EU Accessibility Act Is Now Enforced: What Happened to Companies That Weren't Ready

The deadline came and went. On June 28, 2025, the European Accessibility Act became enforceable across all EU member states. For years, regulators warned that this was coming. Accessibility advocates pushed for it. Industry groups lobbied against the timeline. And a significant number of companies — from scrappy startups to billion-euro enterprises — simply did not prepare.

Now, seven months later, the consequences are materializing. Regulators in multiple EU member states are issuing fines, publishing non-compliance notices, and processing a growing backlog of consumer complaints. If your digital products serve EU customers and you still have not addressed EAA compliance, the window for quiet remediation is closing fast.

This article covers what the EU Accessibility Act requires, what enforcement looks like on the ground in early 2026, who is affected, and a practical remediation guide for teams that need to act now.

What the EU Accessibility Act Actually Requires

The European Accessibility Act (Directive 2019/882) is not a suggestion. It is a binding legal framework that requires digital products and services sold in the EU to meet specific accessibility standards. The directive was adopted in 2019, giving companies six years to prepare. The transposition deadline for member states was June 28, 2022. The enforcement deadline for businesses was June 28, 2025.

The EAA covers a broad range of products and services:

• Websites and web applications — Any site offering products or services to EU consumers
• Mobile applications — iOS and Android apps used for commerce, banking, or services
• E-commerce platforms — Online stores, marketplaces, and checkout flows
• Banking and financial services — Online banking, payment terminals, ATMs
• Transport services — Ticketing systems, booking platforms, travel information
• E-books and e-readers — Digital publishing platforms and reading devices
• Telecommunications — Messaging services, video calling, customer support systems
• Consumer hardware — Computers, smartphones, tablets, self-service terminals

The technical standard underpinning EAA compliance is EN 301 549, which maps closely to WCAG 2.1 Level AA (and increasingly references WCAG 2.2). In practical terms, this means your digital products must be perceivable, operable, understandable, and robust for people with disabilities — including those using screen readers, keyboard-only navigation, voice controls, and other assistive technologies.

This is not limited to "accessibility overlays" or bolt-on widgets. The EAA demands that accessibility is built into the product itself.

The Enforcement Landscape in Early 2026

One of the most common misconceptions about the EAA was that enforcement would be slow. That member states would drag their feet, that regulators would issue warnings before fines, that there would be a de facto grace period.

That has turned out to be partially true in some countries and entirely false in others.

Countries Actively Enforcing

Germany has been among the most aggressive enforcers. The Barrierefreiheitsstarkungsgesetz (BFSG), Germany's transposition of the EAA, empowered the Federal Network Agency (Bundesnetzagentur) to conduct market surveillance. By late 2025, the agency had begun issuing formal non-compliance notices to e-commerce platforms and banking services. Fines under the BFSG can reach up to 100,000 euros per violation, with repeat offenders facing escalating penalties.

France has similarly moved quickly. The ARCOM (formerly CSA) and DGCCRF have been processing complaints and conducting audits of major digital services. France's implementation includes provisions for consumer organizations to file collective complaints, which has accelerated enforcement activity.

The Netherlands designated the Dutch Authority for Consumers and Markets (ACM) as the enforcement body. The ACM has focused initially on financial services and e-commerce, sectors where accessibility barriers directly affect consumer transactions.

Spain, Italy, and Ireland have established enforcement mechanisms, though action has been slower. In these countries, the complaint-driven model means enforcement is largely reactive — regulators respond to filed complaints rather than proactively auditing companies.

Nordic countries (Sweden, Finland, Denmark) have integrated EAA enforcement into existing digital accessibility frameworks. Sweden's Agency for Digital Government (DIGG) has been particularly transparent, publishing compliance guidelines and audit results publicly.

Types of Penalties

Penalties under the EAA vary significantly by member state because the directive allows each country to define its own sanctions. Common penalty structures include:

• Administrative fines — Ranging from 10,000 to 100,000+ euros depending on the country, severity, and whether the company has shown intent to remediate
• Product withdrawal orders — Regulators can order non-compliant digital products to be withdrawn from the market
• Public non-compliance notices — Some countries publish the names of non-compliant companies, creating reputational damage
• Injunctions — Courts can order companies to make their products accessible within a set timeframe, with daily penalties for continued non-compliance
• Consumer compensation — Individuals affected by inaccessible services may be entitled to compensation

The fines may seem modest compared to GDPR penalties, but the compounding effect is significant. Each product, each service, and each violation can be penalized separately. A company with an inaccessible website, mobile app, and payment system could face three separate enforcement actions.

Real Consequences: What Is Happening to Non-Compliant Companies

While regulatory bodies have not published comprehensive enforcement databases yet, the pattern emerging across member states is clear.

Scenario 1: The Mid-Size E-Commerce Platform

A mid-size fashion retailer based in the Netherlands, selling across 12 EU countries, received a formal complaint through the ACM in September 2025. The complaint identified that the checkout flow was entirely inaccessible to screen reader users — form labels were missing, error messages were not announced, and the payment step required mouse interaction with no keyboard alternative. The ACM gave the company 90 days to remediate. When the follow-up audit in December found only partial fixes, the company received a fine of 25,000 euros and a mandate to achieve full compliance within 60 additional days, with daily penalties of 1,000 euros for continued non-compliance.

Scenario 2: The SaaS Company With EU Customers

A US-based SaaS company offering project management tools had roughly 30% of its customer base in the EU. The company assumed the EAA only applied to EU-based businesses. It does not. The EAA has extraterritorial reach — any company offering products or services to EU consumers is subject to the directive, regardless of where the company is headquartered. A complaint filed in Germany triggered an investigation, and the company is now facing a choice between making its platform accessible or withdrawing from the EU market entirely.

Scenario 3: The Banking App

A digital-only bank operating in France and Germany received multiple consumer complaints about its mobile application. Key issues included low color contrast ratios, touch targets too small for motor-impaired users, and a complete lack of screen reader support for account balance and transaction history. The French ARCOM issued a formal warning in October 2025, followed by a 50,000-euro fine in December when remediation was deemed insufficient.

These scenarios illustrate an essential point: enforcement is not theoretical. It is happening, and it targets both the obvious violations (no screen reader support at all) and the subtler ones (inadequate contrast, missing form labels, non-functional keyboard navigation).

Who Is Affected: The Extraterritorial Reach of the EAA

This is the part many companies outside Europe still do not fully understand. The EU Accessibility Act applies to any economic operator that places products on the EU market or provides services to EU consumers. This includes:

• EU-based companies of any size (with limited exceptions for micro-enterprises with fewer than 10 employees and under 2 million euros in turnover)
• Non-EU companies that sell products or services to EU customers, including through websites, app stores, and online marketplaces
• Companies using EU-based payment processors or shipping to EU addresses
• SaaS platforms with EU subscribers

If your website is accessible from the EU, accepts payments in euros, or has any EU customer base, you are likely within scope. The "we're not an EU company" defense does not hold.

Practical Remediation Guide: What to Do Right Now

If you are reading this in January 2026 and your digital products are not yet compliant, the situation is urgent but not hopeless. Here is a practical, prioritized approach to getting compliant as quickly as possible.

Step 1: Run an Automated Accessibility Audit Immediately

Before you can fix anything, you need to know the scope of the problem. Automated tools will not catch every accessibility issue — they typically find 30-50% of WCAG violations — but they give you a comprehensive baseline in minutes rather than weeks.

Tools to use:

• axe-core — The industry-standard open-source accessibility testing engine. Integrates with browser DevTools and CI/CD pipelines.
• WAVE — A web-based evaluation tool from WebAIM that provides visual feedback on accessibility issues.
• Plaintest — Runs automated accessibility audits as part of its AI-driven exploration. When Plaintest explores your application, it automatically runs axe-core checks on every screen it discovers, catching violations across your entire app — not just the pages you remember to test.

Run these audits on your production site, your staging environment, and your mobile apps. Export the results and categorize issues by severity.

Step 2: Prioritize by Impact

You cannot fix everything at once. Prioritize the issues that affect the most users and carry the highest compliance risk:

1. Keyboard navigation — Every interactive element must be reachable and operable with a keyboard alone. This is the single most common barrier and the first thing auditors check.
2. Color contrast — Text must meet minimum contrast ratios (4.5:1 for normal text, 3:1 for large text). Low contrast affects users with low vision and is trivially detectable by automated tools.
3. Alternative text — Every meaningful image needs descriptive alt text. Decorative images need empty alt attributes (alt="").
4. Form labels — Every input field must have a programmatically associated label. Missing labels make forms unusable for screen reader users.
5. Focus indicators — Users navigating with a keyboard must be able to see which element is currently focused. Never remove the focus outline without providing an alternative.
6. Error identification — Form validation errors must be clearly described and associated with the relevant input field.
7. Heading structure — Use a logical heading hierarchy (h1, h2, h3) so screen reader users can navigate by document structure.

Step 3: Test With Real Assistive Technologies

Automated tools are mandatory but not sufficient. You must test with actual assistive technologies to catch the issues that automated scans miss:

• NVDA (free, Windows) — The most widely used free screen reader. Test your critical user flows with NVDA and a keyboard only.
• VoiceOver (built into macOS and iOS) — Essential for testing on Apple devices. Activate with Cmd+F5 on Mac.
• JAWS (commercial, Windows) — The most common screen reader in enterprise environments.
• TalkBack (built into Android) — Required for Android app testing.

Focus your manual testing on critical paths: login, registration, checkout, account management, and any flow that involves forms or transactions.

Step 4: Document Your Accessibility Statement

The EAA requires that you publish an accessibility statement describing:

• The accessibility standard you are targeting (EN 301 549, WCAG 2.1 AA, or WCAG 2.2 AA)
• Known limitations and areas of non-compliance
• A timeline for remediation of known issues
• Contact information for accessibility feedback and complaints
• The date the statement was last reviewed

This is not optional. An accessibility statement demonstrates good faith and provides a channel for users to report barriers. Many enforcement bodies check for an accessibility statement as a first step in their assessment.

Step 5: Establish Ongoing Monitoring and Regression Testing

Fixing accessibility issues once is not enough. Every new feature, every design change, every dependency update can introduce regressions. You need continuous monitoring built into your development workflow.

Integrate accessibility checks into your CI/CD pipeline. Every pull request should run automated accessibility tests before merging. This catches regressions at the point where they are cheapest to fix — before they reach production.

Plaintest integrates accessibility auditing directly into its automated test runs. When you run a test suite, Plaintest's AI explores your application and flags WCAG violations as part of the same workflow that catches functional bugs. This means accessibility regressions are caught alongside broken buttons and failed logins, in the same test report, without requiring a separate audit process.

Other CI/CD-integrated accessibility tools include axe-core with Playwright or Cypress, pa11y-ci, and Lighthouse CI.

Step 6: Train Your Development Team on WCAG 2.2

Long-term compliance requires that your developers, designers, and product managers understand accessibility fundamentals. This does not mean everyone needs to become an accessibility expert. It means everyone needs to know the basics:

• Semantic HTML — Use the right elements for the right purpose. Buttons for actions, links for navigation, headings for structure.
• ARIA when necessary — ARIA attributes supplement native HTML semantics. The first rule of ARIA is "don't use ARIA if native HTML will do the job."
• Responsive and flexible design — Content must reflow at 400% zoom. Text spacing must be adjustable. Touch targets must be at least 24x24 CSS pixels (a WCAG 2.2 addition).
• Motion and animation — Respect the prefers-reduced-motion media query. Never use flashing content that could trigger seizures.
• Testing habits — Developers should tab through their interfaces regularly. Designers should check contrast ratios during design, not after implementation.

WebAIM, Deque University, and the W3C's own WCAG 2.2 documentation offer free and paid training resources. Invest in a half-day workshop for your team. The cost is negligible compared to a single enforcement fine.

Automated Testing as a Compliance Strategy

One of the most effective ways to protect your organization from EAA enforcement is to make accessibility testing automatic and continuous. Manual audits conducted once or twice a year are insufficient — they create a snapshot that becomes outdated the moment new code is deployed.

Modern CI/CD pipelines should include:

• Pre-merge accessibility checks — Block pull requests that introduce new WCAG violations
• Full-application accessibility scans — Regularly scan your entire application, not just individual pages
• Regression tracking — Track the total number of violations over time and alert when the count increases

This is where tools like Plaintest provide a comprehensive advantage. Because Plaintest's AI autonomously explores your application — clicking buttons, filling forms, navigating between screens — it discovers accessibility issues on pages that manual testers and page-by-page scanners might miss. The exploration-based approach means new pages and flows are automatically included in the audit without updating a test script.

For teams building web applications, integrating axe-core into your Playwright or Cypress tests is another essential step. The combination of targeted unit-level accessibility tests and broad application-level scans creates a layered defense against regressions.

What Comes Next: The EAA Enforcement Trajectory

Enforcement will only intensify from here. Several factors point to escalation throughout 2026 and beyond:

Consumer awareness is growing. Disability rights organizations across Europe are actively educating consumers about their rights under the EAA, including how to file complaints. The number of complaints is increasing month over month.

Regulators are building capacity. Many enforcement bodies spent the second half of 2025 hiring staff, developing audit methodologies, and building tooling. They are now operational and scaling up.

Cross-border enforcement is coming. The EAA includes provisions for market surveillance cooperation between member states. A complaint filed in one country could trigger investigations in others, especially for companies operating across multiple EU markets.

The European Commission is watching. The Commission is required to review the implementation of the EAA and report to the European Parliament. Member states that are not enforcing adequately will face pressure.

Private litigation is emerging. Beyond regulatory enforcement, the EAA creates a foundation for private legal action. Consumers and advocacy groups can sue for damages, and law firms specializing in digital accessibility are expanding their EU practices.

The Cost of Inaction vs. the Cost of Compliance

Let us be direct about the math. Making a typical web application compliant with WCAG 2.2 AA costs a fraction of what a single enforcement fine plus forced remediation costs. The numbers:

• Proactive compliance — An accessibility audit, remediation sprint, and ongoing monitoring setup typically costs between 10,000 and 50,000 euros for a mid-size application, depending on the severity of existing issues.
• Reactive remediation after enforcement — The fine alone can be 25,000 to 100,000 euros. Add the cost of emergency remediation (which is always more expensive than planned work), legal fees, and reputational damage, and the total easily exceeds 200,000 euros.

Beyond the financial calculus, there is the fundamental reality that accessible products serve more customers. Over 100 million people in the EU have some form of disability. An accessible product is a better product for everyone — it works on slow connections, small screens, in bright sunlight, and with voice assistants.

Key Takeaways

The EU Accessibility Act is not a future concern. It is current law, actively enforced, with real financial and operational consequences for non-compliant companies.

If you are not yet compliant:

1. Run automated accessibility audits today — use axe-core, WAVE, or Plaintest to understand your current state
2. Prioritize keyboard navigation, contrast, alt text, and form labels
3. Test with real screen readers — NVDA, VoiceOver, JAWS
4. Publish an accessibility statement on your website
5. Integrate accessibility testing into your CI/CD pipeline so regressions are caught automatically
6. Train your team on WCAG 2.2 fundamentals

If you are compliant:

1. Maintain your compliance with continuous automated testing
2. Update your accessibility statement regularly
3. Monitor for new WCAG 2.2 requirements and EU guidance updates
4. Keep records of your compliance efforts — documentation matters during audits

The EAA deadline has passed. Enforcement is here. The companies that act now will protect themselves from fines, serve a broader customer base, and build better products. The companies that continue to wait are accumulating risk with every passing month.

Plaintest automatically detects accessibility violations during AI-powered test exploration. Every test run includes a WCAG audit across every screen discovered. Start a free accessibility audit today.