EAA Enforcement in Numbers: What Has Actually Happened in the EU (2025-2026)

Q: What has the Netherlands done so far?

The ACM (the Dutch consumer and markets authority) published an enforcement investigation in March 2026 covering the 100 largest webshops in the Netherlands: 61% turned out to be inaccessible to customers with a disability, and the worst-scoring webshops were called out publicly (ACM, 24-03-2026). As of mid-2026, the Netherlands has not yet issued a completed EAA fine, the Dutch approach is tiered: a remediation order, then periodic penalty payments, and only after that a sales ban or administrative fine. But being called out publicly is already damage: it ends up in the newspaper, not in a file. The full Dutch picture is on our page the law in the Netherlands.

Q: Which country has already issued a fine?

Spain. Airline Vueling was fined €90,000 because its website failed to meet the accessibility requirements, confirmed by the Audiencia Nacional, Spain's national high court (Poder Judicial). That puts the Spanish risk firmly beyond theory. Spanish penalties run up to €1,000,000 for very serious infringements (Real Decreto Legislativo 1/2013). More on our page the law in Spain.

Q: What fines are at stake per country?

Germany, the Barrierefreiheitsstärkungsgesetz (BFSG) carries fines of up to €100,000 for the most serious infringements, on top of the Verbandsklage (collective action) (activeMind). Supervision runs through the joint state-level authority MLBF. See the law in Germany. France, two parallel tracks: since 1 January 2024 the Arcom has held formal fining powers of up to €50,000 per online service (public sector and large companies) and €25,000 for a missing accessibility statement (Arcom); the DGCCRF oversees the EAA track for private B2C. See the law in France. Italy, under Decreto Legislativo 82/2022, fines run up to €40,000, plus up to €30,000 on top; the regulator AgID adopted its concrete sanction regulation in May 2026 (Determinazione 84/2026) (AgID). Large companies under the Legge Stanca risk up to 5% of annual turnover. See the law in Italy. Spain, €30,000 (minor) up to €1,000,000 (very serious); the €90,000 Vueling fine fell in the middle category.

June 11, 2026

Short answer. Yes, enforcement of digital accessibility has begun in the EU, but at a different pace and along a different route in each country. The Netherlands deployed market surveillance and naming-and-shaming, Spain has already issued a court-confirmed fine of €90,000, Germany built a penalty regime of up to €100,000, and France and Italy have their regulators and sanction frameworks up and running. Anyone waiting "until enforcement actually starts" is watching a train that has already left the station. Below are the verified facts per country, each with a source.

Since when has the EAA applied?

The European Accessibility Act (Directive (EU) 2019/882) has applied since 28 June 2025 to digital products and services for consumers, including webshops. The benchmark is EN 301 549, the European standard based on WCAG 2.1 level AA. Only micro-enterprises (fewer than 10 employees and less than €2 million in turnover or balance sheet total) are exempt as service providers (EAA art. 4(5)). Each member state has transposed the directive into its own legislation, with its own regulators and its own fines, and that's where the big differences lie.

What has the Netherlands done so far?

The ACM (the Dutch consumer and markets authority) published an enforcement investigation in March 2026 covering the 100 largest webshops in the Netherlands: 61% turned out to be inaccessible to customers with a disability, and the worst-scoring webshops were called out publicly (ACM, 24-03-2026). As of mid-2026, the Netherlands has not yet issued a completed EAA fine, the Dutch approach is tiered: a remediation order, then periodic penalty payments, and only after that a sales ban or administrative fine. But being called out publicly is already damage: it ends up in the newspaper, not in a file. The full Dutch picture is on our page the law in the Netherlands.

Which country has already issued a fine?

Spain. Airline Vueling was fined €90,000 because its website failed to meet the accessibility requirements, confirmed by the Audiencia Nacional, Spain's national high court (Poder Judicial). That puts the Spanish risk firmly beyond theory. Spanish penalties run up to €1,000,000 for very serious infringements (Real Decreto Legislativo 1/2013). More on our page the law in Spain.

What fines are at stake per country?

Germany, the Barrierefreiheitsstärkungsgesetz (BFSG) carries fines of up to €100,000 for the most serious infringements, on top of the Verbandsklage (collective action) (activeMind). Supervision runs through the joint state-level authority MLBF. See the law in Germany.
France, two parallel tracks: since 1 January 2024 the Arcom has held formal fining powers of up to €50,000 per online service (public sector and large companies) and €25,000 for a missing accessibility statement (Arcom); the DGCCRF oversees the EAA track for private B2C. See the law in France.
Italy, under Decreto Legislativo 82/2022, fines run up to €40,000, plus up to €30,000 on top; the regulator AgID adopted its concrete sanction regulation in May 2026 (Determinazione 84/2026) (AgID). Large companies under the Legge Stanca risk up to 5% of annual turnover. See the law in Italy.
Spain, €30,000 (minor) up to €1,000,000 (very serious); the €90,000 Vueling fine fell in the middle category.

"But hardly anyone is enforcing this yet, right?"

That was a defensible position in 2025; in 2026 it no longer is. The patterns differ by country, but the direction is the same everywhere: regulators are staffed, sanction frameworks are in place, and the first public actions are a fact. More importantly: enforcement rarely starts with a fine. It starts with a letter, a remediation order or formal notice with a deadline. Whoever can produce a compliance file at that moment (scans, issues found, issues fixed, dates) is in a fundamentally different position from whoever has to start from scratch.

What does this mean for my webshop?

The EAA is market-based: if you sell to consumers in an EU country, that country's law applies to you, even if you're not established there. A single webshop serving German, French, and Spanish customers is therefore dealing with three enforcement regimes at once. The good news: the technical benchmark is the same everywhere (WCAG 2.1 AA / EN 301 549), so one structural approach covers all markets at the same time. Scan your website for free and see where you stand within a minute, and start building, today, the file you'll want to be able to show when that first letter arrives.