What really happens if your website breaks the European Accessibility Act?

The European Accessibility Act contains no fine of its own. What you risk depends on the country your customers are in, and so far orders to fix a site have been far more common than penalties.

Published on 11 October 2026 · Libration editorial team · 10 min read

In short The Directive sets no amount; each Member State sets its own penalties, from a few thousand euros to one million. In most systems the authority first has to ask you to fix the problem and give you time to do it. Publicly documented fines are rare so far. What private parties can do differs widely: associations have gone to court in France, while in Germany lawyers send warning letters whose legal basis is untested.

1. Does the EAA apply to you at all?

The European Accessibility Act is Directive (EU) 2019/882. It is not directly applicable law: each Member State has written it into national legislation, and those national laws have applied since 28 June 2025. For websites the important category is "e-commerce services" (Article 2(2)(f)): services provided at a distance through websites and mobile apps, at the individual request of a consumer, with a view to concluding a consumer contract (Article 3(30)). In practice that means online shops and booking or ordering flows. Consumer banking, e-books, parts of passenger transport and electronic communications are covered as well.

Three situations usually fall outside:

Micro-enterprises providing services. Fewer than 10 people and an annual turnover or balance sheet total of no more than EUR 2 million (Article 3(23), Article 4(5)). The exemption does not cover products.
Pure B2B offers. The Directive is about services provided to consumers, meaning natural persons acting outside their trade or profession.
Information-only websites through which no contract with a consumer is concluded. They are generally not e-commerce services in the Directive's sense.

Two further rules matter. Under Article 14 you may depart from a requirement if meeting it would impose a disproportionate burden, but you have to assess this against the criteria in Annex VI, document it, keep the documentation for five years and, unless you are a micro-enterprise, inform the authority. And Article 32 lets service contracts agreed before 28 June 2025 run unchanged until they expire, at the latest until 28 June 2030.

Where you are based is not the test. Law firms consistently describe the EAA as applying to anyone selling to consumers in the EU, whether or not the provider is established there. The United Kingdom is not covered; the Equality Act 2010 applies there instead. Our EAA quick check walks you through these questions, and the article on the EAA explains the scope in more detail.

2. Route 1: the authority

For services, Article 23 obliges every Member State to set up procedures to check compliance, to follow up complaints and to verify that the provider has actually corrected the problem. Article 30 leaves penalties to the Member States. They must be "effective, proportionate and dissuasive" and take into account how serious the non-compliance is and how many people are affected. Article 13(4) adds a duty that is easy to overlook: if you find that your service does not conform, you must correct it and tell the competent authority.

The national results differ considerably. The table shows six countries; the maximum amounts are upper limits, not typical fines.

Country	Authority for online shops	Maximum penalty	First step
Germany	MLBF, a joint market surveillance body of the 16 federal states, based in Magdeburg	Up to EUR 100,000; up to EUR 10,000 for lesser breaches such as information duties	Request to fix the defect by a deadline, then a second request threatening prohibition, then an order to stop the service
France	DGCCRF (consumer protection directorate), with sector regulators	Fine of up to EUR 7,500 for a company (EUR 1,500 for an individual); an injunction can carry a daily penalty payment of up to EUR 3,000	Check, hearing of the business, then an injunction to comply within a set period
Italy	AgID (Agency for Digital Italy)	EUR 5,000 to 40,000; EUR 2,500 to 30,000 for not following the authority's measures	Request for corrective measures within a reasonable period
Spain	Authorities designated by the autonomous communities	EUR 301 to 1,000,000; minor infringements up to EUR 30,000, serious ones up to EUR 90,000	The law sets no fixed period for corrections; a fine requires a formal sanction procedure
Ireland	CCPC (Competition and Consumer Protection Commission)	Summary conviction: fine up to EUR 5,000 and/or up to 6 months' imprisonment. On indictment: up to EUR 60,000 and/or up to 18 months	Notice of a proposed direction with 14 days to respond, then a written direction with a deadline
Sweden	PTS (Post and Telecom Authority)	Penalty fee of SEK 10,000 to 10,000,000	Supervision by the authority; no fee in minor cases

Notice what the systems have in common. In Germany the sequence of requests is written into the law. In Ireland it is not the inaccessible website as such that becomes an offence in this procedure, but ignoring a direction. In Italy a separate fine exists precisely for not following the authority's measures. The fine is the end of a process, and the process starts with a letter and a deadline. Other countries are listed in our overview of the EAA by country.

What has actually happened so far

France. The DGCCRF checked 38 rail-related establishments between April 2025 and March 2026 and responded with corrective and educational measures. Since January 2026 it has been examining around 50 e-commerce businesses. By early September 2026 more than 20 sites had been checked, and corrective or enforcement follow-up was planned for half of them. The authority has not published the kind of follow-up or any amounts. Final results are expected in early 2027. Since December 2025 consumers can report accessibility defects through the state platform SignalConso.
Germany. The MLBF published its market surveillance strategy in January 2026. It relies on automated pre-checks of websites to set priorities. By June 2026 it had received almost 700 complaints, tip-offs and notifications. It publishes no figures on proceedings, and no fine has been publicly documented.
Italy. AgID published guidelines and opened a complaints platform in March 2026, and in May 2026 adopted a regulation on how it checks and sanctions. Cases can be closed without sanction if the provider fixes the defects in time. We found no published sanction.
Sweden. PTS measured 576 websites in 2025 and found shortcomings in all nine sectors examined. It stressed that the measurement was not supervision, and reported no orders or fees.

That does not mean nothing is going on. It means that, in October 2026, nobody outside the authorities can say reliably how many cases are open.

3. Route 2: consumers, associations and competitors

Article 29 requires Member States to let consumers bring a matter before a court or an administrative body. Public bodies and associations with a legitimate interest must be able to act on a consumer's behalf or in support. How this is done is again national. In Ireland a consumer can apply to the Circuit Court for a compliance order. In Germany a consumer or a recognised association can ask the authority to open proceedings.

France is where this route has been used most visibly. Two associations of blind and partially sighted people sent formal notices to four large retailers in July 2025 and took them to court in summary proceedings in November 2025. Two decisions are known:

On 5 May 2026 the court in Lille dismissed the claim against one retailer's e-commerce subsidiary. It applied a turnover threshold of EUR 250 million from older French law, which the subsidiary did not reach. The associations have appealed, according to press reports.
On 4 June 2026 the court in Caen ordered another retailer to make its website and app accessible within six months, with a penalty of EUR 500 per day of delay according to press reports. The retailer had argued that meeting 71 per cent of the French criteria was enough. The court did not accept that.

Neither decision awarded a fine in the usual sense, and both are first-instance summary rulings. The remaining two cases were still open in the reports we found.

Germany has a national peculiarity: the warning letter. Since summer 2025 law firms have been writing to site operators on behalf of alleged competitors, arguing that an inaccessible shop is unfair competition. One published letter from February 2026 demanded about EUR 2,700 for legal fees and an automated test report, citing an empty link, a low-contrast element and a doubtful alternative text. Whether the German accessibility act can be enforced through unfair-competition law at all is undecided: by early September 2026 no court ruling on the question had been published. If you sell to German consumers, this is the letter you are most likely to see. It is not an EAA mechanism.

4. What to do if a letter arrives

From an authority

Note the deadline. It is the most important sentence in the letter.
Check whether the law applies to you, and be ready to prove it if you rely on an exemption.
Fix the defects named and record what you changed and when.
Reply within the deadline, even if not everything is finished.

From a lawyer or an association

Note the deadline and do not let it pass.
Do not sign or pay anything before a lawyer who practises in that country has read the letter.
Check the alleged defects all the same. If they are real, fix them.

5. What really protects you

Not a widget and not a badge. In every procedure described above, the same three things count:

You know where your site stands. An audit report with a date on it.
You are visibly working on it. A list of fixed and open issues.
Your accessibility statement exists and is honest. Article 13(2) requires service providers to publish how their service meets the requirements. It is the first thing a check looks at; see our article on the accessibility statement.

No tool, ours included, makes a website legally compliant. The Caen decision also shows that "mostly accessible" is not a safe place to stop. But if you know your status and work through the defects, you have a good answer to an authority's first letter and something to set against a private claim.

Start with the facts Our free scan checks a page in a few seconds and lists the barriers it finds. Automated tests detect only part of the problems, but they give you a dated starting point.

6. Outlook

The national laws themselves are still moving. On 11 March 2026 the European Commission sent Germany (INFR(2022)0295) and Croatia (INFR(2022)0306) additional reasoned opinions for incomplete transposition of the Directive; Germany responded in July 2026 by amending its implementing regulation. Bulgaria was referred to the Court of Justice in July 2024. In France the appeal in the Lille case should clarify which companies the consumer-law obligation covers, and the DGCCRF's final e-commerce results are due in early 2027. In Germany the first ruling on warning letters is still awaited. The Commission must report on the Directive's application by 28 June 2030. We will update this article when any of this changes.

Sources and notes

Directive (EU) 2019/882 (European Accessibility Act), Articles 2, 3, 4(5), 13, 14, 23, 29, 30, 32 and 33.
Germany: Barrierefreiheitsstärkungsgesetz (BFSG), sections 29, 32 and 37; website of the market surveillance body MLBF; press release of the European Commission's Representation in Germany, 11 March 2026.
France: Code de la consommation, Articles L.412-13 and R.451-4; DGCCRF guidance for businesses; DGCCRF review of 25 June 2026; DGCCRF press release of 4 September 2026; press reports on the Lille and Caen decisions.
Italy: Decreto legislativo 27 May 2022, no. 82, Articles 21 and 24; AgID regulation on supervision and sanctions (May 2026).
Spain: Ley 11/2023, Articles 29 and 30; Real Decreto Legislativo 1/2013, Article 83.
Ireland: S.I. No. 636 of 2023, Regulations 4, 27, 30 and 32; Fines Act 2010, section 3.
Sweden: Lag (2023:254), sections 37 to 39; PTS report PTS-ER-2026:7.
Negative findings (no published fine, no ruling on German warning letters) reflect what we could find on 11 October 2026.

This article describes the legal situation as we understand it and is not legal advice. If you have received a letter from an authority, a lawyer or an association, have it reviewed by a lawyer qualified in the country concerned.