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EAA Enforcement Tracker by Country: Verified vs Claimed (October 2026)

Published · 13 min read

As of 28 October 2026, enforcement of the European Accessibility Act (EAA) is national, mostly driven by complaints, and focused on orders to fix rather than fines. The clearest public activity is in France (consumer authority checks and a court order against Carrefour), the Netherlands (a regulator sweep of large webshops) and Germany (a national complaint portal). We have not found an officially confirmed fine against an online store under any country's EAA law; vendor claims of dozens of fines could not be verified.

This tracker lists what each country has done, with a date and a label for how solid the source is. We will update it as decisions come in. For whether the EAA applies to your store at all, start with Does the EAA apply to your online store?

How to read this tracker

The EAA is a directive (Directive (EU) 2019/882). It has applied since 28 June 2025, and each member state enforces its own national law with its own authorities and penalties (European Commission). The Directive itself sets no fine amounts; Article 30 asks for penalties that are "effective, proportionate and dissuasive" (Directive (EU) 2019/882, EUR-Lex).

Each item below carries one of four labels:

  • Official: published by the authority or government itself.
  • Court, reported: a court decision, as reported by press, the parties or lawyers. We have not read the judgment text.
  • Secondary: a law firm, trade press or advocacy group report of an official action, not yet matched to the official source.
  • Vendor claim: a figure from a company that sells accessibility products or services, with no independent confirmation found.

Two more tags appear where they fit: Unverified blog claim (a figure from a blog that is not shown to be a vendor, which we could not match to any official source) and Not found. Every item is dated. "Not found" means our searches up to 28 October 2026 returned nothing, not that nothing happened.

Summary table

Country Authority for online shops What has happened Label Date
Germany MLBF (joint authority of the 16 states) Complaint portal opened; no documented fines found; private warning letters reported Secondary June 2026
France DGCCRF; civil courts Checks found failings on over half of e-commerce sites checked; Carrefour ordered to fix Secondary; Court, reported 4 June and 4 Sept 2026
Netherlands ACM Sweep: 61% of about 100 large webshops could not take an order with assistive technology Official 24 March 2026
Austria Sozialministeriumservice Fewer than 100 proceedings opened in year one, per advocacy group Secondary 25 June 2026
Sweden PTS Staged supervision of larger e-commerce sites Secondary 2025 to 2026
Denmark Danish Business Authority, Market Surveillance division (formerly Sikkerhedsstyrelsen) Dialogue-based; warning to a large retailer Secondary 2025 to Feb 2026
Italy AgID New supervision and sanctions regulation Official 15 May 2026
Spain Secretaría de Estado de Digitalización e IA (per one blog) About 40 files opened, per one blog Unverified blog claim July to Dec 2025
Ireland CCPC Guidance published; no public action found Official (guidance) 2025
Belgium FPS Economy (reported) E-commerce guidelines in preparation; no action found Secondary June 2025

Germany

Germany implements the EAA through the BFSG. Online shops are supervised by the MLBF, a joint authority of all 16 federal states based in Magdeburg, which began work when the states' treaty took effect on 26 September 2025 (Schleswig-Holstein state government).

  • Complaint portal (Secondary, 8 June 2026). A consumer portal was launched where people can report barriers in online shops, banking, apps and machines to the MLBF, plus a route for a formal application for review under § 32 BFSG (gegen-hartz.de).
  • Fines (Not found). Under § 37 BFSG, fines can reach €100,000 for the breaches the law lists for that ceiling, which include offering a service that does not meet the accessibility requirements, and €10,000 for the others (BFSG § 37). We found no publicly documented fine as of October 2026. Some agency blogs say the first fines came in early 2026 but name no case, authority decision or amount (xictron, vendor).
  • Private warning letters (Secondary, from August 2025). Law firm Heuking reported the first BFSG warning letter (Abmahnung) about six weeks after the law took effect (Heuking, 19 August 2025). Händlerbund, a retailers' association, says many letters described defects only in general terms (Händlerbund). Whether competitors can enforce the BFSG through unfair competition law has not, as far as we found, been decided by a court.

France

France added the EAA rules to its Consumer Code (article L412-13). The DGCCRF checks merchant services. A breach is a fifth-class petty offense (contravention de 5e classe) under article R451-4 of the Consumer Code (DGCCRF consumer sheet, PDF), reported as up to €7,500 per infringement for a company (donneespersonnelles.fr).

  • DGCCRF checks (Secondary, 4 September 2026). At France's 7th national disability conference (Conférence nationale du handicap), held on 4 September 2026 after being postponed from June (Mon Parcours Handicap, French government; informations.handicap.fr), the DGCCRF presented interim results: more than half of the e-commerce sites it had checked since the start of the year had failings, which led to corrective or punitive measures. Final results are expected in early 2027 (Lettre des réseaux). We have not found the DGCCRF's own release. Consumers can report barriers through a dedicated route on the government's SignalConso service (informations.handicap.fr).
  • Carrefour (Court, reported, 4 June 2026). Two disability associations, apiDV and Droit Pluriel, sued four grocery retailers. The Caen court ordered Carrefour France to make carrefour.fr and its app accessible within six months, under a penalty of €500 per day of delay, and rejected the argument that meeting about 71% of the French criteria (RGAA) was enough. Carrefour said it reserved the right to appeal; we found no report of an appeal being filed (France 3; informations.handicap.fr; Intérêt à Agir).
  • Auchan (Court, reported, 5 May 2026). The Lille court dismissed the claim against Auchan's e-commerce company, applying a €250 million turnover threshold, while noting that Auchan's own audit showed a low level of accessibility. An appeal has been reported as lodged with the Douai Court of Appeal; we found no hearing date (informations.handicap.fr; Deque, vendor).
  • E.Leclerc and Picard (Not found). The Leclerc hearing in Créteil, first set for 5 May 2026, was reported as postponed to 22 September 2026 (CB News). We found no outcome as of 28 October 2026. We found no hearing date for Picard.

Netherlands

  • ACM sweep (Official, 24 March 2026). The Netherlands Authority for Consumers and Markets tested about 100 of the largest Dutch webshops and the sites of large telecom and energy providers. In 61% of cases, a customer using assistive technology could not complete a purchase; a further 33% had serious problems. Typical barriers were order buttons that could not be reached with a keyboard and an inaccessible CAPTCHA. The ACM contacted the worst performers and said it can enforce if they do not improve (ACM).
  • Sanctions (Not found). We found no published ACM sanction for accessibility as of October 2026.

Austria

  • First-year figures (Secondary, 25 June 2026). Disability organization Lebenshilfe Österreich, working with six students at WU Vienna, reported that fewer than 100 proceedings were opened across Austria in the first year of the Barrierefreiheitsgesetz. Its testers also found the official complaint form hard to find and use (Lebenshilfe Österreich press release, PDF). The market surveillance authority is the Sozialministeriumservice (WKO). We found no official count.

Sweden and Denmark

  • Sweden (Secondary, 2025 to 2026). PTS began its first supervision of e-commerce under the new law with larger Swedish retailers, checking websites (not apps) and focusing on the home page, a product page and the search function. The review runs in stages through 2025 and 2026 (M3; AbilityNet, November 2025). We found no published sanction.
  • Denmark (Secondary, 2025 to February 2026). AbilityNet reported that Danish authorities notified at least one major online retailer of problems in mid-2025, as a warning rather than formal enforcement, with no fines reported (AbilityNet). The W3C Nordic Accessibility Community Group describes the Danish approach as dialogue-based (W3C Nordic Accessibility CG). Since 1 January 2026, the former Danish Safety Technology Authority (Sikkerhedsstyrelsen) has been the Market Surveillance division of the Danish Business Authority (Erhvervsstyrelsen), which says it enforces the Danish accessibility act, tilgængelighedsloven (Erhvervsstyrelsen; Erhvervsstyrelsen on the merger).

Italy, Spain, Ireland and Belgium

  • Italy (Official, 15 May 2026). AgID published Determination 84/2026, a new regulation on its supervision and sanction procedures. It covers private websites with average turnover above €500 million under Italy's general accessibility law, and the service providers covered by the EAA transposition (Legislative Decree 82/2022). It adds no new technical requirements (AgID, 29 May 2026; Linkiesta). We found no sanctions yet.
  • Spain (Unverified blog claim). Ley 11/2023 transposes the EAA, and law firms report fines of up to €1 million for very serious infringements (Fieldfisher). One blog says about 40 formal files were opened from July to December 2025 by the Secretaría de Estado de Digitalización e Inteligencia Artificial, citing official data we could not find (Jacar). We could not confirm which authority supervises e-commerce under the Spanish law.
  • Ireland (Official guidance; no action found). The CCPC is the authority for e-commerce services and has published guidelines for microenterprises (CCPC). Irish law makes breaches criminal offenses, with fines of up to €60,000 on indictment, according to a law-firm summary (DLA Piper). We found no public enforcement.
  • Belgium (Secondary). Belgium's federal disability council gave an opinion on draft e-commerce accessibility guidelines in June 2025 (Belgian disability council opinion). We found no enforcement action.

Claims we could not verify

These figures circulate widely. We list them so you can recognize them, not because we accept them.

  • "About 50 to 100 fines through Q1 2026, mostly €5,000 to €25,000." TestParty (vendor) (TestParty). We found no authority decision or press report that matches it.
  • "The first fines came in early 2026" in Germany. Several German agency blogs, with no named case (xictron, vendor).
  • Warning letter costs of €3,500 to €20,000. Attributed to a single law firm by agency blogs; not confirmed.
  • "The first wave of fines has landed." Disability World (Disability World). We could not match its figures to official sources, and a companion page cites data dated after this article.

On the other side, Level Access (vendor) says no monetary fine had been confirmed under any national EAA law as of mid-2026 (Level Access). That matches what we found, but it is still a vendor source.

What the pattern means for a small online store

Four points stand out from the record so far, and they apply to non-EU sellers too, since the EAA can reach US companies.

  1. Complaints drive action. Germany, France and Austria all run public complaint routes. A barrier one customer meets can start a review.
  2. Correction comes first. Authorities ask for fixes with a deadline before penalties. The Carrefour order and the ACM letters both follow that pattern.
  3. Authorities test the buying journey. The ACM checked whether an order could be placed with assistive technology; PTS looks at the home page, a product page and search. A keyboard walk from home page to the start of checkout covers most of this (WCAG 2.2 checklist for online stores).
  4. Partial scores are not a defense. The Caen court rejected "about 71%". An accessibility statement should say what is not yet fixed, not claim full conformance.

Microenterprises (fewer than 10 staff and €2 million or less in turnover or balance sheet) are exempt from the service requirements (CCPC). The legal yardstick today is EN 301 549 with WCAG 2.1 AA, and a WCAG 2.2 edition is waiting to be cited (EN 301 549 V4.1.1 and WCAG 2.2). Testing against WCAG 2.2 AA covers both. An overlay widget does not change the code an authority tests (why an overlay doesn't fix your theme).

What to watch next

  • Early December 2026: the end of Carrefour's six-month period, counted from 4 June 2026.
  • Douai Court of Appeal: the Auchan appeal, and whether the €250 million threshold holds.
  • Créteil: the outcome of the Leclerc case.
  • Early 2027: the DGCCRF's final results.
  • The Official Journal citation of EN 301 549 V4.1.1 (the standard itself was published on 2 September 2026), expected between late November and mid-December 2026, depending on the source (NDA Ireland).

Sentinela scans and audits any public website against WCAG 2.2 A and AA, and an audit includes a draft accessibility statement. Fixes are made on Shopify and WooCommerce stores; fixes on other platforms are coming. For PrestaShop stores, see what the EAA means for PrestaShop. See our EAA page and method.

This article is general information, not legal advice. For your obligations, talk to a lawyer.

Sources