EAA fines, penalties and sanctions by country
Each EU member state sets its own penalty regime. Here is what enforcement looks like in the three markets where active enforcement is most advanced.
The penalties for non-compliance with the EAA vary by member state but include daily fines, market bans, criminal sanctions, and public naming of non-compliant organisations. The severity of the penalty depends on the jurisdiction, the nature of the violation, the size of the organisation, and whether the organisation has previously been notified of the failure.
The European Accessibility Act requires member states to establish penalties that are "effective, proportionate and dissuasive." What that means in practice varies significantly by country. This guide covers the three markets where UA operates and where enforcement activity is most advanced.
| Country | Maximum penalty | Criminal sanctions | Enforcement authority | Active enforcement |
|---|---|---|---|---|
| Ireland | €60,000 (on indictment) | Yes: up to 18 months imprisonment | ComReg (telecoms/digital services); CCPC (products) | Yes: ComReg processing complaints including against Three |
| Netherlands | €900,000 or 10% of annual turnover | No | ACM (Authority for Consumers and Markets); AFM (financial services) | Yes: ACM conducting active audits; formal sanctions moving second half of 2026 |
| Sweden | SEK 10,000,000 (~€900,000) | No | PTS (Post and Telecom Authority); Konsumentverket (products) | Yes: 28 supervisory investigations launched including H&M, IKEA, Coop |
| Italy | €1,000,000 | No | AgID (Agenzia per l'Italia Digitale) | Yes: cure period proportionate to nature of non-conformity; Determination No. 84/2026 sets new regulatory process |
| Finland | Daily-accruing conditional fine (no fixed ceiling) | No | Traficom | Yes: complaint-driven model active since 28 June 2025; no named penalty decisions published |
| Germany | €100,000 (government fine) | No | Split federal/Länder; joint services body (MLBF) still forming | No confirmed government fine; 300–500 private Abmahnungen (competition-law warning letters, a separate track from BFSG's own government enforcement) since transposition |
| France | No fixed ceiling; €500/day astreinte if Carrefour's order is not met by its deadline | No | French courts (civil society litigation) | Order issued against Carrefour (June 2026), not a fine; Auchan dismissed on procedural grounds; E.Leclerc hearing 22 Sep 2026; Picard pending |
No EAA fine has been imposed in France. The Carrefour figure is a potential daily penalty tied to a compliance order, not a fine already levied.
Ireland
Ireland is the only EU member state with criminal penalties for EAA non-compliance. Under S.I. No. 636/2023, serious or persistent non-compliance can be prosecuted as a criminal offence. On summary conviction: a fine up to €5,000 and/or imprisonment up to 6 months. On conviction on indictment (higher courts): a fine up to €60,000 and/or imprisonment up to 18 months.
Crucially, where a company commits an offence, directors, managers, secretaries, and other officers can be held personally liable. The liability follows the individuals whose decisions or neglect contributed to the non-compliance.
There is a due diligence defence available: a defendant who can demonstrate they exercised due diligence may have a case against the charge. Documented accessibility management (assessments, remediation records, governance processes) is the evidence that supports this defence.
ComReg is already processing formal complaints, including one against Three Ireland. Irish regulators review the accessibility statement first in any complaint investigation.
Netherlands
The Dutch ACM can impose fines up to 10% of annual turnover, with a ceiling of €900,000. The ACM is conducting active audits of organisations that failed to report non-conformance by the October 2025 deadline. ACM is moving toward formal sanctions in the second half of 2026, prioritising organisations that did not self-report.
The Netherlands has a mandatory reporting requirement that most organisations have missed: organisations must proactively report their accessibility compliance status to the ACM, with documentation and a compliance declaration ready on request. Failure to report, or submitting an incomplete report, prioritises an organisation for audit.
For financial services organisations, the relevant authority is the AFM, with the same enforcement mandate and penalty ceiling.
Reading this because a fine like this could apply to you? A free 20-minute conversation tells you whether the EAA applies to your organisation and what a proportionate next step looks like. Book your free assessment today. No obligation.
Sweden
The PTS has launched 28 supervisory investigations, including named inspections of H&M, IKEA, and Coop. Sweden's maximum penalty of SEK 10,000,000 (approximately €900,000) places it among the highest in Europe.
Sweden operates two distinct fine types. A Sanktionsavgift (a formal requirements fine of SEK 10,000 to SEK 10,000,000 per occurrence) applies to organisations that fail to report to or cooperate with PTS. This fine is triggered by non-cooperation regardless of whether the underlying accessibility issues have been fixed. A Vite applies to accessibility issues that have not been remediated within a grace period set by PTS. An organisation can face both simultaneously.
Sweden's disability rights culture means consumer awareness is high and complaints arrive quickly. Disability organisations are well-organised and actively monitoring digital services for EAA compliance. Penalty decisions are expected throughout 2026.
PTS also has market ban authority: it can prohibit the sale or distribution of non-compliant products and services within Sweden. For many organisations, a market ban represents a more severe consequence than a fine: losing access to the Swedish market, even temporarily, can mean significant revenue loss regardless of the financial penalty imposed.
The EAA applies where the service is offered, not where the company is headquartered. A US company selling to Dutch consumers is subject to ACM enforcement. A UK company selling to Irish consumers is subject to ComReg enforcement.
Beyond financial penalties
Not all EAA enforcement consequences are financial. Ireland carries criminal sanctions for directors. Sweden has market ban authority. These are covered in full in our EAA sanctions guide.
Germany
Germany's BFSG (Barrierefreiheitsstärkungsgesetz) implementation is notable for its private enforcement mechanism. Under German competition law (UWG), any competitor or law firm can send an Abmahnung (a private warning letter demanding compliance, legal costs, and a signed declaration) without any regulator being involved. The Bundesnetzagentur can separately impose fines of up to €100,000 per violation. See our BFSG enforcement guide for detail.
Find out where you stand
A free 20-minute conversation to find out whether the EAA applies to your organisation and where to begin, or, if you already know you need an audit, to talk through what that typically involves and what questions to answer first. No obligation, no assumptions.
Book your free assessment todayFor a focused guide to criminal sanctions and market bans specifically, see EAA sanctions: criminal liability and market bans.