The European Accessibility Act (EAA, Directive (EU) 2019/882) has been enforceable since 28 June 2025. For a large share of digital products and services sold to EU consumers, accessibility is now a legal obligation rather than a best practice. This page explains, in plain terms, what the EAA requires, who it covers, what non-compliance actually risks today, and the practical steps to become and stay compliant.
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The EAA is an EU directive adopted in 2019 to harmonise the previously fragmented accessibility rules of individual member states and to guarantee people with disabilities equal access to everyday products and services across the single market. Member states had to transpose it into national law by 28 June 2025, the date it became enforceable. Because it is a directive rather than a single regulation, each country enforces it through its own national law, its own authorities, and its own penalty structure.
The EAA applies to economic operators — manufacturers, importers, distributors, and service providers — that place covered products or services on the EU market for consumers. Crucially, it applies based on where you sell, not where you are based: a business headquartered outside the EU that serves EU consumers is still in scope.
Covered products include computers and their operating systems, smartphones, self-service terminals (ATMs, payment terminals, ticketing and check-in machines), e-readers, and consumer equipment for digital television.
Covered services include e-commerce, consumer banking services, electronic communications, access to audiovisual media services, e-books, and passenger transport services (including their websites, apps, ticketing and real-time information).
Sectors most affected: e-commerce and retail, banking and financial services, insurance and other consumer-facing financial digital services, telecommunications, transport, and media — plus any B2B or B2G vendor whose customers will require conformance as part of procurement.
Microenterprise exemption: service providers with fewer than 10 employees and an annual turnover under €2 million are exempt for services. If you exceed either threshold, the exemption does not apply.
The EAA sets functional accessibility requirements but does not itself spell out technical criteria. Conformity is instead presumed when you meet the harmonised European standard EN 301 549, which incorporates the Web Content Accessibility Guidelines (WCAG) — currently Level AA of WCAG 2.1, with alignment toward WCAG 2.2 underway. In practice, the most reliable path is to meet WCAG 2.2 Level AA across your websites, mobile apps, and documents. EN 301 549 also adds requirements for software, hardware, and documents that go beyond web pages alone.
Meeting the standard is necessary but not the whole obligation. National transposition laws also require organisations to manage accessibility on an ongoing basis, publish an accessibility statement, and provide a route for users to file complaints.
The Directive does not set fine amounts. Article 30 requires only that penalties be "effective, proportionate and dissuasive", which is why the numbers vary so widely between countries. As of early 2026, no fines have yet been publicly issued under any EAA-transposed law: enforcement is in an early, largely administrative phase of warnings, complaints, and corrective orders — a pattern that closely mirrors the first year of the GDPR. That does not mean the risk is low. Private legal action and warning letters have already begun, and each year of operation builds a record that later enforcement can draw on.
| Country | Maximum / notable penalty | Basis |
|---|---|---|
| Germany | Up to €100,000 per infringement | BFSG (Accessibility Strengthening Act) |
| Spain | Up to €1,000,000 for very serious infringements; business activity may be suspended for up to 3 years | Law 11/2023 (tiered fines) |
| Ireland | Fines plus criminal liability — up to roughly €60,000 and/or up to 18 months imprisonment (the only EU state with criminal penalties) | Irish EAA transposition |
| Italy | Up to €40,000 or up to 5% of turnover | Stanca Law framework (Decree 82/2022) |
| Most other states | Administrative fines commonly in the €5,000–€100,000 range, often with daily penalties for unresolved issues | National transpositions |
Figures change and several country amounts circulate in vendor tables without a primary-law citation, so verify against the specific national transposition for the markets you operate in. Note also that the frequently quoted "€250,000 per breach" and "€3 million" figures do not appear in the Directive itself — treat them with caution. Because each national authority can enforce independently, a single non-compliant service can face action in several markets at once.
France. In 2025, disability organisations sent formal legal notices to major retailers and, when those went unanswered, filed emergency injunctions before the Paris court. As of 2026 the cases remain pending — no ruling and no fine — but they show that early enforcement is being driven by civil society, and that it targets both websites and mobile apps.
Germany. Within weeks of the BFSG taking effect, e-commerce operators began receiving private warning letters (Abmahnungen) citing accessibility violations. Many were assessed as legally weak, but responding to them still creates immediate legal cost and exposure.
Netherlands. Enforcement is distributed across several authorities covering e-commerce, financial services, products, media, and transport, alongside self-reporting obligations.
The takeaway echoes the GDPR experience: the first phase is quiet and procedural, but it establishes accountability over time. Accessibility is increasingly treated as an ongoing responsibility, so a single audit or a static accessibility statement now carries limited weight on its own.
Corpowid is an end-to-end digital accessibility and compliance partner — not a standalone overlay. We combine AI automation with expert human remediation to bring your websites, mobile apps, and documents into WCAG 2.2 and EN 301 549 conformance, then keep them there with continuous monitoring. You receive audit-ready reporting and a maintained accessibility statement that document your conformance journey as clear proof of effort.
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The EAA has been enforceable since 28 June 2025. From that date, EU member states apply it through their own national transposition laws.
Yes. Any business that offers covered products or services to consumers in the EU falls within scope, regardless of where it is headquartered.
Conformity is presumed by meeting EN 301 549, which incorporates WCAG. In practice, targeting WCAG 2.2 Level AA across web, apps, and documents is the most reliable path.
As of early 2026, no fines have been publicly issued under EAA-transposed laws. Enforcement is in an early, mostly administrative phase, but private legal action and warning letters have already begun.
No. Overlay widgets do not fix the underlying code or remediate documents. The EAA requires genuine, code-level conformance, ongoing accessibility management, and a published accessibility statement.
Corpowid has been recognized by Gartner, a leading global research and advisory firm, for our innovation and performance in digital accessibility. These badges reflect our commitment to creating inclusive, AI-powered web experiences.
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