Website Accessibility Remediation: What You Need to Know Now That EAA Enforcement Is Underway

The digital accessibility landscape transformed dramatically on June 28, 2025, when the European Accessibility Act officially took effect across all EU member states. For businesses operating in or serving European markets, website accessibility remediation shifted from a best practice to a legal imperative—and enforcement is already happening.

Just ten days after the EAA deadline, French disability advocacy groups issued formal legal notices to four of France's largest retailers—Auchan, Carrefour, E. Leclerc, and Picard—for failing to meet digital accessibility standards. By October 2025, Sweden's Post and Telecom Authority began active market surveillance of e-commerce sites. Denmark's monitoring agency started contacting companies about compliance. This isn't theoretical anymore: accessibility enforcement has arrived, and it's accelerating.

Website accessibility remediation—the systematic process of identifying and fixing barriers that prevent people with disabilities from accessing digital content—is now mandatory for most businesses operating in Europe. This comprehensive guide examines what's happening with EAA enforcement across EU countries, what website accessibility remediation truly entails, and how organizations can implement sustainable compliance strategies that go beyond superficial fixes.

What Is Website Accessibility Remediation?

Website accessibility remediation is the process of detecting, prioritizing, and resolving accessibility barriers at the source code level to ensure digital properties meet established standards like WCAG 2.1 Level AA and comply with regulations including the EAA, ADA, and Section 508.

Unlike overlay widgets that attempt to modify website behavior on the client side, true remediation addresses issues where they originate—in HTML, CSS, JavaScript, and other underlying code. This includes correcting semantic HTML structure, implementing proper ARIA attributes, ensuring keyboard navigation works throughout the site, fixing color contrast ratios, providing comprehensive text alternatives for multimedia content, and creating logical, predictable navigation structures.

According to the WebAIM Million report, the average website homepage contains over 50 detectable accessibility errors. These barriers affect approximately 1.3 billion people worldwide who live with some form of disability. Effective website accessibility remediation removes these obstacles, creating inclusive digital experiences that serve everyone—including the 87 million people with disabilities in the EU alone.

The European Accessibility Act: Real Enforcement Is Here

The EAA represents one of the most significant accessibility regulations globally. Passed in 2019 and implemented across EU member states by June 28, 2025, the Act establishes comprehensive accessibility requirements for products and services—including websites, mobile applications, and e-commerce platforms.

Who Must Comply with the EAA

The EAA applies to businesses operating within the European Union, regardless of where the company is headquartered. If you sell products or services to European customers, your digital properties fall under EAA jurisdiction. This includes e-commerce websites and mobile shopping apps, banking and financial services platforms, transportation and travel booking services, streaming media and audiovisual content providers, e-books and digital reading platforms, telecommunications services, and consumer-facing websites offering products or services.

Microenterprises (fewer than 10 employees and annual turnover below €2 million) may qualify for exemptions in some member states, but most mid-sized and large organizations must comply. The regulation doesn't distinguish between European and international companies—if you serve European customers, you're subject to EAA requirements.

EAA Standards and Technical Requirements

The EAA doesn't prescribe specific technical implementations. Instead, it requires that digital services be "perceivable, operable, understandable, and robust" for people with disabilities. In practice, this aligns with WCAG 2.1 Level AA standards, which have become the global benchmark for digital accessibility.

Most EU member states reference EN 301 549—the European ICT accessibility standard based on WCAG 2.1—as the technical benchmark. Compliance with EN 301 549 creates a "presumption of conformity" under the EAA, though some countries maintain additional national frameworks.

Key requirements include providing text alternatives for all non-text content, ensuring all functionality works via keyboard, maintaining sufficient color contrast (at least 4.5:1 for normal text), creating consistent navigation structures, ensuring forms include proper labels and error identification, and making customer service channels accessible to people with disabilities.

Country-by-Country EAA Enforcement: What's Actually Happening

Enforcement approaches vary significantly across EU member states, with some countries taking aggressive action while others adopt more advisory approaches. According to the Nordic Accessibility Community Group's enforcement tracking and accessibility law expert Lainey Feingold's documentation, here's what's happening on the ground as of late 2025:

France: Leading with Legal Action

France became the first EU country to pursue formal legal enforcement under the EAA. On July 7, 2025—just ten days after the compliance deadline—disability advocacy groups ApiDV and Droit Pluriel, supported by the legal collective Intérêt à Agir, issued formal legal notices to four major grocery retailers: Auchan, Carrefour, E. Leclerc, and Picard.

The notices cited multiple accessibility failures including websites and apps that couldn't be used with screen readers, checkout processes inaccessible to keyboard-only users, and product information unavailable to people with visual impairments. The retailers received until September 1, 2025, to remediate these issues or face lawsuits.

This enforcement action sent shockwaves through the European business community. France's approach demonstrates that the EAA isn't merely aspirational—it has teeth. The case also established an important precedent: disability advocacy groups and legal teams can initiate enforcement independently, without waiting for government agencies to act.

For complaints in France, users must first contact the organization directly via the required "Accessibilité" feedback link. If issues remain unresolved, complaints can be filed with the Défenseur des droits (Defender of Rights). In commercial cases involving persistent violations, matters may escalate to the DGCCRF (consumer protection authority). Organizations must acknowledge feedback within 10 days and update their Déclaration d'accessibilité (accessibility statement) with current issues and remediation timelines.

Maximum fines in France can reach €250,000 for failing to make public-facing platforms accessible, with additional daily penalties for ongoing non-compliance.

Sweden: Active Government Monitoring

Sweden's Post and Telecom Authority (PTS) began active market surveillance in October 2025, initially focusing on large companies operating in Sweden. According to Nordic Accessibility Community Group meeting notes, the agency employs four dedicated testers (with plans to add two more) and uses JAWS screen reader software for testing. No consulting agencies are currently involved in the monitoring process.

Swedish enforcement includes a strict reporting requirement: companies must report accessibility issues to PTS within 14 days of discovering them, even if they fix the problems immediately. The rationale is that the law's purpose is making services accessible, and authorities need visibility into accessibility challenges across the market.

Sweden has published specific guidance on the "disproportionate burden" exception—allowing organizations to claim that fixing certain accessibility issues would be unreasonably costly. However, these claims require documented economic justification, and monitoring agencies scrutinize them closely.

One notable early case: Swedish public transport company SL claimed fixing accessibility in PDF documents would cost 11 million Swedish crowns. The claim was rejected, and SL was fined 300,000 SEK. Maximum fines in Sweden can reach 10 million SEK (approximately €900,000).

Denmark: Company Notifications Underway

Denmark's monitoring agency began contacting companies about EAA compliance in October 2025. According to Nordic Accessibility Community Group discussions, comprehensive test procedures are being drafted to cover all EN 301 549 criteria to ensure consistent testing approaches.

One company reported being notified by Denmark's monitoring agency and working through the compliance process. Denmark has not specified fixed maximum fines; instead, penalties are assessed case-by-case based on violation severity and extent.

Estonia: Advisory Approach

Estonia has taken a less aggressive enforcement stance, with monitoring agencies providing guidance rather than immediate penalties. According to Nordic Accessibility Community Group discussions, the country won't enforce compliance violations until January 2026, giving businesses additional time to achieve conformance. Estonia's monitoring authority offers advisory services to help organizations understand and meet requirements—an approach that contrasts with France's immediate legal action.

Questions remain about specific issues like whether parcel lockers with payment options fall under EAA requirements. Estonian authorities indicated that if a device has payment functionality, the entire machine must meet accessibility standards.

Other EU Countries: Varied Approaches

Ireland does not have a single EAA compliance body. Responsibility is distributed across several regulators including ComReg (telecoms), Coimisiún na Meán (media services), and various sector-specific authorities. The National Disability Authority advises these bodies but isn't an enforcement agency itself. Severe violations can result in fines up to €60,000 and/or imprisonment for up to 18 months.

Italy is supervised by AgID (Agenzia per l'Italia Digitale), which provides a 90-day cure period after complaints. Fines range from €5,000 to €40,000, or up to 5% of annual turnover in serious cases. Users must contact providers first, then submit complaints to AgID if issues remain unresolved.

Spain handles enforcement through consumer protection and equality bodies under Ley 11/2023. Administrative fines range from €30,000 to €600,000, with repeat or severe violations potentially resulting in operational bans up to 2 years. In April 2024 (before the EAA deadline), Spanish airline Vueling was fined €90,000 for website accessibility failures.

Belgium can impose fines up to €200,000 per breach, with persistent violations potentially leading to business suspension.

Germany allows complaints to be pursued under competition law as "unfair practices," creating an additional enforcement mechanism beyond traditional accessibility channels.

The Future of EAA Enforcement: What to Expect

Early enforcement activity in France, Sweden, and Denmark provides insights into how EAA compliance will evolve across Europe:

Enforcement Will Intensify and Expand

France's legal action just ten days after the deadline signals that enforcement isn't theoretical—it's immediate and aggressive. Sweden's active monitoring with dedicated testing staff demonstrates government commitment to EAA enforcement. Denmark's company notifications show enforcement expanding beyond early-mover countries.

Expect additional EU countries to activate enforcement mechanisms in 2026 as regulatory authorities build capacity and see precedents from early enforcers. Germany, Spain, Italy, and other large markets will likely pursue similar approaches, creating pan-European enforcement pressure.

Complaint-Driven Enforcement Creates Unpredictability

The French case demonstrates that enforcement doesn't only come from government agencies. Disability advocacy groups, legal teams, and even competitors can initiate EAA enforcement actions. This creates unpredictable compliance risk—any user who encounters accessibility barriers can trigger formal complaints or legal action.

Organizations cannot predict when they'll face enforcement. The only protection is maintaining continuous compliance across all digital properties serving European markets.

Documentation and Transparency Requirements Will Strengthen

France requires accessibility statements with current issues and remediation timelines. Sweden requires reporting issues within 14 days of discovery. These documentation requirements create paper trails that regulatory authorities use when investigating compliance.

Expect documentation requirements to strengthen as enforcement matures. Organizations need systems that automatically generate compliance documentation rather than relying on manual reporting—another advantage of platforms like TestParty that automatically produce date-stamped compliance reports.

Consistency in Testing Approaches Will Emerge

Nordic Accessibility Community Group discussions reveal that countries are working toward consistent testing approaches. Sweden publicly announced using JAWS screen reader for testing. Denmark is developing comprehensive test procedures covering all EN 301 549 criteria.

As testing approaches standardize, organizations can implement remediation strategies that work across multiple EU countries rather than managing country-specific approaches. This favors remediation platforms that address the most stringent standards (WCAG 2.1 Level AA / EN 301 549) rather than minimum viable compliance in specific countries.

Taking Action on Website Accessibility Remediation

The combination of active EAA enforcement in France, Sweden, and Denmark with mounting enforcement activity across additional EU countries makes website accessibility remediation urgent for any organization serving European markets.

The enforcement timeline is clear: France issued legal notices just ten days after the compliance deadline. Sweden began active monitoring within four months. Denmark started contacting companies by October 2025. Other countries will follow. Organizations waiting for clearer guidance or hoping for lenient enforcement are discovering that the time for action was months ago.

For e-commerce businesses, particularly those operating Shopify stores, TestParty's done-for-you accessibility service provides the fastest path to EAA compliance. Within two weeks, your store becomes fully accessible with all fixes applied at the source code level. Daily AI scans maintain compliance automatically as you add products, update content, or modify your store. Monthly expert audits validate compliance and produce date-stamped reports meeting regulatory documentation requirements.

This eliminates the common failure pattern where organizations understand they need accessibility but struggle with technical implementation. You get complete remediation plus ongoing maintenance—exactly what active EAA enforcement demands.

For enterprise organizations with complex digital ecosystems across multiple EU markets, TestParty's comprehensive platform creates sustainable "always on" accessibility. From IDE-level scanning that catches issues during development to automated ticketing ensuring prompt remediation to executive dashboards demonstrating compliance status, the platform implements the continuous monitoring that Sweden's 14-day reporting requirement and France's aggressive enforcement make necessary.

The EAA is no longer approaching—it arrived in June 2025, and enforcement is accelerating across Europe. Organizations that embrace website accessibility remediation as both compliance mandate and business opportunity position themselves for success in an increasingly inclusive and actively enforced digital landscape.

To learn more about implementing effective website accessibility remediation that meets EAA requirements, explore TestParty's solutions or book a demo to discuss your specific compliance needs in countries with active enforcement.