EAA Penalties — What UK Businesses Risk 2026

„What happens if my UK business doesn't comply with the EAA?" That's a question many UK business owners ask when they learn about the European Accessibility Act.

In this guide, we'll explain what penalties UK businesses face for EAA non-compliance, how enforcement works, and how to avoid penalties.

EAA Penalties — Overview

The EAA requires EU member states to impose effective, proportionate, and dissuasive penalties for non-compliance. Penalties vary by country but can be significant.

1. Financial penalties

Financial penalties for EAA non-compliance can be substantial:

Maximum penalties by country:

• General EU-wide: Up to €900,000 or 4% of annual turnover
• Belgium: Up to 3% of annual turnover
• Germany: Up to €100,000
• France: Up to €300,000
• Italy: Up to €1,000,000
• Spain: Up to €1,000,000

What determines the fine amount?

• Severity of the violation
• Duration of the violation
• Previous violations — repeat offenders face higher fines
• Efforts made to comply
• Size of the business — larger businesses face higher fines

2. Trading restrictions

EU member state authorities can impose trading restrictions on non-compliant products and services:

What can happen?

• Product ban — products removed from the EU market
• Service restriction — services suspended in the EU
• Sales prohibition — cannot sell to EU customers
• Recall orders — products already sold must be recalled

Which countries have the strictest enforcement?

• Italy — up to €1,000,000 fines, aggressive enforcement
• Spain — up to €1,000,000 fines, strict enforcement
• France — up to €300,000 fines
• Germany — up to €100,000 fines

3. Legal costs

Defending against EAA enforcement action can be expensive:

• Legal representation — solicitors and barristers
• Expert witness fees — accessibility experts
• Court costs — filing fees, hearings
• Compliance costs — fixing issues after enforcement

Even if you win, legal costs can be significant.

4. Reputational damage

EAA non-compliance can lead to significant reputational damage:

Consequences:

• Negative publicity — media coverage of enforcement action
• Loss of customers — customers choose accessible competitors
• Loss of partners — business partners may distance themselves
• Brand damage — long-term impact on brand image
• Loss of trust — customers lose trust in your business

How enforcement works

EAA enforcement is carried out by national authorities in each EU member state:

Enforcement process:

Step 1: Complaint filed

A consumer, competitor, or organisation files a complaint with the national authority.

Step 2: Investigation

The authority investigates the complaint and gathers evidence.

Step 3: Warning

The authority issues a warning and gives you time to fix the issue.

Step 4: Enforcement action

If you don't comply, the authority takes enforcement action:

• Financial penalty — fine imposed
• Trading restriction — products/services restricted
• Court action — legal proceedings started

Who enforces the EAA?

Each EU member state has a designated enforcement authority:

• Germany — Bundesnetzagentur (Federal Network Agency)
• France — Arcep (Electronic Communications Regulator)
• Italy — AGCOM (Communications Regulator)
• Spain — CNMC (Markets and Competition Commission)
• Belgium — BIPT (Postal and Telecommunications Institute)

Important: These authorities can enforce against UK businesses that trade in the EU.

How to avoid EAA penalties

Step 1: Determine if the EAA applies

Check if your UK business trades in the EU and is covered by the EAA.

Step 2: Scan your website

Use the free UK ADA checker to scan your website against WCAG 2.2 Level AA.

Step 3: Fix all violations

Follow the recommendations in the report to fix all violations.

Step 4: Publish an accessibility statement

Publish an accessibility statement on your website (required under the EAA).

Step 5: Document everything

Document all tests and improvements. This serves as evidence of your compliance efforts.

Step 6: Monitor and update

Monitor your website regularly and update your accessibility statement at least once a year.

Frequently Asked Questions — EAA Penalties

Internal links — UK Accessibility Resources