EAA fines, penalties and sanctions by country
Each EU member state sets its own penalty regime. Here is what enforcement looks like in the seven markets we monitor.
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 seven markets we monitor.
| Country | Maximum penalty | Criminal sanctions | Enforcement authority | Active enforcement |
|---|---|---|---|---|
| Ireland | €60,000 (on indictment) | Yes: up to 18 months imprisonment | ComReg (electronic communications); CCPC (products and general services) | No order or fine issued |
| Netherlands | No verified ceiling | No | ACM (Authority for Consumers and Markets); AFM (financial services) | Yes: ACM conducting active audits |
| Sweden | SEK 10,000,000 | No | PTS (Post and Telecom Authority) | Yes: 28 supervisory investigations launched including H&M, IKEA, Coop |
| Italy | €5,000–€40,000 for breaching the requirements; up to 5% of turnover for private organisations above €500m (Law 4/2004) | No | AgID (Agenzia per l'Italia Digitale) | Yes: cure period proportionate to nature of non-conformity |
| Finland | Not verified | No | Traficom | No named penalty decisions published |
| Germany | €100,000 (government fine) | No | Split federal/Länder; the MLBF, operational since 26 September 2025 | No confirmed government fine; private Abmahnungen (competition-law warning letters, a separate track from BFSG's own government enforcement) since transposition |
| France | €7,500 for a company, €15,000 on récidive. No administrative fine: a penalty needs a procès-verbal and a prosecutor | Yes: fifth-class contravention (fines only) | DGCCRF (controls); French courts (civil society litigation) | Order issued against Carrefour (June 2026) with a daily astreinte, not a fine; Auchan dismissed on procedural grounds; E.Leclerc hearing listed 22 Sep 2026, no outcome reported; Picard pending |
We have found no EAA fine in France. French EAA penalties are criminal rather than administrative (5th-class contravention, art. R. 451-4 code de la consommation), and DGCCRF’s published sanctions list, which carries criminal convictions, shows no accessibility entry. The Carrefour figure is a potential daily penalty tied to a compliance order, not a fine already levied. The French figures derive from articles 131-13 and 131-41 of the Code pénal, and reconcile with DGCCRF’s guidance of 13 November 2025.
Ireland
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, a director, manager, secretary or other officer also commits an offence if it was committed with their consent, connivance or approval, or is attributable to their wilful neglect (Regulation 33).
It is a defence for the person charged to prove that they exercised due diligence and took all reasonable precautions to avoid the offence (Regulation 34). Documented accessibility management (assessments, remediation records, governance processes) is the evidence that supports this defence.
No order or fine has been issued.
Netherlands
No Dutch fine ceiling is verified. Financial penalties have been legally available since June 2025. None has been issued. The ACM’s published posture is compliance first.
The ACM says that if your e-commerce or electronic communications service is not accessible, you must fix it straight away. If you can’t, you must report it: within a week for critical or serious problems, within a month for moderate or minor ones. You send a plan for making the service fully accessible with the report. For financial e-commerce and banking services, the AFM takes these reports on the same terms.
Reading this because a fine like this could apply to you? A free 20-minute conversation covering whether your services are likely to be in scope of the EAA, 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 is SEK 10,000,000. The figure that matters legally is the krona amount.
Sweden has two financial instruments. A sanktionsavgift of SEK 10,000 to SEK 10,000,000 can be imposed for breaching the duties listed in section 37, including the duty to keep a service accessible and to tell the supervisory authorities immediately when it is not (Lag (2023:254), sections 24, 37 and 39). A vite is a conditional fine that PTS may attach to an order to put a breach right (section 35). Under section 38, a sanktionsavgift cannot be imposed for a breach covered by a föreläggande om vite where that breach is the basis of an application to have the vite imposed.
For products, where the operator does not correct the non-compliance, the market surveillance authority must ensure the product is withdrawn or recalled, or its supply prohibited or restricted (Regulation (EU) 2019/1020, article 16(5), applied by section 28 of Lag (2023:254)).
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 Irish enforcement.
Beyond financial penalties
Not all EAA enforcement consequences are financial. Ireland carries criminal sanctions for directors. In Sweden, non-compliant products can be taken off the market. 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 MLBF, the market surveillance authority, can separately impose fines of up to €100,000. See our BFSG enforcement guide for detail.
Find out where you stand
A free 20-minute conversation covering whether your services are likely to be in scope of the EAA, and where to begin. If you already know you need an audit, we can 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.