In Effect Since June 28, 2025
The European Accessibility Act (EAA) is no longer a future requirement. The deadline has passed. Market surveillance authorities can now impose fines, consumers can report violations, and competitors can issue cease-and-desist notices. The first enforcement waves are already underway.
1. How the EAA Enforces Compliance
The EAA (Directive (EU) 2019/882) does not set uniform penalties across the EU. Instead, Article 30 requires each member state to define its own sanctions that are “effective, proportionate, and dissuasive.”
In practice, this means fines vary dramatically – from €5,000 in some countries to €1,000,000 in Spain or 10% of annual revenue in the Netherlands. Enforcement intensity also varies significantly.
Three Levels of Sanctions
1. Administrative fines: The most common sanction. Imposed by national market surveillance authorities. Typical range: €5,000–€100,000, significantly higher in some countries.
2. Competitor cease-and-desist notices: Particularly relevant in Germany. Competitors and consumer protection organizations can issue legal notices for violations. Cost: €500–€5,000 per notice plus injunctive relief.
3. Product/service restrictions: Authorities can remove non-compliant products or services from the market. For e-commerce, this can mean your online shop gets shut down.
2. Fines Table: All EU Countries
The following table shows maximum fines per country. Note: most countries grant correction periods before penalties apply. Fine amounts depend on severity, duration, and impact of the violation.
| Country | National Law | Max. Fine | Notes |
|---|---|---|---|
| 🇩🇪 Germany | BFSG | €100,000 | + Competitor cease-and-desist notices. €10,000 for documentation failures. Daily fines for ongoing non-compliance. |
| 🇪🇸 Spain | Ley de Accesibilidad | €1,000,000 | Highest single fine in the EU. Tiered: minor €30k–€90k, serious €90k–€300k, very serious up to €1M. |
| 🇳🇱 Netherlands | Wet tijdelijke bepalingen | €900,000 / 10% revenue | Proactive enforcement by ACM. Revenue-based penalties possible. |
| 🇫🇷 France | Loi accessibilité | €250,000 | Public naming of non-compliant companies. 4 retailers sued since Nov 2025. |
| 🇮🇪 Ireland | EAA Transposition | €200,000 | Only EU country with criminal penalties. Mandatory accessibility audits. |
| 🇦🇹 Austria | BGStG / BZG | €200,000 | Increased fines for repeat violations. Service suspension possible. |
| 🇮🇹 Italy | Decreto Legislativo | €100,000 | Enforced by AGCOM. Active enforcement in public sector already. |
| 🇧🇪 Belgium | Loi transposant | €100,000 | Federal and regional coordination. |
| 🇸🇪 Sweden | Lag om tillgänglighet | ~€900,000 (SEK 10M) | Market bans possible. Strong accessibility culture. |
| 🇫🇮 Finland | Accessibility Act | €150,000 | Mandatory accessibility audits. Documentation requirements. |
| 🇵🇱 Poland | Ustawa o dostępności | ~€50,000 | Enforcement building up. Slower start expected. |
| 🇵🇹 Portugal | Decreto-Lei | €44,000 | Relatively low ceiling. |
As of March 2026. Actual fines depend on severity, duration, impact, and the business’s willingness to cooperate.
3. Germany (BFSG) in Detail
Germany’s Barrierefreiheitsstärkungsgesetz (BFSG) has been in effect since June 28, 2025. It applies to all businesses providing digital services to consumers – including online shops, apps, and digital payment services.
BFSG Fine Structure
Up to €100,000: For selling non-accessible products or providing non-accessible services (§37 BFSG).
Up to €10,000: For missing or incomplete accessibility statements, documentation failures, and missing information obligations.
Daily fines: For ongoing non-compliance, compulsory penalties can accumulate until conformity is achieved.
Microenterprise Exemption
Businesses with fewer than 10 employees AND less than €2 million annual revenue are exempt from service requirements. However, if they sell products covered by the BFSG (computers, e-book readers, smartphones), product accessibility requirements still apply.
4. The 2025/2026 Enforcement Wave
Mass Cease-and-Desist Letters Since August 2025
Since August 2025, the German law firm CLAIM Rechtsanwalts GmbH has been sending mass cease-and-desist notices to online shops for alleged BFSG violations. The standard demand: approximately €595 per notice plus a cease-and-desist declaration. Legal experts consider many of these notices to be legally questionable.
The notices follow a familiar pattern: blanket allegations of BFSG violations without specifying which accessibility elements are missing. Legal experts advise:
- Don’t pay or sign anything hastily. Many notices contain formal deficiencies.
- Have a specialist lawyer review the notice. An IT or competition law attorney can assess its validity.
- Demand specifics. The sender must detail exactly which elements are non-compliant.
- Check the competitive relationship. Only actual competitors can issue competition-based notices.
5. France, Spain, Netherlands
🇫🇷 France: Public Naming + €250,000
France combines fines with public shaming: non-compliant companies can be publicly named. In November 2025, four major retailers (including Auchan, Carrefour, E.Leclerc, and Picard) were sued for inadequate digital accessibility – the first major EAA cases in France.
🇪🇸 Spain: Up to €1,000,000
Spain has the highest individual penalties in the EU. The three-tier system escalates by severity: minor violations up to €90,000, serious up to €300,000, and very serious up to €1,000,000. Companies can also be required to take corrective measures and be publicly identified as non-compliant.
🇳🇱 Netherlands: 10% of Annual Revenue
The Netherlands has one of the most proactive enforcement authorities in the ACM (Authority for Consumers & Markets). Fines can reach €900,000 or 10% of annual revenue – whichever is higher. For larger e-commerce businesses, this can quickly reach six figures.
🇮🇪 Ireland: The Only Country with Criminal Law
Ireland is the only EU member state that provides for criminal consequences in cases of serious EAA violations. Beyond fines of up to €200,000, deliberate non-compliance can lead to personal criminal liability for company directors.
6. Alt Text: The Most Common Violation
Missing alt text for images is one of the most easily provable violations of accessibility requirements. Any automated audit tool can determine in seconds how many images on a website lack alt text. This makes missing alt text the lowest-barrier attack vector for enforcement authorities and competitors.
"In its case against accessiBe, the FTC found that the overlay widget caused "missing or inaccurate alt text" on websites – for example, describing a filet mignon as "brown bread on white ceramic plate.""
Alt text is a core requirement under WCAG 2.1 Level AA (Success Criterion 1.1.1: Non-text Content). Every image that conveys information needs a descriptive alt text. Decorative images need an empty alt attribute (alt="").
How Many Images in Your Store Are Missing Alt Text?
Most online stores with 500+ products have hundreds or thousands of images without alt text. Manual remediation is unrealistic at that scale. AutoAlt.ai generates alt text via AI for all images – in minutes, not weeks.
7. How to Protect Your Business
The good news: the EAA and its national implementations emphasize proportionality. Authorities typically grant correction periods before imposing fines. Businesses that can demonstrate active compliance efforts face significantly lower risk.
Immediate Actions (Today)
- Generate alt text for all images. With AutoAlt.ai, done in minutes – install the plugin, run bulk, finished. 50 free credits/month.
- Publish an accessibility statement. Must be easily discoverable on every page. Describes current status and planned measures.
- Check color contrast ratios. Text-to-background contrast of at least 4.5:1 (WCAG AA).
- Test keyboard navigation. Every function must be reachable without a mouse.
Medium-Term (Within 3 Months)
- Conduct a WCAG 2.1 AA audit. Automated tools + manual testing.
- Document your action plan. Shows authorities you’re actively working on compliance.
- Make forms accessible. Labels, error messages, focus management.
- Screen reader testing. VoiceOver (Mac), NVDA (Windows), or JAWS.
8. Frequently Asked Questions
What are the fines for EAA non-compliance?
Fines vary by country: Germany up to €100,000, Spain up to €1,000,000, Netherlands up to €900,000 or 10% of annual revenue, France up to €250,000. Ireland is the only EU country with criminal penalties. In Germany, competitor cease-and-desist notices add additional financial risk of €500–€5,000 per notice plus injunctive relief.
Are missing alt texts an EAA violation?
Yes. Alt text for images is a core requirement under WCAG 2.1 Level AA (Success Criterion 1.1.1), the technical standard behind the EAA. Online shops without alt text can face administrative fines and competitor cease-and-desist notices. It’s also one of the easiest violations to detect automatically.
Has anyone been fined under the EAA?
As of March 2026, enforcement is actively ramping up across the EU. In Germany, mass cease-and-desist letters have been circulating since August 2025. In France, four major retailers were sued in November 2025. Regulatory authorities in multiple countries are monitoring compliance. While no massive individual fines have been publicly confirmed yet, the infrastructure for enforcement is in place and active.
Does the EAA apply to non-EU businesses?
Yes. If you sell products or services to EU consumers, you must comply with EAA requirements regardless of where your business is headquartered. This includes e-commerce websites, mobile apps, and digital services accessible from the EU. The EAA applies to both B2C and B2B services.
Missing Alt Text? The #1 EAA Violation.
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