The European Accessibility Act came into force on 28 June 2025. A year later, the enforcement scoreboard looked like this: zero fines, anywhere in the European Union, under any national transposition.
Most boards read that as permission to keep waiting. It is the wrong reading, and 2026 explains why.
Two French rulings landed within a month of each other.
On 5 May 2026 the Tribunal judiciaire de Lille issued the first ruling under an EAA transposition. It went against the claimants — but not on the merits. The court found the site only 41% compliant and then dismissed the case on scope, because France's threshold applies above €250 million in revenue and the Auchan e-commerce subsidiary in question reported €144 million. The disability associations appealed to the Cour d'appel de Douai.
On June 2026 the Tribunal judiciaire de Caen ordered Carrefour to make both its e-commerce site and its mobile app fully accessible within six months, under a penalty of €500 per day of delay — the first ruling against a retailer and the first to cover a mobile app.
Read those together and the picture inverts. The absence of fines is not evidence that nothing is happening. It is evidence that the enforcement instrument is not a fine.
The risk you are actually carrying
A fine is a number. You can provision for it, argue it down, treat it as a cost of doing business. Plenty of companies do exactly that with GDPR.
An injunction with a daily penalty is a different animal. It does not ask what you can afford. It sets a date, and after that date the meter runs.
So the question for your business is not "what is the maximum fine in my country". It is: if a court gave you six months to make your website and your app fully accessible, could you do it?
For a two-year-old site built with accessibility considered from the start, six months is comfortable. For a site assembled from a theme, twelve plugins, three embedded widgets and a checkout provided by a third party, six months is not obviously achievable at any price — because you do not control most of the code you would have to fix.
That is the real exposure. Accessibility debt is the only technical debt with a court-imposed due date, and unlike most debt, you cannot pay it off faster by spending more.
What the numbers actually are
Since the question always comes up, the ceilings vary widely because each member state sets its own, and the figures circulating online frequently disagree. Level Access's compliance summary gives, among others:
| Country | Maximum penalty |
|---|---|
| Italy | Up to 5% of annual turnover for companies previously under the Stanca Law; otherwise up to €40,000, with a 90-day notice period |
| Germany | Up to €100,000 for non-compliant product sales; up to €10,000 for failing to provide accurate accessibility information |
| France | €50,000 for web accessibility non-compliance, plus €25,000 for related offences such as a missing accessibility statement |
Two things stand out. Italy's turnover-linked ceiling is the one that scales dangerously with size. And in several member states non-compliance is treated as a criminal rather than administrative matter, which changes who inside your company is exposed.
But again: the fines are the tail risk. The remediation order is the near-term one.
Who it applies to
Broadly: businesses selling to consumers in the EU, including e-commerce, banking services, e-books, transport, and telecoms — regardless of where the business itself is based. Microenterprises (under 10 staff and under €2 million turnover) are largely exempt for services, and, as the Lille ruling showed, some national transpositions add their own revenue thresholds on top.
If you are reading this from outside the EU and selling into it, you are in scope. A Tashkent-built store selling to customers in Germany is subject to the German transposition, not to Uzbek law.
The argument that is not about law at all
Here is why we would push a client on this even in a jurisdiction with no such law.
The WCAG requirements that matter most are, almost item for item, the things that also cost you conversions:
- Colour contrast. Grey-on-grey body text is unreadable for someone with low vision and mildly annoying for everyone else in direct sunlight. Both groups leave.
- Labelled form fields. A screen reader cannot use a placeholder as a label. Neither can a person who has started typing and forgotten which field they are in.
- Visible focus states. Required for keyboard users. Also the thing that makes a form feel responsive to anyone tabbing through it quickly.
- Error messages tied to the field. "An error occurred" at the top of a form is an accessibility failure and the single most reliable way to lose a completed checkout.
- Tap target size. An accessibility minimum that is identical to the mobile conversion best practice.
- Working without a mouse. Which, incidentally, is what an automated agent also needs — see when the buyer is a program.
Baymard's research attributes 17% of intentional cart abandonment to a lengthy or complicated checkout and another 17% to website errors. Most of those failures are the same failures an accessibility audit flags. You are not choosing between compliance and revenue. You are choosing between fixing the same defects now or later.
Retrofitting versus building it in
The cost curve here is unusually steep, and it is worth understanding why.
Accessibility is mostly determined by decisions taken before any code is written: the colour palette, the type scale, the heading hierarchy, the focus treatment, whether interactive elements are real buttons or styled divs, whether the component library exposes labels. Get those right once, in the design system, and every screen you build afterwards inherits them for free.
Get them wrong and you are not fixing a page. You are fixing every instance of a component across every page, in a codebase where the component is a copy-pasted div.
This is why accessibility built-in is a line item on our product design service rather than a separate audit product — contrast, focus states and keyboard paths are designed in, not retrofitted after a complaint. The same reasoning applies to overlay widgets, the JavaScript products that promise compliance from a single script tag: they do not fix the underlying markup, courts and advocacy groups have treated them sceptically, and they add main-thread work to every page load.
We also build the harder end of this. Legible, one of our open-source tools, remediates PDFs and images for screen readers: tiered alt text, reconstructed data tables for charts, MathML for equations, provenance and a confidence score per figure. Its governing rule is that unreadable values stay null and are flagged for human review, because in a workflow someone is legally accountable for, a confident wrong value is worse than no value at all. That principle — never assert what you cannot verify — is the difference between a compliance tool and a compliance liability.
What remediation actually costs, in three tiers
The word "accessibility project" hides an enormous cost range. It helps to know which tier you are in before anyone quotes you.
Tier 1 — settings and content. Days. Colour contrast in the palette. Alt text on images. Page titles and heading order. Link text that says where it goes instead of "click here". A published accessibility statement. Form fields given real labels.
Most of this is editorial, much of it can be done by whoever edits your site, and it closes a surprising share of automated findings. Do it first regardless of what tier you are in.
Tier 2 — components. Weeks.
Focus states. Keyboard operation of menus, modals, tabs, carousels and date pickers. Error messages tied to their fields. Tap target sizes. Anything where a div is pretending to be a button.
This is real engineering, but it is bounded engineering — if you have a component library, you fix each component once and every page inherits it. If you do not have one, this tier is where you find out, because the same fix has to be made in forty places.
Tier 3 — structure. Months, or a rebuild. A checkout provided by a third party that you cannot modify. A theme whose markup is generated. A framework that renders nothing without JavaScript. An interaction pattern that is inaccessible by design and central to the product.
The step from Tier 2 to Tier 3 is almost entirely determined by whether you control the code. That is the same question that decides every other cost in this article, and it is why the ownership conversation in the case against your page builder is not a separate topic from this one.
How to find your tier in an hour: run an automated scan, then take the ten findings it reports on your checkout and ask your developer, for each, "can we change this file?" The proportion of no's is your tier.
What to do in the next thirty days
- Establish scope. Do you sell to EU consumers, and does your national transposition's threshold catch you? A lawyer answers this in an hour.
- Run an automated scan and accept that it finds perhaps a third of the issues. It is still the fastest way to size the problem.
- Keyboard-test your money path. Unplug the mouse. Try to search, select, add to cart and check out. Whatever breaks first is your priority.
- Check whether you control the code. List every third-party component in your purchase flow. Anything you cannot modify is a remediation risk you cannot schedule.
- Publish an accessibility statement. In several jurisdictions its absence is separately penalised, and it is an afternoon of work.
If step four turns up a checkout you cannot change and a theme you cannot untangle, you have learned that your exposure is not a compliance project. It is a rebuild — and the good news is that a rebuild done now is a planned expense, while a rebuild done under a six-month court order is not.
Tell us what you need. You get a fixed price and a delivery date back — free, and with no obligation to proceed.
Frequently asked questions
Does the EAA apply if my company is outside the EU?
If you offer covered products or services to consumers in the EU, yes. Enforcement runs through the member state where the service is offered, not where your office is.
Is WCAG 2.1 AA the standard I need to hit?
In practice yes — the harmonised European standard EN 301 549 maps closely to WCAG 2.1 level AA for web content. Aim there, and treat anything beyond it as optional.
Will an accessibility overlay widget make me compliant?
No. Overlays modify presentation at runtime without fixing the underlying markup, and they have not fared well when tested. They also add JavaScript to every page, which costs you on the metrics discussed in speed is a pricing decision.
How much does it cost to make an existing site accessible?
Entirely dependent on how it was built. On a site with a real design system it is usually a contained piece of work. On an assembled theme it is frequently comparable to a rebuild, because the fixes have to be made in code you do not own.
What if I am a microenterprise?
Most service obligations do not apply to you, and national thresholds may exempt you further. That is a reason not to panic, not a reason to design inaccessibly — the usability benefits apply to your customers regardless of your headcount.
