One Year of the European Accessibility Act: What the Enforcement Looks Like

The European Accessibility Act came into force on June 28, 2025. It was the most significant piece of digital accessibility legislation in European history, extending binding obligations to private sector products and services across every EU member state, for the first time.

Twelve months on, we have a factual record of what enforcement looks like in practice.

Here is what has happened in Europe, country by country.

Norway: A fine with no ceiling

Norway is not an EU member, but it is fully bound by the EAA through the EEA Agreement. And its enforcement story is among the most significant signals for the region as a whole.

After the EAA deadline, the Authority for Universal Design of ICT (Tilsynet for universell utforming av IKT) inspected HelsaMi, a patient portal used by approximately 425,000 residents in central Norway to access medical records, view test results, manage appointments, and communicate with healthcare providers.

The inspection found 119 accessibility errors across 12 of 14 legal requirements. A formal remediation order was issued with a deadline. When it passed, 64 issues remained unresolved.

The authority's decision: fix the outstanding problems by December 19th, 2025, or pay NOK 50,000 per day (approximately €4,500 per day) until every issue is corrected. There is no cap on the total. The fine accumulates every single day until full remediation is confirmed. Depending on the pace of remediation, total exposure could reach hundreds of thousands of euros.

Several EU member states are now examining this escalating daily penalty model as a template for their own enforcement frameworks.

Source: Tilsynet for universell utforming av IKT

Sweden and the Netherlands: Regulators who come to you

These two cases matter most for businesses operating at scale, because they signal a structural shift in enforcement logic.

In Sweden, the Post and Telecom Authority (PTS) launched its first regulatory cases in October 2025, targeting large e-commerce operators. Not because a complaint had been filed,  but because the PTS had designed a structured programme to select businesses and audit them proactively. In the Netherlands, the Authority for Consumers and Markets (ACM) set an October 15th, 2025 deadline for non-conformance reports from companies in covered sectors. Those who submitted incomplete reports were flagged for priority audits in early 2026.

The message from both countries is the same: you do not need to be reported on to be found. Regulators are building systematic surveillance programmes. Being below the radar is not a compliance strategy.

Sources: Swedish PTS · Dutch ACM

Austria: What the gap between "fixed" and verified looks like

Austria's case is one of the most instructive for any organization currently working through remediation.

A company in the gambling sector* had previously worked with Accessiway on an accessibility audit. When the EAA deadline arrived, they had held off on re-auditing: their platform was under continuous development, making it difficult to pin down a stable baseline to work from.

Shortly after the June 2025 deadline, they received a formal letter from the Austrian Ministry of Social Affairs, asking what they had done on accessibility, what barriers remained, and what their roadmap looked like. Their response was not considered sufficient. The Ministry issued a defined list of requirements with a deadline of the end of Q1 2026.

The company came back to Accessiway to update their Accessibility Conformance Report. They believed they had addressed everything on the Ministry's list. When we ran the audit, there were still many open points.

This is one of the most consistent patterns we see: the gap between what a team believes has been fixed and what independent verification confirms. It is not a failure of intent. It is a structural feature of how accessibility remediation works and it is precisely what structured, expert-led auditing exists to close.

The company was not fined, but the time and resources spent managing the Ministry's process would have been avoided entirely with a timely independent re-audit in place. 

*The company’s name is not disclosed, being Accessiway client with an accessibility project currently going on.

France: The first court cases in the EU

Just days after the June 2025 deadline, two disability rights organizations, ApiDV and Droit Pluriel, joined forces with the legal collective Intérêt à Agir to test four major grocery retailers: Auchan, Carrefour, E.Leclerc, and Picard. They recruited blind and low-vision users to attempt one task: to do their weekly shopping online.

The results were unambiguous. On every platform tested, core functions were broken for screen reader users: product listings, checkout, delivery slot selection, cart management, and price information. Formal legal notices went out on July 7th, 2025. The retailers were given until September 1st to comply. When no meaningful action followed, injunctions were filed before multiple regional courts.

On June 4th, 2026, the Tribunal judiciaire de Caen ruled against Carrefour. Six months to reach full RGAA compliance, a €500 daily penalty for non-compliance, and €10,000 in damages. Carrefour's defence, a claimed 71% compliance rate, was rejected outright. The court was clear: an e-commerce platform "cannot be only somewhat accessible, it must be fully accessible."

Accessibility is an obligation of result, not of effort.

This is the first court decision against a private company under the EAA framework in the European Union. France has demonstrated it is fully prepared to litigate.

Germany: A new authority, and a private enforcement mechanism that changes the stakes

Germany's enforcement infrastructure took longer to establish, but it is now fully operational.

All 16 federal states agreed to create a single joint authority by state treaty: the MLBF (Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen), based in Magdeburg. It formally began operations on September 26th, 2025 and published its Market Surveillance Strategy in January 2026, a documented framework defining its inspection priorities, risk-based approach, and how it selects organizations to investigate. Penalties for non-compliance reach €100,000 per violation.

The MLBF works both reactively, responding to complaints from consumers or businesses, and proactively, running sector-based audits on its own initiative. Being unreported is not the same as being safe.

But the enforcement dynamic that makes Germany genuinely distinct has nothing to do with the MLBF. Under the German Unfair Competition Act (UWG), accessibility obligations under the BFSG are classified as market conduct rules. A competitor whose website is accessible can argue that yours is not and that your non-compliance gives you an unfair cost advantage, because you saved money they invested in getting compliant.

They can then send you an Abmahnung: a formal cease-and-desist letter demanding remediation, a signed commitment, and often covering their legal costs, with no regulator involved at any stage.

This mechanism is well-established in German copyright and trademark law. It is now being applied to accessibility for the first time. It is fast; an Abmahnung can arrive very shortly after a violation is identified. Consumer protection associations can use it, not only direct competitors. 

Source: mlbf-barrierefrei.de, UWG

Italy: The enforcement chain is complete

Italy's transposition, D.lgs. 82/2022, entered into force on June 28th, 2025. What came next was a deliberate, phased construction of the full enforcement infrastructure.

March 4th, 2026: AgID published its official Guidelines, giving the legal basis for penalties concrete operational meaning.

March 11th, 2026: AgID launched a public complaints platform, opening enforcement to anyone, not just regulators. A screen reader user who cannot complete a checkout. A blind customer who cannot read their bank statement. Anyone can now initiate a formal process.

May 15th, 2026: A new market surveillance regulation defined AgID's sanctioning powers: fines of up to €40,000 for violations.

Guidelines, complaints mechanism, sanctioning powers. The chain is complete.

Source: https://www.agid.gov.it/it 

Twelve months in: what the pattern shows

Across all six markets, three things stand out consistently.

Enforcement reaches you even without a complaint. Sweden and the Netherlands are running proactive inspection programmes. Germany's MLBF has a published surveillance strategy. Italy's complaints platform opens the process to any member of the public. Waiting to be reported is not a risk mitigation strategy.

The gap between remediation and verification is real. Teams that have worked hard on accessibility fixes routinely discover, when an independent audit is run, that genuine gaps remain. It is the structural reason independent verification exists.

Documentation is part of what regulators assess. What the Austrian case shows clearly is that regulators want to see evidence of a structured approach. An Accessibility Conformance Report is not only a compliance deliverable. It is a record of good faith that becomes material the moment a regulator or court gets involved.

How Accessiway supports organizations navigating this landscape

The Accessiway Platform was built for exactly this environment.

It runs structured, expert-led audits and provides Accessibility Conformance Reports that give you the documented, independent baseline regulators look for. It supports continuous monitoring, so your compliance status reflects the platform you have today. And it gives your teams a structured way to manage and track remediation, so the gap between "we believe we've fixed it" and "we can demonstrate we've fixed it" stays closed.

The cases above are not stories of organizations that ignored accessibility entirely. Several had done genuine work. What they lacked was verified, documented, and continuously maintained compliance, and that is exactly where exposure lives when enforcement arrives.

Want to understand where your digital estate stands today?

Book a conversation with our team