EAA Year One: What Actually Happened
The European Accessibility Act became enforceable on 28 June 2025. It has now been in effect for over a year.
Before enforcement began, predictions ranged from "nothing will happen" to "mass fines within weeks." The reality has been somewhere in between: structured, methodical, and building momentum.
Here is what actually happened in the first twelve months.
The headline numbers
- Zero fines issued across the entire EU in year one
- 28 proactive investigations launched by Sweden's PTS (Post and Telecom Authority)
- One court ruling - the first EAA-related judicial decision
- Three countries with active enforcement proceedings: France, Sweden, and Norway
- 27 member states have transposed the EAA into national law
The absence of fines does not mean the absence of enforcement. Regulators have spent year one building infrastructure, running pilot inspections, and establishing precedent.
Country-by-country enforcement
Sweden - the most active regulator
Sweden's PTS has been the most aggressive enforcement body. In year one, PTS launched 28 proactive investigations targeting e-commerce platforms. Their approach is systematic: they published a prioritised list of sectors and are working through it.
PTS inspections focus on EN 301 549 conformance of checkout flows, product pages, and account management. Businesses that fail inspection receive a remediation deadline. Non-compliance after the deadline triggers financial penalties of up to approximately SEK 10 million (around 900,000 euros).
No fines have been issued yet, but remediation deadlines from the first batch of inspections are approaching.
France - first to court
France has taken a litigation-first approach. The DGCCRF (consumer protection authority) filed lawsuits against major retailers whose e-commerce sites failed accessibility requirements. These are the first EAA-related court proceedings anywhere in the EU.
French penalties can reach up to 75,000 euros per infringement for legal entities, with daily penalties for continued non-compliance.
Norway - daily penalties
While not an EU member, Norway adopted the EAA via the EEA Agreement. Norwegian authorities have issued daily penalties of NOK 50,000 (approximately 4,300 euros per day) for non-compliant health portals. This makes Norway the first country to impose actual financial consequences under EAA-equivalent legislation.
Netherlands - ramping up
The Dutch Authority for Digital Infrastructure (RDI) announced active enforcement for the second half of 2026. Businesses that failed to submit mandatory non-conformance reports by October 2025 have been prioritised for audit.
Germany - cautious approach
Germany's market surveillance authority (Bundesnetzagentur) has focused on guidance rather than enforcement in year one. They published detailed compliance guides and are running awareness campaigns before shifting to inspections.
What regulators are checking
Across all active enforcement countries, the pattern is consistent. Regulators are checking:
- Checkout flows - can a user complete a purchase using only a keyboard? Are form fields labelled? Are errors identified accessibly?
- Product information - do images have alt text? Is pricing information available to screen readers?
- Authentication - can users log in and manage accounts with assistive technology?
- Accessibility statements - does the business publish a conformance statement as required by the EAA?
Notably, regulators are not yet testing complex WCAG criteria that require manual evaluation. They are starting with issues that can be detected through automated scanning and basic manual checks.
The penalty landscape
EAA fines vary significantly by member state because each country defines its own penalty structure:
| Country | Maximum fine |
|---|---|
| Spain | 1,000,000 euros |
| Hungary | 1,260,000 euros |
| Sweden | ~900,000 euros |
| France | 75,000 euros per infringement |
| Ireland | 60,000 euros |
| Poland | 10% of turnover or ~21,000 euros |
Beyond financial penalties, authorities can order product withdrawal from the market, ban non-compliant services, require mandatory accessibility audits, and publicly name non-compliant organisations.
What to expect in year two
Based on the trajectory of year one, here is what is likely in the next twelve months:
More fines. Sweden's remediation deadlines from the first batch of inspections will expire, and some businesses will not have remediated in time. France's court proceedings will produce rulings. Norway has already shown willingness to impose daily penalties.
Wider sector coverage. Year one focused on e-commerce. Year two will likely expand to banking, transport, and telecommunications, all explicitly covered by the EAA.
Cross-border coordination. The European Commission's Administrative Cooperation group has been meeting throughout year one to coordinate enforcement approaches. Expect more consistent standards across member states.
Complaint-driven enforcement. As public awareness grows, consumer complaints will become a significant enforcement trigger alongside proactive investigations.
What this means for your business
If you sell digital products or services to EU consumers, the enforcement trajectory is clear: regulators are building capacity, establishing precedent, and moving toward financial penalties.
The practical steps have not changed:
- Scan your site to establish a baseline. Lumi checks over 350 rules across five engines.
- Fix critical and serious issues first. These are the categories regulators are checking.
- Publish an accessibility statement. This is a specific EAA requirement that regulators are already verifying.
- Monitor continuously. Accessibility regresses with every deployment. Automated scanning on a schedule catches regressions before a regulator does.
- Get a manual audit for the issues automation cannot catch. This is particularly important if you operate in a sector that regulators have explicitly prioritised.
For a detailed breakdown of whether the EAA applies to your business, use our EAA Scope Checker. For country-specific guidance, see our EAA country guides.
