The European Accessibility Act took effect on 28 June 2025. Ten months in, the most common question from companies with mobile apps is straightforward: what actually happens if we are not compliant?
This post answers that question country by country, using verified sources. Where evidence is strong, we say so. Where it comes from vendor marketing materials without primary legal citations, we flag that too.
The short version: penalties vary wildly across the EU. No fines have been issued yet under any EAA-transposed law. But enforcement machinery is running, legal notices have been filed, and private actors in Germany started sending warning letters within weeks of the law taking effect. This is a practical reference, not a scare piece.
How EAA Penalties Work
The EAA (Directive 2019/882) required each of the 27 EU member states to transpose it into national law by 28 June 2025. Each country set its own penalties, enforcement authorities, and mechanisms.
The Directive itself does not specify fine amounts. Article 30 requires only that penalties be "effective, proportionate and dissuasive." This is why you see such wide variation between countries.
Enforcement can take several forms depending on the member state:
- Regulatory fines issued by market surveillance or consumer protection authorities
- Product or service withdrawal from the market
- Mandatory corrective actions with deadlines
- Private legal action by consumers, disability organisations, or competitors
One important clarification: the often-quoted "EUR 250,000 per breach" figure does not appear anywhere in the Directive. It originates from vendor marketing materials and compliance tool websites. Do not treat it as a statutory figure.
Country-by-Country Penalties
Countries With Strong Evidence
The following penalty figures are confirmed through primary legislation, official legal analyses, or multiple independent law firm assessments.
Germany
Germany transposed the EAA through the BFSG, which took effect on 28 June 2025. Market surveillance is split between federal and Länder authorities. Multiple German law firm analyses confirm the EUR 100,000 maximum. Enforcement focuses on product and service providers, with e-commerce operators receiving the earliest attention.
Spain
Spain has the steepest confirmed penalties in the EU. Fines are tiered: minor infractions range from EUR 301 to EUR 30,000, serious infractions from EUR 30,001 to EUR 90,000, and very serious infractions from EUR 90,001 to EUR 1,000,000. Authorities can also suspend business activity for up to three years.
Ireland
Ireland is the only confirmed EU member state where EAA violations can carry criminal liability. The maximum penalty is EUR 60,000 in fines and/or 18 months imprisonment. This applies to service providers who fail to meet accessibility requirements after being given notice to comply.
France
French penalties for accessibility non-compliance are set through amendments to the Consumer Code transposing the EAA. The confirmed figure is EUR 7,500 per infraction, rising to EUR 15,000 for repeat offences. Authorities can also order product withdrawal from the market. Some industry sources cite higher figures up to EUR 250,000, but these are not confirmed against the primary legislation.
Italy
Italy extended its existing Stanca Law (Law 4/2004) through Legislative Decree 82/2022 to cover EAA requirements. AgID (Agenzia per l'Italia Digitale) enforces accessibility obligations. Penalties can reach EUR 40,000 or 5% of turnover. Note that Italy's enforcement framework is not purely EAA-specific and predates the Directive.
Countries With Indicative Evidence
The following figures appear in industry compliance matrices and vendor reports. We have not been able to verify them against primary legislation or official government sources. Treat them as indicative.
- Netherlands: EUR 100,000 to EUR 250,000 reported. No primary statute cited.
- Sweden: approximately EUR 200,000 reported. Vendor tables only.
- Belgium: EUR 50,000 to EUR 200,000 reported. Sources conflict on the upper bound.
- Austria: approximately EUR 200,000 reported. Vendor matrix, no statutory citation.
- Poland: approximately EUR 200,000 reported. Vendor matrix.
- Portugal: EUR 5,000 to EUR 100,000 reported. Vendor matrix.
- Greece: EUR 2,000 to EUR 100,000 reported. Vendor matrix.
- Croatia: EUR 2,000 to EUR 50,000 reported. Vendor matrix.
If your business operates in any of these countries, verify penalties against the specific national transposition law. We will update this section as primary sources become available.
What Has Actually Happened Since June 2025
This is the section that matters most. Here is what has actually occurred in the ten months since the EAA took effect.
France: Disability Organisations File Legal Action
In July 2025, three French disability organisations (ApiDV, Droit Pluriel, and Intérêt à Agir) sent formal legal notices to major retailers including Auchan, Carrefour, E.Leclerc, and Picard. The notices demanded accessibility compliance with the transposed EAA requirements by September 2025.
When the retailers failed to act, the organisations filed emergency injunctions before the Tribunal judiciaire de Paris in November 2025. The legal basis was the French Consumer Code as amended to transpose the EAA.
As of April 2026, these cases remain pending. No court ruling has been issued and no fines have been imposed. But the cases established an important precedent: enforcement action in France is being driven by civil society, not regulators. The injunctions targeted both websites and mobile applications.
Germany: Private Warning Letters Arrive Fast
Within weeks of the BFSG taking effect in August 2025, e-commerce operators in Germany began receiving private warning letters (Abmahnungen) citing accessibility violations.
These letters were not sent by regulators or disability organisations. They came from opportunistic law firms using Germany's competition law framework (UWG), not the BFSG directly. The targets were web shops. No confirmed cases involved mobile app operators.
Legal assessments from specialist firms including Heuking, IT-Recht-Kanzlei, and Mueller.legal characterised most early warnings as legally weak. The Handelsverband Hessen (Hesse Retail Association) issued guidance advising members not to pay settlements without legal review.
The mechanism matters: these were private commercial disputes, not regulatory enforcement. But they demonstrate that accessibility compliance gaps create immediate legal exposure in Germany, even if the regulator has not yet acted.
Netherlands: Self-Reporting and Multi-Authority Oversight
The Dutch transposition came into force on 28 June 2025. A mandatory self-reporting obligation began in October 2025, after a voluntary window closed on 15 October.
The Netherlands has distributed enforcement across multiple authorities: ACM handles e-commerce, AFM covers financial services, RDI oversees products, CvdM monitors media services, and ILT manages transport. Secondary sources report follow-up investigations underway as of March 2026, but no formal audit activity has been confirmed from primary ACM sources.
The Honest Summary
As of April 2026:
- No fines have been issued anywhere in the EU under EAA-transposed laws
- No court has ruled on an EAA accessibility case
- No mobile app operator has been specifically targeted by a regulator
- Private legal action (France) and private warning letters (Germany) are the only confirmed enforcement activity
This does not mean enforcement is not coming. It means we are in the early warning period. Regulators are building capacity, civil society is testing legal mechanisms, and private actors in Germany have already found commercial incentive to pursue non-compliant businesses.
Beyond Fines: Other Consequences
Financial penalties are only one risk. Depending on the member state, non-compliance can trigger:
- Product or service withdrawal from market. Regulators can order you to remove a non-compliant digital product or service from the EU market entirely.
- Mandatory corrective actions. Authorities can require specific remediation within fixed deadlines, with escalating penalties for non-compliance.
- Loss of public procurement eligibility. Non-compliant products and services may be excluded from government procurement processes across the EU.
- Private litigation. Several member states, including the Netherlands, explicitly allow consumer civil remedies for accessibility failures. This creates exposure beyond regulatory action.
- Reputational damage. Enforcement actions are public. For companies that serve disability communities or sell accessibility-adjacent products, a public finding of non-compliance carries significant brand risk.
- Business suspension. In Spain, authorities can suspend business activity for up to three years for very serious infractions.
What This Means for Mobile App Operators
Mobile apps are explicitly in scope of the EAA. The technical standard is EN 301 549, with Chapter 11 covering native mobile app requirements including VoiceOver and TalkBack compatibility, platform accessibility service support, and OS preference inheritance.
No mobile-specific enforcement has occurred yet. But the French injunctions targeted both websites and apps, and the pattern from web accessibility enforcement over the past decade is clear: web first (it is easier to test programmatically), then apps.
The microenterprise exemption applies only to businesses with fewer than 10 employees and less than EUR 2 million in annual turnover, and only for services. If your organisation is above either threshold, the exemption does not apply.
One practical point: an accessibility audit now costs a fraction of what a single German Abmahnung response costs in legal fees. The economics favour proactive compliance.
Start With an Audit
AUDITSU walks your team through every EN 301 549 requirement your mobile app needs to meet. Failed items become tracked tickets. Your accessibility statement updates as you fix issues.
Start your first audit