EAA 2026: What’s Enforced Now

The European Accessibility Act(opens in a new tab) (EAA) has been enforceable since 28 June 2025. If your organization offers products or services in the European Union, EAA compliance is not a best practice you can put off; it is a legal requirement that is being enforced now. Organizations that offer covered products or services on the EU market without meeting accessibility standards are already exposed to enforcement by national authorities, and the wave of complaints and legal action that advocacy groups and regulators signaled before the deadline is now materializing.

Below, we'll look at why EAA lawsuits and enforcement actions are now rising, and how you can reduce your legal risk. But first, here's exactly what the EAA is, what it requires, and who needs to comply.

What is the EAA, and Why Does it Matter?

European Accessibility Act compliance means meeting the requirements of Directive (EU) 2019/882(opens in a new tab) for covered products and services, using the Web Content Accessibility Guidelines(opens in a new tab) (WCAG) 2.1 Level AA as the technical baseline. The EAA requires organizations that offer products or services in the European Union to make their websites, mobile applications, online documents, and digital products accessible to people with disabilities.

To comply with the EAA, organizations must ensure their digital content is perceivable, operable, understandable, and robust (POUR),  the same principles behind WCAG. The EAA's technical requirements are based on the standard EN 301 549(opens in a new tab), which is aligned with WCAG 2.1 Level AA. So if you meet WCAG 2.1 Level AA, you meet the EAA's baseline. We cover how the EAA and WCAG fit together in more detail below.

The EAA applies across a defined set of products and services, including banking and payment services, e-commerce, e-readers, transport, and telecommunications. Essentially, any organization offering covered products or services in the EU market must comply, including companies based outside the EU. This means that a U.S., UK, or other non-EU business that sells to EU consumers must comply with the EAA.

Non-compliant organizations face enforcement by national authorities, financial penalties, and other consequences such as orders to withdraw a product or service from the market. Because each member state sets its own penalties, the amounts vary widely, from lower fixed fines in some countries to ceilings of €100,000 per violation in Germany and up to €1,000,000 for the most serious infringements in Spain. 

Which Businesses are Most at Risk for Lawsuits?

All in-scope organizations must comply with the EAA, but some face a higher risk of complaints and enforcement because of the nature of their digital services. The most exposed tend to be the ones that handle high volumes of consumer transactions or provide essential services:

• E-commerce: High transaction volume and constant consumer interaction make online retail a frequent target, and the first EAA-related legal actions in France centered on major retailers.

• Banking and financial services: When a lack of accessibility can stop someone from managing their own money, the stakes are high, which makes this sector a priority for regulators.

• Telecommunications and essential services: Utilities, telecoms, healthcare, and transport provide services people cannot easily do without, so accessibility failures draw scrutiny quickly.

• Streaming and digital media: Widely used entertainment and content platforms are high-visibility, making non-compliance easy to spot and report.

• Travel and hospitality: Booking and ticketing sites have a long history of accessibility complaints, and that pattern is expected to carry into EAA enforcement.

One note worth repeating: the risk doesn’t depend on where a business is based. A U.S., UK, or other non-EU company that sells covered products or services to EU consumers is in scope, and early enforcement has focused first on large, high-visibility brands. 

A gray-and-white drawing of a courthouse, with an icon of the scales of justice behind it.

What EAA Enforcement Looks Like Now

As of June 28, 2025, the EAA is in effect, meaning there is no grace period. Any organization that places covered products or services on the EU market without meeting the standard is exposed to enforcement, and that enforcement is already happening.

Enforcement is Happening Country by Country

Because each member state enforces the EAA, the risk takes different forms in different markets. National authorities can investigate complaints, order a non-compliant service to be fixed, impose fines, and, in some cases, order a product or service withdrawn from the market.

Complaints can come From More than Regulators

You are at risk not only if a regulator notices you. Consumers, disability advocacy groups, and, in some countries, competitors can all trigger enforcement. In Germany, for example, competitors can bring claims against a non-compliant business under unfair competition law, so the pressure does not necessarily depend on a regulator finding you first.

The First Cases are Already Here

That pressure is already producing real cases. In France, disability organizations moved against major retailers within months of the deadline: the first EAA-related legal actions in the EU. Similar activity is building in other member states as authorities shift from guidance to active enforcement.

The Pattern is a Familiar One

Anyone who watched web accessibility litigation in the U.S. will recognize what happens next: once a standard becomes enforceable, the organizations that ignored it become targets. The EAA is early in that cycle, but the direction is clear: complaints lead to notices, notices lead to fines, and the businesses with the most exposure tend to be the ones that treated accessibility as optional.

Two questions usually follow. The first is who is most at risk. The second is what non-compliance actually costs, from per-violation fines to market-withdrawal orders.

The Cost of Non-Compliance: Fines and Legal Consequences

The EAA does not set penalties at the EU level. Instead, each member state sets its own fines and sanctions, which it must make "effective, proportionate, and dissuasive." That means the cost of non-compliance depends on where your customers are. And the ceilings vary widely.

A few examples show the range:

• Germany: Fines of up to €100,000 per violation under the Barrierefreiheitsstärkungsgesetz (BFSG). Because the cap applies per violation, a site with multiple failures can face stacked penalties.

• Spain: A tiered system under Ley 11/2023, with fines reported to reach as high as €1,000,000 for the most serious infringements, plus possible orders to withdraw a service or suspend operations.

• Ireland: The only member state with criminal penalties. On indictment, fines of up to €60,000 and/or up to 18 months' imprisonment, with company directors potentially liable in person.

Beyond fines, national authorities can order a non-compliant product or service to be withdrawn from the market, which, for many businesses, is the more disruptive outcome. Losing the ability to serve customers in a country can cost far more than the fine itself.

A stylized version of a website with a number of accessibility issues highlighted, next to a green accessibility symbol.

How to Avoid an EAA Website Compliance Lawsuit

The good news: reducing your EAA risk is not a mystery. The requirements map to WCAG 2.1 Level AA (via EN 301 549), so the work is well understood. The task is finding where your site falls short and fixing it.

Start with an accessibility audit. You can’t fix what you haven't found, so the first step is to understand where your website, apps, and online documents fall short of WCAG guidelines. An automated scan will surface common, high-frequency issues quickly (e.g., missing alt text, poor color contrast, unlabeled form fields, and keyboard traps) and give you a clear starting point. One thing to note: automated testing alone will not catch everything, which is why the most defensible approach pairs it with expert audits from accessibility experts and real users with disabilities.

From there, the path is a plan, not a single fix: fix the issues that block real users first, build accessibility into how new content and features are created, and keep testing as your site changes. 

For a full step-by-step approach, including how to prioritize, document your efforts, and maintain compliance over time, see our EAA compliance checklist. 

The Cost of Inaction: Why EAA Compliance Can’t Wait

EAA enforcement is live, and the cost of ignoring it keeps rising. National authorities are moving from guidance to active enforcement; advocacy groups are watching; and the organizations most exposed are the ones still treating accessibility as optional. 

The encouraging part: you don't have to navigate the path to EAA compliance alone. AudioEye helps organizations meet the accessibility standards required by the EAA, combining automated fixes with expert testing and audits conducted by real users with disabilities. That combination stands up to scrutiny in the places where automated tooling alone would leave gaps.

The best time to address accessibility was before the deadline. The second-best time is now. See how AudioEye supports EU compliance by scheduling a demo.

Curious how accessible your existing site is? Get a free accessibility scan.