EAA enforcement is already active across Ireland, the Netherlands, Sweden, France, Germany, Finland, and Italy. It does not work the way most organisations assume.
EAA enforcement began the day the Act became enforceable on 28 June 2025. It did not wait for organisations to be ready. In France, disability organisations filed lawsuits nine days after that date. In Sweden, PTS launched systematic inspections within months. In the Netherlands, the ACM began auditing webshops and found that 61% made ordering entirely impossible for disabled users. Enforcement is not coming. It is here.
EAA enforcement operates through two independent tracks. An organisation can face both simultaneously.
Track 1 — Regulatory enforcement. National authorities audit organisations, issue formal findings, and impose financial penalties. The process varies by market but the outcome is the same: a formal compliance obligation with financial consequences for non-compliance.
Track 2 — Civil society enforcement. Disability organisations with legal standing bring proceedings directly, without waiting for a regulator. France demonstrated this model nine days after the EAA became enforceable. The mechanism is available in every EU member state. It does not require a complaint to be filed with a regulator first.
Neither track requires the other to act first. An organisation under regulatory investigation can simultaneously face civil society proceedings. Both are independent paths to a compliance obligation.
Ireland — ComReg enforces for electronic communications and digital services. The CCPC enforces for products. Ireland is the only EU member state with criminal sanctions for EAA non-compliance: directors face personal liability, fines up to €60,000 on indictment, and imprisonment up to 18 months. ComReg is already processing formal complaints. See our Ireland enforcement guide.
Netherlands — The ACM (Authority for Consumers and Markets) enforces for e-commerce and digital services. The AFM enforces for financial services. A mandatory reporting requirement has been in effect since October 2025. As of mid-2026, the ACM has shifted from information-gathering to formal sanctions. Fines reach €900,000 or 10% of annual turnover. See our Netherlands enforcement guide.
Sweden — PTS (Post and Telecom Authority) conducts proactive systematic inspections. As of June 2026, 28 organisations are under investigation including H&M, IKEA, Coop, ICA, and Systembolaget. PTS has received 124 public complaints. Two penalty types apply: Sanktionsavgift (SEK 10,000–10,000,000) for non-cooperation, and Vite for non-remediation. Market ban authority exists. See our Sweden enforcement guide.
France — No single national EAA regulator. Enforcement is driven by disability organisations with legal standing. As of June 2026, two EAA court rulings have been issued. The Auchan case was dismissed on a procedural threshold. The court found the site inaccessible. The case is being appealed. Carrefour was ordered to make its online commerce services fully accessible within six months. E.Leclerc has a hearing scheduled for 22 September 2026. See our France civil society enforcement guide.
Germany — Private enforcement via Abmahnung operates independently of regulators. Any competitor or qualifying organisation can send a formal warning letter without involving a public authority. Bundesnetzagentur can separately impose administrative fines up to €100,000. See our Germany BFSG guide.
Finland — Traficom enforces on a complaint-driven basis. Conditional daily fines apply where compliance orders are not met. See our Finland enforcement guide.
Italy — AgID (Agenzia per l’Italia Digitale) enforces with a 90-day cure period before financial penalties apply. Fines reach €1,000,000 for very serious violations. See our Italy enforcement guide.
Step 1: First contact. In Ireland and the Netherlands, the accessibility statement is the first document requested. An organisation without one, or with one that does not meet EAA requirements, has demonstrated non-compliance at the first point of contact.
Step 2: Investigation. The regulator or court assesses whether the product meets EN 301 549. Automated testing identifies obvious failures. User testing with assistive technology identifies the rest.
Step 3: Formal finding. A formal notification of non-compliance is issued. In Italy this triggers the 90-day cure period. In other markets it triggers financial penalty proceedings.
Step 4: Penalty or compliance order. Financial penalties are imposed or, as in France, a court orders compliance within a set deadline with daily fines accruing after it.
Step 5: Appeal. Organisations can appeal decisions. The Auchan case was dismissed on narrow procedural grounds specific to that entity. The Carrefour compliance order stands and is running.
No EAA administrative fine has been published in any market as of June 2026. This is not evidence of low enforcement risk. Most markets began with audit and monitoring phases before moving to formal sanctions. The Netherlands explicitly shifted from monitoring to sanctions in mid-2026. Sweden’s first penalty decisions are expected throughout 2026. Germany’s private enforcement track has been active since enforcement began, without involving public authorities at all.
The absence of published fines reflects the pace of enforcement proceedings, not the absence of enforcement activity. The organisations under investigation now are the organisations that will face the first published decisions.
The question is not whether your organisation will face enforcement. It is whether, when enforcement arrives, you are in a position to demonstrate genuine compliance management. The due diligence defence in Ireland, the 90-day cure period in Italy, and the documented governance requirement across all markets reward organisations that started compliance work early and can evidence what they did.
An accessibility statement is the document requested first. Governance includes a named owner, a testing process, and a remediation record. It is what distinguishes an organisation that responds to enforcement contact from one that has no documented position at all. See our governance guide for what that requires in practice.
Our free initial assessment covers your current accessibility position, where gaps may exist relative to EAA requirements, and what a proportionate next step looks like.
Book your free assessment