The EAA's First Year of Enforcement: Quiet, Not Empty

Conformly·

The European Accessibility Act became enforceable on 28 June 2025. Almost a year later, the question we hear most from agencies and their clients is a version of the same thing. Nobody got hit with a giant fine. So is any of this real?

It is real. It just did not arrive the way the scare pages promised.

The first year produced very few public regulator fines. What it produced instead was a record. Warning letters. Court filings. Sector inspections. A clear signal about how this law actually bites. If you read the silence as safety, you are reading it backwards. Here is what the first year looked like, and what it tells you about the rest of 2026.

Was the EAA actually enforced in its first year?

Yes, though not with blockbuster penalties. Enforcement happens at national level. Each member state writes its own rules and runs its own authority, so early action tends to be administrative, private, or local rather than one dramatic headline.

That is the same shape GDPR took. The first year after GDPR was mostly guidance, warnings, and quiet observation. The large fines came later, once authorities had built routines and a paper trail. Accessibility is following the same curve. The absence of a famous fine in year one is not a verdict that the law is toothless. It is the early part of a longer story.

France: the pressure came from civil society, not the regulator

The sharpest action of the first year did not come from a government agency at all. It came from disability organisations.

In July 2025, French disability groups including ApiDV, Droit Pluriel, and Intérêt à Agir sent formal legal notices to major retailers, among them Auchan, Carrefour, E.Leclerc, and Picard. The notices demanded that the retailers meet the accessibility duties France had written into its Consumer Code to transpose the EAA. When the deadline passed without fixes, the groups filed emergency injunctions at the Tribunal judiciaire de Paris in November 2025.

As of spring 2026 those cases were still pending, with no ruling and no fine yet. The precedent matters more than any single outcome. It shows you do not need a regulator to come knocking. An advocacy group with a lawyer and a screen reader can put your brand in front of a judge.

Germany: the warning letters started within weeks

Germany transposed the EAA through the Barrierefreiheitsstärkungsgesetz, the BFSG. Within weeks of it taking effect, online retailers began receiving private warning letters, the Abmahnungen that German competition and consumer law is known for.

These were not government penalties. They were private legal demands, often citing specific accessibility failures and asking for a fix plus costs. The lesson is uncomfortable and useful at once. In Germany, an accessibility gap can become a legal expense before any regulator opens a file. The exposure is immediate, and it does not wait for the state.

Sweden and the Netherlands: regulators chose process over punishment

Where national regulators did move, they moved patiently.

Sweden's Post and Telecom Authority opened its first cases focused on online retail and began systematic inspections, with the review set to continue through 2026. The Netherlands spread enforcement across several authorities and started a reporting duty in late 2025. A senior official at the Dutch consumer authority described the work as a process and said penalties were not the goal, acknowledging a wide gap between where industry sits today and what the law asks.

Read those two together and a pattern appears. The regulators are not hunting for a company to make an example of. They are building a baseline, opening cases, and expecting visible effort. Some authorities elsewhere have already moved to daily penalties, but only after an organisation failed to fix flagged issues in time.

The pattern that runs through all of it: a notice comes first

Look across France, Germany, Sweden, and the Netherlands and one mechanic repeats. Almost nobody gets fined out of nowhere. Something arrives first. A legal notice. A warning letter. An inspection. A request for your accessibility statement. Then a window to respond and fix.

That window is the whole game, and it is written into the law. The EAA's correction mechanism gives most organisations a chance to remedy a problem before a penalty lands. We covered that in detail in the EAA cure window. The first year of enforcement is the proof. The cases that escalate are the ones where nothing happened after the notice arrived.

Why "we are compliant" is the wrong thing to say

Here is the trap. When a notice or a letter arrives, the instinct is to reply that you are compliant. Resist it.

Accessibility on a live site is never finished. It depends on manual review and testing with assistive technology, not only on a scanner's pass. Claiming a clean bill of health you cannot fully back up is how you turn a fixable situation into a credibility problem. It is also why Conformly never asserts that a site is compliant. The word is not even something our data model can represent. What protects you is not a claim. It is evidence.

The strongest answer to a notice is boring and powerful at the same time. Here are the issues we found. Here are the fixes we shipped, as real changes in our codebase. Here is the date each one landed. Issues known, prioritised, fixed, and recorded. That is the posture authorities have signalled they reward.

Ignore the scare numbers, learn the mechanism

You will see a different penalty figure on every page. €250,000 per breach. 5% of turnover. €3 million. €1 million. They cannot all be right, and most are not. The EAA itself sets no single fine. Article 30 only requires that national penalties be effective, proportionate, and dissuasive, and leaves the amounts to each country. We separated the confirmed law from the invented figures in our country by country breakdown.

Chasing the scariest number is the wrong exercise anyway. The amount is set by the country and the severity. The outcome is set by what you can show when someone asks.

What to do for the rest of 2026

The first year handed you a clear brief. Stop trying to declare victory, and start being able to prove you are paying attention.

Three moves cover most of it. Know what is broken on your site, in detail, on a schedule. Fix the issues that matter and keep a dated record of each fix. Publish an honest accessibility statement that names your enforcement contact, as the law requires. None of that depends on claiming perfection. All of it depends on evidence.

That is the loop Conformly runs. It finds the issues, fixes them with real pull requests, and documents each step as dated evidence you can hand to anyone who asks. If you want to see where your site stands today, run a free audit. You will get the findings, not a badge.

Keep reading

BFSG fines explained: what German accessibility non-compliance actually costs

Germany's BFSG caps fines at €100,000 — not the €250,000 figure that circulates in vendor marketing. Here's what the law really says, who enforces it now, and how a fine actually happens.

How to write an EAA accessibility statement (without overclaiming)

Under EAA Article 13(2) and Annex V, your accessibility statement is a legal document — not a compliance badge. Here's what it must contain, and why 'fully compliant' is the trap to avoid.

The EAA cure window: why a notice isn't a fine — and why that's not a reason to wait

EU accessibility enforcement almost always starts with a correction period, not a fine. But you don't control the clock, you don't always get one, and the window only protects you if you can prove you acted. Here's how the cure window really works.