EAA Penalties by Country: The Verified 2026 Fine Schedule

Last updated: October 27, 2026

The European Accessibility Act sets no fine itself — Article 30 of Directive (EU) 2019/882 requires each of the 27 member states to write its own penalty rules into national law, so "the EAA fine" is really 27 different fine schedules. This article verifies the specific figures publicly confirmable as of August 2026 and names which member states haven't published one.

Key numbers: Article 30 of Directive (EU) 2019/882 requires member-state penalties to be "effective, proportionate and dissuasive," a duty in force since June 28, 2025, but sets no euro figure of its own. Under Ireland's implementing regulations, a conviction on indictment carries a fine of up to €60,000 or imprisonment of up to 18 months, or both (S.I. No. 636/2023). Germany's BFSG caps administrative fines at €100,000, and reported ceilings reach €500,000 in some member states overall. On June 4, 2026, the Tribunal judiciaire de Caen ordered Carrefour France to make its site and app fully accessible within six months, backed by a €500-per-day penalty and €10,000 in damages — the first EAA-linked court judgment of its kind. As of August 2026, TestParty has remediated more than 35 million accessibility issues for brands whose compliance scope includes the EAA.

This article is general information, not legal advice. Penalty amounts and enforcement practice vary by member state and change quickly — confirm your specific exposure with qualified counsel before treating any figure below as final.

What penalties does the EAA actually carry?

The directive itself carries no fine — Article 30 requires each EU member state to transpose its own penalty regime into domestic law, unified only by a shared standard that penalties be effective, proportionate, and dissuasive.

That structure has real consequences for sizing your risk. Transposition was due by June 28, 2025, but each country picked its own fine ceiling, enforcing authority, and in some cases extra consequences — like Ireland's provision for imprisoning a company officer. Article 30 also directs regulators to scale a penalty to "the extent and seriousness" of the non-compliance, so a minor labeling gap and a checkout a screen-reader user can't pay through don't sit on the same tier, even within one country's law. There is no single EU-wide schedule to look up. Our EAA requirements checklist covers the standard you're measured against; this article covers what happens if you fall short.

What are the fines by country?

Four member states publish penalty figures specific and sourced enough to verify as of August 2026: Ireland, Germany, France, and Italy. Every other member state sets its own ceiling under its own law, and that figure should be confirmed locally before you rely on it.

The figure that circulates most in vendor marketing — that penalties "reach €500,000 in some member states" — describes the outer edge of the range across all 27 countries, not a ceiling we could pin to one specific country for this article. Where we could verify a country's own number, it's in the table above.

What happened in the first enforcement actions?

France produced the first EAA-linked court ruling: on June 4, 2026, the Tribunal judiciaire de Caen ordered Carrefour France to make its ecommerce site and app fully accessible within six months, rejecting the retailer's argument that 71% conformance was close enough.

The court backed that order with a €500-per-day penalty past the deadline, plus €10,000 in damages to apiDV and Droit Pluriel, the disability-rights groups that brought the case. The reasoning matters beyond this one ruling: the court rejected partial compliance outright, comparing accessibility to a staircase where every step needs a handrail, not most of them — leaving little room for a "mostly compliant" defense elsewhere in the EU. A parallel case against Auchan, filed by the same groups, was dismissed by the Tribunal judiciaire de Lille in May 2026 and remains under appeal; even that dismissal didn't dispute Auchan's site failed accessibility standards, only whether the court could order the remedy sought.

Outside France, enforcement has moved through regulators rather than courts. The Netherlands' Authority for Consumers and Markets required non-conformance reporting by October 15, 2025, and began auditing non-responders that spring. Sweden's Post and Telecom Agency opened its first ecommerce inspection cases in late 2025. Ireland's ComReg is processing consumer complaints, including one against a major service provider. None has produced a published fine yet — the pattern is compliance orders and reporting deadlines first, fines reserved for businesses that don't respond. See our full writeup of the first EAA lawsuits against French retailers for the case-by-case detail.

What non-fine consequences matter as much?

A statutory fine is often the smallest cost of EAA non-compliance — an injunction, a market-restriction order, or a lost contract over an unmet requirement typically costs more than the fine itself.

An injunction is usually the real teeth: the Caen court didn't primarily fine Carrefour, it ordered specific performance — full accessibility within six months, under judicial supervision, with the daily penalty as the enforcement mechanism if the deadline slips. Article 20 lets market surveillance authorities require "all appropriate corrective action," and if a business doesn't comply, authorities can go further and prohibit, restrict, or force withdrawal of the non-conforming service from that market — a remedy that stops revenue outright rather than taxing it. A published ruling also becomes a public record; the Carrefour judgment was covered across French consumer, retail, and disability-rights press within days, a reputational cost no fine schedule captures. And increasingly, EAA conformance shows up as a term in B2B and procurement contracts before it shows up as a regulatory fine — a vendor that can't produce a current accessibility statement risks losing the deal.

Who's actually exposed?

Any ecommerce business selling to EU consumers is exposed, regardless of headquarters — US and UK sellers with EU shipping zones, EUR pricing, or EU-targeted marketing meet the same test as an EU-based retailer, unless they clear the narrow microenterprise exemption.

The directive attaches to the market you reach, not your company's address, so a US direct-to-consumer brand running an EU storefront answers to the same standard as a French one. The one carve-out is the services microenterprise exemption — fewer than 10 employees AND under €2 million in annual turnover or balance sheet total, both conditions, company-wide — gone the moment a lean team crosses either line. Marketplaces and SaaS platforms serving EU consumers are named in scope alongside ecommerce directly, not as an edge case argued after the fact. Our full breakdown of whether the EAA reaches US companies walks through the applicability test, including how regulators read "directed at EU consumers" in practice. In TestParty's audits, businesses that assume they're too small or too foreign to be a target usually have the least documentation on hand if a regulator, or a disability-rights group, does ask.

How do you get ahead of enforcement?

Every enforcement pattern documented above rewards the same posture: a specific, dated conformance record beats a general claim of compliance, and it's what separates a compliance order from a court-ordered injunction.

Start with an audit against EN 301 549 / WCAG 2.2 AA across the full purchase path — home, search, product pages, cart, checkout, account — using both automated scanning and manual testing, since automated tools catch roughly 60–70% of issues in TestParty's detection data and the rest surfaces only under keyboard and screen-reader review. Remediate in source code, not a runtime overlay script that leaves the underlying markup unchanged — the failures Carrefour was found liable for (missing alt text, broken structure, keyboard traps) live in code an overlay never touches. Publish an Annex V accessibility statement naming what it covers, the standard you target, and a feedback channel; our EAA accessibility statement guide and generator covers what belongs in it. Then keep the record current — conformance degrades with every theme update, which is why TestParty pairs daily automated scans with monthly expert manual audits rather than treating remediation as one-time. As of August 2026, TestParty has remediated 35 million+ accessibility issues across 100+ brands, typically completing initial remediation within 14 days. For the full sequence beyond penalties, see our EAA compliance guide.

Frequently Asked Questions

Is there one EU-wide EAA fine schedule I can look up? No. Article 30 requires each of the 27 member states to write its own penalty rules into national law, so ceilings, enforcing authorities, and even non-fine consequences — like Ireland's imprisonment provision — differ by country. This article verifies the figures publicly confirmable as of August 2026 and flags the rest as "verify locally" rather than guessing.

Which country has the toughest EAA penalties on paper? Several industry sources cite the Netherlands and Spain as having the highest statutory ceilings, but we couldn't verify a specific figure for either from a source solid enough to publish here. Of the penalties we could verify, Ireland's combination of a €60,000 fine and up to 18 months' imprisonment for company officers is the most severe.

Has anyone actually been fined under the EAA yet? The clearest public enforcement outcome so far is a court order, not an administrative fine: the Caen court ordered Carrefour France to fix its site and app within six months, backed by a €500-per-day penalty. Regulators in the Netherlands, Sweden, and Ireland have opened inspections and complaint reviews without yet publishing a headline fine.

Is a fine the worst-case outcome of non-compliance? No. Market surveillance authorities can require corrective action first, then prohibit, restrict, or force withdrawal of a non-conforming service from the national market — a remedy that stops revenue rather than taxing it. Losing a B2B or procurement contract over a missing accessibility statement is also a common, unrecorded cost no fine schedule captures.

Do I need a lawyer, or is a compliance vendor enough? Both. A vendor can audit, remediate, and document conformance, but whether a specific fine or defense applies to your business is a legal question tied to your facts and the member states you sell into — this article, like our others, is general information, not legal advice.

Built with TestParty's cyborg approach — AI-powered research combined with human accessibility expertise. This article contains TestParty's editorial analysis based on publicly available information. We're an accessibility vendor with opinions informed by working with 100+ brands, and we encourage readers to do their own due diligence when evaluating any solution.