How enforcement looks so far

The European Accessibility Act began to apply in June 2025. Because penalties and regulators are set nationally, enforcement differs by country. Commentary reports that some member states moved into formal proceedings quickly while others were still building monitoring capacity. In France, advocacy groups sent formal notices to several large grocery retailers soon after the date, and a May 2026 case against one of them was reportedly dismissed even though the court noted the site did not meet accessibility standards. In the Netherlands the regulator is reported to have moved from a self-reporting phase to active audits.

Reporting on fines and penalty ceilings is inconsistent, and several figures circulating online come from garbled tables or vendor posts, so check national regulators before relying on any number.

E-commerce checkout flows and consumer storefronts are repeatedly reported as the center of early enforcement attention. If you sell online to EU consumers, start there.

An engineering plan that holds up anywhere

The technical benchmark most teams use is the European standard EN 301 549, which incorporates WCAG 2.1 Level AA for web content. Build to that and you are well placed across member states. Note that microenterprises providing services have an exemption, but that does not help larger sellers, and customers' expectations do not follow the exemption anyway.

Automated scanners catch only a portion of issues, so combine them with manual checks and testing with assistive technology. Prioritize the highest-impact journeys: search, product pages, cart, checkout, account, and support.

Test the real journeys

Run keyboard-only and screen-reader passes on the checkout path and fix blockers first.

Publish and maintain a statement

Keep an accessibility statement and a feedback route, and document known issues with timelines.

Build accessibility into delivery

Retrofits are expensive. Add accessibility checks to design reviews, component libraries, and the build pipeline, and train teams on common failures such as missing labels, poor focus handling, and low contrast. Track defects like any other quality issue.

That also makes it easier to respond to a complaint, since you can show a program rather than a scramble.

Selling online into the EU? Talk to us about an accessibility audit and remediation plan.

Key takeaways

  • The EAA applies EU-wide but enforcement and penalties are national, so the picture is uneven.
  • E-commerce checkout and storefronts are a central early focus.
  • Build to EN 301 549, which incorporates WCAG 2.1 AA, and combine automated and manual testing.
  • Embed accessibility in design, components, and pipelines to avoid expensive retrofits.
This is general information, not legal advice. Many sources are vendor and law-firm commentary; check national regulators and the Commission before relying on enforcement or penalty details.