accessibility case specifically.Italy: €40,000, or 5% of Turnover for Large Companies
Standard fines: €5,000 to €40,000 per violation under Decreto Legislativo 82/2022, Article 24. A separate €2,500 to €30,000 fine applies if the operator fails to cooperate with the surveillance authority or ignores required corrective measures. Large-company penalty: up to 5% of annual turnover for companies with more than €500 million in annual revenue. Enforcement agency: AgID (Agenzia per l’Italia Digitale). The 5% turnover rule creates real exposure for multinationals even though Italy’s fixed fines are among the lowest in the EU: a company with €500 million in annual revenue could face a €25 million fine for a single serious, sustained violation.Netherlands: No Published Fine Ceiling, but a Duty to Self-Report
Enforcement agency for e-commerce and electronic communications services: ACM (Autoriteit Consument & Markt), since 28 June 2025. ACM has not published an EAA-specific fine ceiling; it says its enforcement "depends on the magnitude of the problems, and on what steps companies are taking to solve those problems." We have left out the €900,000 / 10%-of-turnover figure that circulates online because we could not tie it to the Dutch EAA rules. What the Netherlands does have is unusual: a duty to self-report. If your webshop is not accessible and you cannot fix it immediately, you must notify ACM — within one week for problems with a critical or serious impact, within one month for moderate or minor ones. Few other countries put the burden of disclosure on the business itself. ACM is also measuring. In a report published on 24 March 2026, it found that 61% of the roughly 100 largest Dutch webshops it tested were not digitally accessible, and warned that companies which fail to make sufficient improvements risk enforcement.Sweden: SEK 10 Million and a Named Review of 28 Platforms
Maximum fine: SEK 10,000,000 (around €900,000), with a sanction fee that can be set anywhere between SEK 10,000 and SEK 10,000,000 depending on severity. Lag (2023:254) gives PTS (Post- och telestyrelsen) supervisory responsibility for electronic communications, banking services and e-commerce. PTS is running a named, active review: as of its most recent update it is examining 28 e-commerce platforms, focusing on homepages, search functions and product pages, through 2025 and into 2026. A non-compliant company can be issued an injunction (föreläggande) that carries a financial penalty (vite) if not followed — but PTS has not, as far as we could verify, issued a sanction fee yet.Ireland: The Only EU Country With Prison Terms
Maximum penalty: up to €60,000 and/or up to 18 months’ imprisonment on conviction on indictment. Summary conviction: up to €5,000 and/or up to 6 months’ imprisonment. Source: S.I. No. 636 of 2023 (European Union (Accessibility Requirements of Products and Services) Regulations 2023), enforced by the CCPC and ComReg depending on sector. Ireland is the only EU member state in our verified set with a custodial sentence attached to EAA non-compliance. Where an offence is committed with the consent, connivance or neglect of a director, manager or other officer, that individual can be held personally liable alongside the company. Ireland’s concentration of EU-headquartered tech companies makes this provision worth taking seriously even though the fine itself — €60,000 maximum — is modest by EU standards; the imprisonment clause and the reputational cost of a criminal prosecution change the calculus.Poland: Up to ~€21,000 or 10% of Turnover
Maximum fine: up to ten times the average monthly wage in the national economy for the previous year. Based on the 2025 figure of 8,903.56 PLN announced by the President of Statistics Poland (GUS) in Monitor Polski, that ceiling is 89,036 PLN — about €21,000. Alternative cap: the penalty may not exceed 10% of the company’s turnover in the preceding financial year. Enforcement: the President of PFRON (Państwowy Fundusz Rehabilitacji Osób Niepełnosprawnych, the State Fund for Rehabilitation of Disabled Persons) holds general oversight and can request information, run inspections, and receive complaints; sector-specific market-surveillance bodies handle specialised product categories. Poland’s transposition is the Act of 26 April 2024 on ensuring compliance with accessibility requirements for certain products and services, in force since June 28, 2025. On paper Poland has one of the lowest fixed maximum fines in the EU, but the 10%-of-turnover ceiling means large companies face exposure far beyond the headline figure — the same structural risk seen in Italy. Enforcement is progressive. PFRON first issues a call to bring the product or service into compliance, and financial penalties follow only for persistent or repeated breaches. The amount is set according to the scope of the violation, including its gravity, the number of non-compliant products or services, and the number of people affected.Austria, Portugal, and Hungary
Austria imposes fines of up to €80,000 per violation for large enterprises under §36 of the Barrierefreiheitsgesetz (BaFG), reduced to €50,000 for SMEs, with lower tiers under §36(2) and (3) down to €16,000 for lesser or procedural breaches. Enforcement sits with the Sozialministeriumservice, which can also order a non-compliant product or service withdrawn from the market. Portugal sets its sanctions in Decreto-Lei n.º 82/2022, Article 29: serious violations by legal entities carry fines of €12,000 to €24,000; very serious violations run from €24,000 up to the general ceiling set by Portugal’s framework misdemeanour law (Decreto-Lei n.º 433/82) — approximately €44,891 for a legal entity. Depending on the product or service, enforcement falls to ASAE (general market surveillance), ANACOM (electronic communications), Banco de Portugal (financial services), CMVM (investment services) or ERC (audiovisual media). Hungary has the highest potential fine among the countries we verified. Under Act XVII of 2022, an economic fine of HUF 15,000 to HUF 500,000,000 applies, and a non-SME economic operator with annual net revenue above HUF 100 million can additionally face an administrative fine of up to 5% of annual net revenue, capped at HUF 500,000,000 — roughly €1.3 million at October 2026 exchange rates (the euro figure moves with the forint, so treat it as an approximation, not a fixed ceiling). Supervision is split by sector among Hungary’s consumer protection authority, the Budapest Capital Government Office, NMHH (telecoms) and other sector regulators.Enforcement Mechanisms: How Fines Actually Get Imposed
Understanding the fine amounts is only half the picture. How enforcement actually works determines your real risk level.
Across the countries we reviewed, the pattern is broadly similar: a complaint or inspection triggers a review, the regulator (or, as in France, a private party with legal standing) issues a formal notice, and a fine or court order follows only if the business doesn't remediate. Austria's BaFG and Poland's accessibility act both explicitly require a prior compliance request before any financial penalty.
The trigger mechanisms vary by country. Sweden's PTS runs its own named inspections of specific e-commerce platforms; France's enforcement so far has come from disability associations using their standing under the Consumer Code rather than from a regulator-led sweep. In most other countries, complaints from individuals and organisations remain the primary route into an enforcement file.
Appeal procedures follow each country's own administrative or judicial law. We did not find a reliable, up-to-date comparison of appeal-stay rules across all EU member states, so we're not going to invent one — check the relevant national regulator's own procedural guidance before assuming a fine is final.
Who Can File Complaints Against You
The EAA creates multiple pathways for enforcement actions, and they do not all start with regulators.
Individuals with disabilities can file complaints directly with national enforcement authorities. In France, the associations ApiDV and Droit Pluriel showed in 2025 that an organisation with standing can skip the regulator altogether and go straight to civil court — their référé against Auchan, Carrefour, E.Leclerc and Picard Surgélés is the clearest example of this route in the EU so far.
Competitors can use the EAA as a competition-law lever in Germany, where the Abmahnung mechanism under the UWG lets a compliant business sue a non-compliant rival directly, arguing unfair competitive advantage. This means enforcement in Germany can come from business rivals as much as from the market-surveillance authority.
Suppliers and business customers in B2B relationships are increasingly including EAA compliance requirements in procurement contracts, creating contractual liability exposure separate from regulatory enforcement. A supplier found non-compliant may face contract termination and damages claims on top of any regulatory penalty.
Cross-Border Enforcement and Extraterritorial Reach
The EAA applies where the service is offered, not where the company is headquartered. This mirrors the extraterritorial logic of GDPR and creates similar compliance obligations for non-EU companies.
A US company with a French-language e-commerce site targeting French consumers is subject to French EAA enforcement regardless of whether it has any physical presence in France. The test is whether the service is offered to EU consumers, not whether the provider is established in the EU.
Directive 2019/882 requires member states' market-surveillance authorities to cooperate and exchange information, though the mechanism is less centralised than GDPR's lead-supervisory-authority model — there is no single “lead regulator” for a pan-EU EAA case. In practice, a company operating across several EU markets should expect that an enforcement notice in one country is discoverable by regulators in another, even without a formal joint procedure.
Real Enforcement Cases Since June 2025
Enforcement since the 28 June 2025 deadline has produced a handful of verifiable actions — fewer, and different in character, than some early coverage suggested. France has the highest-profile case. The disability associations ApiDV and Droit Pluriel sent formal notice to four major retailers — Auchan, Carrefour, E.Leclerc and Picard Surgélés — on 7 July 2025, then filed an emergency court petition on 12 November 2025 after the retailers failed to remediate 31 identified non-conformities on their e-commerce platforms. This is civil litigation brought by associations under the Consumer Code, not a regulator's decision — no French regulator fine has been made public. Sweden's PTS is reviewing 28 e-commerce companies for accessibility compliance, with the review running through 2025 and into 2026. No sanction fees have been reported yet; PTS can follow a review with an injunction (föreläggande) backed by a financial penalty if a company doesn't correct what it finds. We could not verify claims circulating about Norway issuing daily EAA penalties, a specific Dutch ACM complaint against a named bank, or a wave of hundreds of German Abmahnungen — so we've left them out rather than repeat unsourced numbers. The two cases above are the only ones we could confirm against a primary or regulator source as of 2 October 2026.Penalty Comparison: Strictest to Most Lenient
Ranking EU countries by severity of their EAA penalty regimes means weighing maximum fines, additional sanctions, and how severity is calculated — a fixed amount versus a turnover-linked one.
By fixed maximum fine, the strictest regimes we verified are Hungary (HUF 500 million cap, ≈€1.3 million, or 5% of net revenue), Spain (€1,000,000 for very serious infractions), and Sweden (SEK 10 million, around €900,000).
Ireland is the outlier: a relatively low €60,000 maximum fine, but the only verified criminal sanction in the group — up to 18 months' imprisonment on indictment.
Germany's regulatory fine maximum is moderate (€100,000), but the Abmahnung mechanism means enforcement there can also come from competitors under unfair-competition law, independent of anything the MLBF does.
The most lenient fixed maxima we verified are Poland (~€21,000, tied to ten times the average monthly wage), Italy (€40,000) and Portugal (~€44,891). But turnover-based ceilings change the picture for larger companies: Poland caps at 10% of turnover, and Italy's 5% turnover rule applies to companies above €500 million in annual revenue — so the "lenient" label only holds for smaller businesses.