A Year of the European Accessibility Act: What Actually Happened

Published guidance on this is contradictory, so it is worth being precise. Several sources state that regulators in multiple member states are issuing fines. The accounts that show their working say something different: that as of mid-2026, no company has been fined under any national law transposing the EAA, anywhere in the European Union. The one monetary penalty in the wider European Economic Area — a daily fine on a Norwegian health portal — rests on older Norwegian law rather than the EAA. We think the careful reading is the correct one, and we would rather tell you that than repeat a scarier number.

France moved first, and not through a regulator. Disability organisations sent formal legal notices to four major retailers within days of the deadline, then filed emergency injunctions in November 2025 when the responses were judged inadequate. In June 2026 a court ordered Carrefour to make its site and app fully accessible under a €500-per-day penalty. A parallel case against Auchan was dismissed in May 2026 on a scope question now under appeal, with the judge noting the company did not actually dispute that its site failed the standard. Elsewhere: Sweden’s telecoms regulator opened investigations on its own initiative, the Netherlands ran a mandatory self-reporting round and is auditing the businesses that stayed quiet, and in Germany a wave of Abmahnungen — formal warning letters from law firms rather than regulators — began within weeks of the national law taking effect.

Two things catch people out. The first is that the law follows the customer, not the company — a business headquartered outside the EU selling to EU consumers is in scope, in the same way GDPR reached far beyond Europe. The second is the micro-enterprise exemption, which is regularly misquoted. It requires fewer than 10 employees and under €2 million in turnover. Both, not either. Above that line, if you sell to EU consumers through your website, the obligation is live and has been since June 2025.

The EAA is a directive, so each member state wrote its own enforcement law, and the differences are larger than most summaries admit. Ireland is unusual in attaching criminal penalties, with directors personally liable. Italy runs two regimes side by side, and separately voids web design contracts that fail to provide for accessibility guidelines. Germany enforces through the Bundesnetzagentur with per-violation fines. The Netherlands added a self-reporting duty to the ACM where a service is not fully accessible. Our country pages cover what each market actually requires — Ireland, Italy, Germany, the Netherlands, France and the rest.

Accessibility overlay widgets — the one-line scripts that add a floating accessibility menu — do not make a site compliant, and their presence tends to signal the opposite to anyone looking. They sit on top of the page without fixing the underlying markup a screen reader actually parses. In the US, where litigation volumes are far higher, roughly 1,400 businesses with a widget installed were sued in 2025 anyway. Automated scanners have a related limit worth knowing: they catch somewhere around a quarter to a third of the issues in the standard, which makes a clean scanner report a starting point rather than a result.

If you are under the micro-enterprise threshold, this is not currently your problem, and nobody should sell you an audit on the basis that it is. If you are above it and selling to EU consumers, the sensible read is that year one built the machinery and year two runs it — investigations that are open do not close themselves, and a deadline that has passed does not reset. The practical version is unglamorous: real alt text, keyboard operability, sufficient contrast, labelled form fields, sensible heading structure. Those are build decisions, which is why we would rather agree accessibility scope at the start of a project than sell it back to you as a fix afterwards.