EAA fines: what non-compliance could cost

The European Accessibility Act has been in force since June 2025, and a lot of website owners are still unsure what that actually means for them. European Accessibility Act fines are real, enforcement is active, and the mechanism that triggers it is simpler than most people expect. This post explains how enforcement works, what EAA penalties look like, and what practical steps you can take to reduce your exposure.

What the European Accessibility Act requires

The European Accessibility Act (EAA) is EU legislation requiring businesses to make their digital products and services accessible to people with disabilities. It covers websites and web applications used to provide services to EU consumers: ecommerce stores, SaaS platforms, agency client sites.

One point worth knowing upfront: the EAA applies based on where your customers are, not where your business is registered. A US company selling software to EU users is in scope. So is a UK agency building sites for clients in Germany or France. The geographical reach is broad by design.

The technical standard the EAA maps to is WCAG 2.1 Level AA — the same benchmark used by accessibility regulations in most countries. For a full breakdown of what that means in practice, the EAA compliance overview covers the requirements in detail.

Who enforces the EAA?

This is the part most EAA articles either skip or get wrong. There is no single EU-wide body that proactively audits websites. Understanding how enforcement actually works changes how you should think about the risk.

Enforcement is member-state led

Each EU country designates its own national enforcement authority. Germany, France, the Netherlands, Ireland — every member state has appointed a body responsible for receiving complaints and investigating non-compliance. Implementation varies: some countries have dedicated digital accessibility units, others route complaints through existing consumer protection or telecoms regulators.

What they have in common is that they respond to complaints rather than running unsolicited audits. That distinction matters.

How complaints work

The process is straightforward. A user with a disability — or an accessibility advocacy organisation acting on behalf of users — files a complaint with the relevant national authority. The authority reviews it, investigates the site in question, and typically issues a remediation order: a formal notice giving the business a defined period to address the identified issues.

If the business complies within that period, the matter is usually resolved without a fine. If it does not, financial penalties apply.

This means that the risk of EAA sanctions is not random. It scales with how non-compliant your site is, how large and visible your EU audience is, and whether you respond to formal notice when it comes. A business that acts when told to is in a fundamentally different position from one that ignores repeated instructions.

What are EAA fines for non-compliance?

Fines vary by country

EAA penalties are set at the member state level, not by the regulation itself. This means fine amounts differ across the EU, sometimes significantly. Member state implementations generally allow for penalties ranging from several thousand euros for initial violations up to considerably larger amounts for systematic non-compliance or repeated failures to act after formal notice.

The size of the fine matters less than the structure. Most enforcement pathways begin with a remediation order, not a fine. Businesses that respond to that order in good faith — and can show documented effort to address accessibility issues — are rarely the ones who end up paying the largest penalties. The biggest risk belongs to organisations that are visibly non-compliant and unresponsive.

Micro-enterprise exemptions

The EAA includes an exemption for micro-enterprises, defined as businesses with fewer than 10 employees and an annual turnover or balance sheet total below €2 million. This exemption applies to some product and service categories, but it is narrow.

If your business is close to those thresholds, the safe assumption is that the EAA applies to you. The exemption was designed for the smallest sole traders, not for growing SMBs or agencies with established digital operations. When in doubt, treat the EAA as applicable and audit accordingly.

When did EAA enforcement start?

Commercial businesses became subject to EAA requirements on 28 June 2025. Public sector organisations in the EU have faced related obligations under the Web Accessibility Directive for longer, but the June 2025 date is when the EAA’s requirements for private-sector businesses came into force.

If your site was not accessible by that date, it is not too late to act, but the exposure is already present. Any EU user who encounters a barrier on your site today can file a complaint with their national authority.

How to avoid EAA fines

Complaint-based enforcement rewards businesses that have made a genuine, documented effort. A site with known issues but clear evidence of active remediation work is in a much stronger position than a site where nothing has been done.

Understand what’s required

Start by knowing where you stand against WCAG 2.1 Level AA — the standard the EAA maps to. The EAA compliance overview explains the framework, and the EAA compliance checklist gives you a structured list of what to work through. Knowing the requirement is the prerequisite for meeting it.

Audit your site

An accessibility audit identifies where your site falls short and gives you a concrete starting point for remediation. Scanluma scans your site against 50+ WCAG criteria and produces a report that shows each issue, where it appears, and the HTML involved — so you and your developer can see exactly what needs attention.

A free scan takes a few minutes and requires no setup. It will not give you a certificate of compliance, but it will show you your current position and the most significant gaps to address first.

Keep a compliance record

If a complaint is filed, the enforcement authority will look at what your business has done. Scan reports, issue logs, and documented remediation steps are all evidence of good faith. Scanluma’s automated weekly scanning keeps a history of your results over time. That record builds automatically as part of regular monitoring, with no extra effort on your part.

For agencies advising clients: encouraging clients to run regular scans and keep those reports is a straightforward way to build compliance evidence without adding significant overhead.

Publish an accessibility statement

The EAA requires businesses to publish an accessibility statement — a public declaration covering your site’s current accessibility status, known issues, and how users can contact you to request accessible alternatives or report problems. This is a separate topic from the audit itself, but it is part of the compliance picture and a visible signal that your business takes the obligation seriously.

Frequently asked questions

The EAA is in force, enforcement is complaint-driven, and documented compliance effort is what separates low-risk businesses from high-risk ones. The first practical step is understanding where your site currently stands.

Scanluma’s free scan checks your site against 50+ accessibility criteria and gives you a clear picture of what needs attention, with no setup or credit card required. Run a free scan and see where you stand today.