The Ultimate Guide to the European Accessibility Act for WordPress

Read the law: Austria: Accessibility Act, Ministry of Social Affairs Service Act (in German)

Responsible authority

The Sozialministeriumservice (Federal Ministry of Social Affairs Service) is designated as the market surveillance authority for both products and services. It conducts inspections, investigates complaints, and enforces compliance.

Enforcement triggers

• Consumers and designated organizations (like the Austrian Disability Council) can file complaints or report non-compliance.
• Market surveillance actions can be initiated through regular inspections or complaint-driven investigations.

Corrective measures

Before issuing penalties, the authority typically:

• Asks businesses to take voluntary corrective actions within a set deadline (10+ working days).
  
• If ignored, it may issue formal orders, including product recalls, service suspensions, or public notices.

Penalties

Administrative fines:

• Up to €80,000 per violation.
• The penalty amount is determined based on the size and financial capacity of the business.
• Lower maximum fines apply to small and medium-sized enterprises (SMEs) and microenterprises.

For first-time or minor infractions, the Sozialministeriumservice is encouraged to issue guidance or warnings rather than immediately imposing fines. Collected fines go to the Disability Support Fund, which promotes participation projects for people with disabilities.

Exceptions

The law comes into full effect on June 28, 2025 (aligned with the EU EAA directive); however, § 37 BaFG does allow for a transition period through June 28, 2030.

Service providers may continue using products (including software and websites) that were already in use before June 28, 2025. This is permitted for up to 5 years, i.e., until June 28, 2030. After that, these services must be adapted to meet accessibility requirements.

Contracts for services entered into before June 28, 2025, may remain unchanged for up to 5 years. After that, the contracts must either be updated to comply with the accessibility requirements or terminated.

Note: This transition allowance does not mean websites are exempt until 2030. It’s very limited and applies only when tied to long-term service contracts or use of legacy platforms. E-commerce, banking, and similar sectors are expected to comply sooner, especially if their websites are core to service delivery.

Also, if the website or service is new (i.e., goes live or enters the market after June 28, 2025), it must be accessible from day one, and adding major new functionality to an existing site may also void the transition period.

Read the law: Belgium: Act amending the Act of 13 June 2005 on electronic communications, partially transposing Directive 2019/882 of the European Parliament and of the Council of 17 April 2019 on accessibility requirements for products and services (in Dutch or French)

This law amends Belgium’s Electronic Communications Act to partially implement the European Accessibility Act, ensuring that certain digital services and consumer electronics are accessible to people with disabilities.

Responsible authority

The Belgian Institute for Postal Services and Telecommunications (BIPT) is the designated regulatory body. It oversees compliance with accessibility rules for electronic communications services and consumer-facing radio equipment. It may request documentation, conduct assessments, and initiate enforcement actions.

Enforcement triggers

• Complaints from consumers or organizations can trigger investigations.
• The BIPT may also initiate proactive inspections or request updated compliance assessments.
• Businesses are required to keep documentation justifying any exemptions based on “disproportionate burden” or “fundamental change” and submit it upon request.

Corrective measures

Before issuing penalties, authorities may:

• Ask businesses to provide or update documentation justifying non-compliance.
• Require compliance measures where burdens are not substantiated.
• Invalidate claims of disproportionate burden if public or private funding was received to support accessibility efforts.

Penalties

While the law does not explicitly list fine amounts in the published amendments, enforcement will likely include:

• Orders to correct or remove non-compliant products or services.
• Potential sanctions under broader consumer protection or electronic communications laws.
• Companies cannot claim a disproportionate burden if they receive external funding for accessibility improvements.

Exceptions

The law in Belgium does not include a transition period as some countries do. However, the law states that accessibility requirements apply only if compliance:

1. Does not require a fundamental change in the essential nature of a product or service, and
2. Does not impose a disproportionate burden on businesses, “in light of the criteria established by the King.”

This means:

If a company receives public or private funding to improve accessibility, it may not claim a disproportionate burden.

The exact criteria for determining what constitutes a disproportionate burden will be set out in a Royal Decree (not in the July 20, 2023 law itself).

Businesses must self-assess whether compliance would be disproportionate and document their reasoning (unless exempt as a microenterprise).

They must retain this documentation for five years and provide it to the BIPT (Belgian Institute for Postal Services and Telecommunications) upon request.

Read the law: Croatia: NN 89/2025 (13.6.2025), Act on Accessibility Requirements for Products and Services (in Croatian)

Responsible authority

The ministry responsible for social welfare affairs oversees the law, with multiple entities below it responsible for inspections. The Croatian Regulatory Agency for Network Industries is the designated authority responsible for overseeing compliance with Croatia’s Law on Accessibility Requirements for Products and Services as it applies to electronic communications, including websites. It acts in cooperation with the State Inspectorate, which specifically oversees e-commerce.

Enforcement triggers

Enforcement may be triggered by:

• User complaints submitted by individuals or advocacy organizations
• Routine inspections by the State Inspectorate
• Market surveillance initiated by the competent ministry or its partners
  

Corrective measures

Before imposing penalties, authorities may:

• Request voluntary corrective actions with a defined timeline.
• Issue formal decisions requiring service providers to make their websites accessible.
• Order the withdrawal or suspension of digital services that are found to be non-compliant.

Penalties

Administrative fines may be imposed for non-compliance, including failure to publish an accessibility statement, to make necessary improvements, or to cooperate with authorities:

• €6,630.00 to €132,720.00 for service providers who are legal entities (businesses).
• The responsible person in a legal entity shall also be fined from €2,650.00 to €6,630.00.
• Reduced amounts for individual entrepreneurs, craftsmen, and “natural persons”: €2,650.00 to €6,630.00.

Continued non-compliance after a formal warning may result in higher-tier penalties or service restrictions.

Exceptions and Transition period

Websites and services in use before June 28, 2025, may continue without modification until June 28, 2030, provided no substantial updates are made. Contracts signed before June 28, 2025, may remain valid until that same date, but must be updated afterward.

Read the law: Cyprus: The Accessibility of Products and Services Law of 2024 (57(I)/2024) (in Greek)

Responsible authority

The Deputy Minister of Social Welfare is the designated authority responsible for enforcing Cyprus’s Accessibility of Products and Services Law. He or she can appoint ministers or departments to carry out market surveillance, and cooperates with interested bodies, including the Cyprus Confederation of Disabled Persons’ Organizations.

Enforcement triggers

Enforcement can be triggered by:

• Complaints submitted by individuals, especially persons with disabilities.
• Reports from recognized consumer or disability organizations.
• Routine audits or inspections are initiated by the overseeing authority.
• Evidence of non-compliance is found during market surveillance, such as by being a “secret shopper” and purchasing a product without disclosing their identity.

Corrective measures

When non-compliance is detected, the authority may:

• Request the service provider to implement corrective actions within a defined deadline.
• Issue binding orders to bring websites into conformity.
• Impose restrictions or prohibitions on offering non-compliant services.
• Make the violation publicly known.
• Request documents translated into Greek and/or English.

Penalties

Administrative Fines

Administrative fines may be imposed for violating the accessibility obligations:

• Up to €10,000 on a person for their first violation and up to €20,000 for subsequent violations.
• Continuation of violations without remediation can result in fines of up to €500 per day, depending on the severity.

Repeated violations may lead to increased sanctions or legal proceedings. Failure to cooperate with enforcement authorities may result in additional penalties.

Penalties are assessed in proportion to the severity of the violation and the size of the business. Fines may be appealed for up to 75 days.

Criminal Penalties

The criminal provisions of Cyprus’s accessibility law apply to cases of serious misconduct that go beyond ordinary non-compliance. This includes:

• Selling or offering products and services that do not meet the accessibility requirements puts disabled consumers at a systemic disadvantage. 
• Ignoring official compliance orders from enforcement authorities, thereby undermining the regulatory process. 
• Forging, misusing, or issuing accessibility certificates or documents without proper authorization.
• Knowingly providing false or misleading information during inspections or certification processes. 

These actions are treated as criminal offenses because they represent deliberate attempts to evade or obstruct legal obligations, and they carry criminal penalties, including:

• Imprisonment:
  • Up to 2 years for a first conviction.
  • Up to 3 years for repeat offences.
• Significant monetary fines:
  • Up to €20,000 for a first offence
  • Up to €30,000 for subsequent convictions

Exceptions

Cyprus has a very clearly outlined Annex added to the law, which explains how to determine if a disproportionate burden exception can apply. 

Companies must compare the cost of making a product or service accessible to their total operating and production costs. This includes one-time costs like staff training or updating development processes, and ongoing costs like design changes, testing, and documentation. They must also consider how the cost compares to the benefit for people with disabilities—especially how many people use the website and how often—and how the cost compares to their annual turnover. Read the law for more information.

Transition period

Cyprus follows the EU-wide effective date of June 28, 2025, with specific transitional provisions:

Contracts signed before that date may remain unchanged until 2030, after which they must comply or be terminated.

Websites and digital services launched before June 28, 2025, may remain in use without updates until June 28, 2030, unless substantially changed or redesigned.

Read the law: Czech Republic Act N. 424/2023 Coll (in Czech)

Responsible authority

The responsibility for enforcing the EAA in the Czech Republic as it pertains to websites depends on the type of service the website provides. 

• Czech Trade Inspection Authority – General oversight of e-commerce websites.
• Czech Telecommunications Office – Electronic communications websites.
• Council for Radio and Television Broadcasting – Audiovisual media service websites.
• Relevant transport regulators – For websites related to air, rail, water, and public transport services.

Enforcement triggers

The Czech Republic’s implementation of the European Accessibility Act provides for proactive and reactive monitoring, including market surveillance, complaint-based enforcement, and EU coordination. Service providers must also self-publish accessibility information, which serves as both a compliance requirement and a verification tool for authorities.

Market Surveillance by Authorities

The law explicitly empowers supervisory authorities to conduct market surveillance. This includes:

• Monitoring websites and mobile applications for compliance.
• Reviewing the accessibility of information published on websites (such as terms and conditions or service descriptions).
• Checking whether the service provider has published required accessibility statements and technical details (as per § 14).

Consumer Complaints

Individuals can report accessibility barriers to the relevant supervisory authority. This is a major trigger for enforcement, especially for websites used by the general public (e.g., online shops, video platforms, transport portals).

Cooperation with EU-Wide Surveillance

If a noncompliant website or service is identified in another EU country, Czech authorities may be notified through the EU’s information and communication system for market surveillance and take corresponding action.

Corrective measures

If a website is determined not to be in compliance, authorities can:

• Require service providers to bring their websites into compliance within a set time frame.
• Publish lists of noncompliant services online.
• Monitor and verify if accessibility statements and technical requirements are being met.

Penalties

Businesses that don’t have accessible websites or published accessibility documentation can be fined. The amount of fines depends on the severity of the violation.

• 1 million CZK (~40,572€) for failure to act promptly or insufficient diligence:
  • Not ensuring the service meets accessibility requirements.
  • Not taking corrective measures.
  • Failing to act after being notified by the supervisory authority.
  • Not publishing accessibility information.
  • Not ensuring accessibility information remains published and accessible.
• 2 million CZK (~81,145€) for moderate but substantial failures in documentation, labeling, communication, and reporting issues:
  • Failing to maintain assessments.
  • Not preparing new assessments.
  • Failing to inform or include an affidavit.
• 5 million CZK (~202,863€) for serious violations, including falsification and refusal to document or report:
  • Failing to prepare technical documentation or conduct a conformity assessment.
  • Failing to maintain documentation.
  • Failing to update the declaration.
  • Falsely claiming an undue burden exemption after receiving funding.

Exceptions

The EAA exception for microbusinesses applies, and for the purposes of determining the revenue or turnover, the exchange market rate announced by the Czech National Bank for the balance sheet date is used to convert the Czech currency into Euros.

Other exceptions to accessibility requirements include:

• Third-party content on a website that the provider does not control, fund, or influence.
• Maps, unless basic navigation info is provided in an accessible digital form.
• Archived websites or those not updated after the law takes effect.
• Pre-recorded media and office file formats published before June 28, 2025.

Transition period

The Czech law allows a transition period until June 28, 2030, only for websites that were published before June 28, 2025, and “is not updated or modified.” This limitation on updates and modifications effectively means that no WordPress websites can claim an exemption during the transition period, as changing content or updating plugins will void the transition period exemption.

Read the law: Denmark: Accessibility requirements law for products and services (in Danish)

Responsible authority

Multiple supervisory authorities are designated based on the type of service provided through the website:

• The Danish Business Authority (Erhvervsstyrelsen) is generally responsible for oversight of digital services, including websites that offer goods and services to consumers.
• Other authorities may have sector-specific responsibilities, such as the Danish Financial Supervisory Authority for banking or the Danish Transport Authority for transport-related services.

Enforcement triggers

A website may be identified as noncompliant through:

• Consumer complaints: Individuals can report accessibility barriers on websites directly to the relevant authority.
• Market surveillance: Authorities are empowered to actively monitor compliance. This includes checking websites for conformance with accessibility standards (primarily EN 301 549, which incorporates WCAG 2.1 AA).
• Cross-border cooperation: Under EU rules, Danish authorities can be informed of violations detected in other member states if the service is also offered in Denmark.

Corrective measures

If a website is found to be noncompliant, the authority may:

• Issue improvement orders requiring the service provider to bring the website into compliance within a specified deadline.
• Require documentation such as accessibility assessments or an updated statement on accessibility.
• Request the removal of a service or digital offering from the market if the provider fails to correct the issues.

Penalties

Fines may be imposed for:

• Noncompliance with accessibility obligations.
• Failure to provide required documentation (such as a conformity declaration or accessibility statement).
• Providing misleading information about accessibility compliance.

The law does not specify exact fine amounts in the main text, but violations can lead to administrative penalties under the general Danish sanctioning framework for consumer protection and product regulation.

Exceptions

Micro-enterprises are generally exempt from certain digital accessibility obligations as outlined in the EAA, unless they receive public funding or subsidies related to accessibility. Other exceptions include:

• Archived or legacy content on websites that is not updated after the law’s effective date may be exempt.
• Third-party content embedded on websites that the service provider does not control is not subject to compliance requirements.
• An undue burden exception may apply if meeting accessibility requirements imposes a disproportionate burden, but this must be documented with a formal assessment.

Transition period

The law takes effect on 28 June 2025, aligning with the deadline in the European Accessibility Act. Digital services (including websites) that are newly launched or significantly modified after this date must meet accessibility requirements.

Existing contracts using inaccessible technology may continue only until 28 June 2030, provided no substantial modifications are made. The Danish accessibility law does not explicitly define the term “substantial modifications” in its statutory text. Its usage implies meaningful updates to websites — for instance, in structure, content, features, or interface — that would require reassessing and updating accessibility information, but it doesn’t specifically define this term. That means that the definition of substantial modifications is up to interpretation, norms, or supervisory discretion. 

Read the law: Estonia: Products and Services Accessibility Act (English)

Responsible authority

The Consumer Protection and Technical Regulatory Authority (Tarbijakaitse ja Tehnilise Järelevalve Amet) is responsible for supervising and enforcing compliance with the European Accessibility Act in Estonia.

Enforcement triggers

Websites providing covered services (e.g., e-commerce, transport booking, audiovisual media, e-books, banking, electronic communications) must be accessible under Annex I requirements AccessibleEU+8riigiteataja.ee+8European Commission+8.
Compliance is monitored through:

• Submission of accessibility information by service providers.
• Inspections and requests for information by the Authority.
• Reviews triggered by complaints or identified issues.

Corrective measures

If a website is found non-compliant, the Authority may order service providers to implement corrective measures to meet accessibility requirements.

Website owners and other service providers are required to self-report issues. If their website is not accessible, they must inform the Authority about the non-compliance and the steps they are taking to correct the issues.

Penalties

There are two different types of fines allowed by Estonian law. 

The law allows for direct sanction for noncompliance. This is a punitive fine issued after a violation has occurred, specifically when a service (e.g., a website or digital service) does not conform to accessibility requirements. The amount of these fines is:

• Up to €400 for individuals.
• Up to €20,000 for legal entities (e.g., businesses).

Additional fines or penalties are allowed under the Substitutive Enforcement and Penalty Payment Act, which is used to pressure a service provider to comply with a formal order from the supervisory authority. If a website owner fails to comply with written instructions to fix the accessibility problems on their website, they can also be fined up to €10,000 in addition to previous fines.

Exceptions

Estonia’s Products and Services Accessibility Act includes several exceptions that limit which content must meet accessibility requirements. These exceptions help clarify when certain digital content—such as parts of a website or mobile app—does not need to be made accessible, even if the rest of the service is covered by the law.

The law states that accessibility requirements for services do not apply to the following website and app content:

• Audio and video recordings that were published before the law took effect on June 28, 2025.
• Files such as PDFs, Word documents, Excel spreadsheets, etc., that were uploaded or made publicly available before June 28, 2025.
• “Frozen” or archived websites and apps: pages or content that remain completely untouched after the law’s effective date.

Transition period

Estonia follows the EAA transition period until June 28, 2030; however, that only applies to websites that are not updated or edited after June 28, 2025.

If a web page is not modified at all after June 28, 2025, it remains exempt. However, any update—even fixing a typo or updating WordPress plugins—could trigger the need to bring that content into compliance. With this language in mind, there is no transition period for WordPress websites. They must all have been made accessible prior to June 28, 2025.

Read the law: Finland: Law on the provision of digital services (in Finnish and Swedish) and Finnish FAQ Document (in English)

Responsible authority

In Finland, Traficom (Finnish Transport and Communications Agency) oversees accessibility compliance for both public and private-sector digital services under the amended Act on the Provision of Digital Services. The Regional State Administrative Agencies in Southern Finland enforce the original public-sector-focused law (Digital Services Act 306/2019) and now cover private businesses under the 2023 EAA amendments.

Accessibility Statements

The law in Finland specifically requires websites to have public accessibility statements. These statements must have:

1. An explanation of which parts of the website do not meet the accessibility requirements and the justification for not meeting the accessibility requirements.
2. Instructions on how website users can obtain the information contained in the digital service or in an alternative way.
3. Electronic contact information to which the website users can send feedback.
4. A link to Traficom’s website where the website user can make an accessibility complaint or request for clarification.

The accessibility statement must be maintained in the form specified in the European Commission’s implementing act adopted pursuant to Article 7 (2) of the Accessibility Directive. 

Enforcement triggers

Websites may be flagged in several ways:

• Routine audits by Traficom or regional agencies, including technical testing and manual checks.
• User complaints or feedback, which are specifically required to be enabled and monitored by covered entities.
• Self‑notification: Providers must inform authorities if they invoke disproportionate burden exemptions and allow the authority to request more information.

In Finland, website owners must notify Traficom if:

• If a product or service is non-compliant but bringing it into conformity would fundamentally change the product or service, and they want to claim an exemption.
• If the website is found to be non-compliant and the site owner does not wish to invoke the exemption grounds, or if it is not possible to invoke the exemption grounds, they must notify the authority of the deficiency they have detected, planned corrective measures, and the timetable for rectifying the deficiency.

If your website is not accessible, use this form to notify Traficom if your website does not comply with the European Accessibility Act and your plans for remedying it.

Corrective measures

If non-compliance is found, the supervisory authority can issue enforcement notices requiring specific accessibility improvements within set deadlines. Continued failure may result in fines issued under the Finnish Conditional Fines Act.

Traficon may publish a list of products that do not meet the accessibility requirements, which may include websites.

Penalties

Fines for EAA noncompliance in Finland are discretionary, with amounts depending on the severity of the breach and the provider’s financial capacity. 

The Law on the Provision of Digital Services does not specify a specific amount for fines. Fines are covered in the periodic penalty payment law (1113/1990).

Exceptions

There is an exception to the law if a website owner can show an undue or unreasonable burden in making their website accessible. The assessment of an unreasonable burden must take into account:

• the needs of people with disabilities to use this digital service, and the size,
• financial position, and
• nature and extent of the business.

Transition period

There is no transition period specified in the Finnish law.

Read the law: France: Section 7: Provisions relating to the accessibility of products and services (Articles D412-49 to D412-62) (in French)

Responsible authority

The Regulatory Authority for Electronic Communications, Postal Services and Print Media Distribution (Autorité de Régulation des Communications Électroniques, des Postes et de la Distribution de la Presse (ARCEP) is an independent administrative authority in France established in 1997. The ARCEP has enforcement powers over:

• digital communication services (like messaging, email, and internet access), 
• websites and mobile apps of service providers in covered sectors, 
• accessibility documentation and compliance reporting, especially when providers claim exemptions or must publish accessibility statements.

Enforcement triggers

Websites can be assessed through:

• ARCEP inspections: They may request accessibility documentation and technical details.
• Random checks or spot audits by ARCEP or consumer regulators, as empowered by the decree 
• User complaints can initiate enforcement actions following evidence submission requirements.

Corrective measures

The Minister responsible for disabled persons issues administrative sanctions for non-compliance with accessibility requirements. If non-compliance is found:

1. The authority notifies the party (e.g., a business or municipality) in writing.
2. The party has 3 months to respond and justify the failure.
   • This can be extended by two more months if needed.
3. The authority considers:
   • Efforts made
   • Good faith
   • Justified reasons for failure

Based on this, the authority may:

• Grant up to 3 additional months for compliance, or
• Impose a fine (and repeat this annually if needed).

Penalties

Criminal fines can be imposed for failure to comply with accessibility rules, including violation of Sections covering web accessibility or refusal to cooperate. For businesses (legal persons), administrative fines may be imposed per Consumer Code L412‑13.

Fines are:

• €2,000 for municipalities or public groups with fewer than 5,000 residents and related public bodies or public service contractors in small towns.
• Up to €50,000 for all other organizations (e.g., larger businesses, municipalities, or service providers).
• €25,000 for not publishing or updating the mandatory accessibility declaration or action plan.

Exceptions

Accessibility requirements for websites do not apply to:

• Pre-recorded time-based media published before 28 June 2025
• Office file formats published before that date
• Content not updated after 28 June 2025. Decree provisions exempt legacy content in accordance with the Directive.

Transition period

Only content published before 2025 and that is not updated has a 5-year transition period (through June 28, 2025), but all updates and new content must be compliant now.

Read the law: Germany: Ordinance on the accessibility requirements for products and services in accordance with the Accessibility Strengthening Act (Ordinance on the Accessibility Strengthening Act – BFSGV) (in German) or read Germany’s FAQ on the Accessibility Strengthening Act (in German).

Responsible authority

German states are currently setting up a joint office to carry out the tasks of the Accessibility Strengthening Act. Market surveillance will be carried out by the federal states’ designated authorities, coordinated through a joint federal monitoring body hosted by Saxony‑Anhalt’s Ministry for Labour, Social Affairs, Health and Equality. 

The state market surveillance body for the accessibility of products and services (MLBF) is to begin work as a new institution under public law in Saxony-Anhalt, in the state capital of Magdeburg. The prerequisite for this is the ratification by all German states of the state treaty to fulfill their tasks in accordance with the Accessibility Strengthening Act (BFSG). All states are currently creating the necessary conditions for this. You can follow the progress of the creation of this office in Germany here.

Enforcement triggers

Authorities may detect non‑compliance via:

• Complaints from consumers or disability organizations.
• Random inspections of websites and digital services.
• Monitoring reports or warning letters issued by organizations under Germany’s Unfair Competition Act (UWG)

Germany’s Unfair Competition Act, known in German as the Gesetz gegen den unlauteren Wettbewerb (UWG), is the primary law used to prevent dishonest business practices and ensure fair competition in the marketplace.

Under the European Accessibility Act and Germany’s Barrierefreiheitsstärkungsgesetz (BFSG), the UWG plays an indirect but powerful role:

If a business fails to meet accessibility obligations for websites or digital services, it may be accused of gaining an unfair competitive advantage, and that could be challenged under the UWG.

Examples:

• If a company ignores accessibility requirements while competitors invest in compliance, it may cut costs unfairly.
• Disability advocacy groups and consumer protection associations may file under the UWG.
• Courts may issue injunctions or impose fines, even if the accessibility law itself hasn’t yet triggered enforcement.

This means that accessibility non-compliance can be treated not only as a regulatory violation (under the BFSG), but also as unfair competition — a legal risk with both public and private enforcement.

This is unique among European countries as enforcement will not just come from government agencies. In Germany, your competitors, consumer protection organizations, trade associations, and individuals (e.g., a disabled user denied access) can file a civil lawsuit, demand corrective action, or seek damages or an injunction for website accessibility violations.

Corrective measures

Once non-conformity is found, authorities can:

• Require businesses to fix accessibility issues within deadlines.
• Impose further compliance deadlines if initial attempts fail.
• Ultimately, order the suspension or withdrawal of inaccessible online services.

Penalties

In addition to corrective actions, fines up to €100,000 may be imposed for serious non‑compliance under § 36 BFSG.

Exceptions

There are two limited exceptions:

1. Fundamental alteration: Adhering to accessibility would fundamentally change the nature or purpose of the product/service.
2. Disproportionate burden: Compliance would create an excessive organizational or financial burden.

Whether a website qualifies for an exception must be assessed using the criteria in Annex 4 and documented, with documentation kept for five years. 

Micro-enterprises dealing with products are exempt from the documentation requirement (though they must still provide information to authorities on request). Service providers must reassess regularly (at least every 5 years, or upon change or request) and notify market surveillance of any exception invoked (also in other EU member states where they operate).

Transition period

Some specific products and services have extended transition periods under § 38 BFSG, which allows delayed compliance deadlines in defined cases (e.g., for products already on the market before June 28, 2025). However, this is unlikely to apply to WordPress websites due to their frequency of updates and content changes.

Official German guidance on the law for online stores specifically states that the entire website must be compliant, not just key user journeys.

Read the law: Greece Law 4994/2022 – FEK 215 / A / 18-11-2022 (Codified) (in Greek)

Greece was one of the last countries to fully transpose the European Accessibility Act into national law (the European Commission sent them a warning about this in March 2025), and their processes around the EAA may not be fully developed. 

Responsible authority

The National Accessibility Authority serves as the central supervisory and advisory body, monitoring digital accessibility and advising on standards for websites and mobile apps. Market surveillance and enforcement fall under designated public bodies overseeing compliance, including data from Law 4994.

Accessibility Statement

To be compliant, websites must include a declaration of conformity, maintain a technical documentation file, and publish clear, accessible compliance information. Staff must also be trained on handling accessibility requirements and providing customer support to people with disabilities.

Enforcement triggers

Websites and e‑services can be flagged through:

• Proactive audits by authority-led checks.
• User complaints or advocacy group referrals prompting authorities to investigate non-compliance.
• Routine monitoring of public and private digital platforms as part of the market surveillance regime

Corrective measures

Upon finding non-conformity, the competent authority may:

• Order remediation within a set period.
• Impose a temporary suspension of access to non-compliant services.
• Force updates or corrective actions to bring the site into compliance.

Affected parties (including website owners) are allowed to provide observations and justify delays before measures are finalized.

Penalties

The law provides administrative sanctions that must be “effective, proportionate and dissuasive.” While the exact upper limits are to be defined by subsequent ministerial decisions, Article 26 of Law 4994/2022 allows administrative penalties of up to €100,000 for non-compliant digital accessibility.

The severity of penalties depends on:

• The seriousness and duration of the violation.
• The number of affected individuals.
• Any recurrence or negligence in compliance.

Additional legal recourse and collective actions by disability rights groups are also enabled under draft amendments.

Website owners have 30 days to appeal penalties after they have been notified of noncompliance and possible sanctions.

Exceptions

The law in Greece has provisions to allow deferring obligations where compliance would cause a disproportionate burden or fundamental product/service changes, though specifics are not laid out for how these are defined at the website level.

Read the law: Hungary: Act XVII of 2022 on the general rules for compliance with accessibility requirements for products and services (in Hungarian)

Responsible authority

In Hungary, the designated market surveillance authority responsible for enforcing the Accessibility Act, including e‑commerce websites as service providers, is the Market Surveillance Department (Piacfelügyeleti Osztály) housed within the Metrology and Technical Surveillance Division of the Budapest Government Office under the Hungarian Trade Licensing Office (now part of MKEH).

Enforcement triggers

Websites can be found non-compliant through:

• Routine inspections or audits by the authority.
• Complaints submitted by users, consumer associations, or disabled persons trigger an investigative process.
• Automated monitoring and self-declarations or accessibility statements on the site.

Corrective measures

If a website lacks accessibility, the site owner must immediately:

1. Implement corrective actions to restore compliance.
2. Inform the supervisory authority of the issues and the steps taken, and
3. Upon request, provide evidence and documentation proving accessibility.

Penalties

Beginning in June 2025, organizations that violate Hungary’s EAA law may face administrative fines. These fines start at HUF 15,000 (~€37.54) and vary greatly based on an organization’s annual revenue: 

• Annual revenue exceeding HUF 100M: fines up to 5% of the organization’s annual revenue, capped at HUF 500M (~€1,251,289).
• Annual revenue less than or equal to HUF 100M: Fines up to HUF 500,000 (~€1,251) or up to 5% of the organization’s annual net revenue if the violation impacts consumers’ health and financial well-being. 

In addition to annual revenue, the regulatory authority will consider additional factors when determining the amount of fines. Other factors that will be considered include consumer interests affected by the lack of accessibility, the range of products and services affected that are not in compliance, and measures taken by the organization to reduce or compensate the damage suffered by consumers.

Exceptions

The Hungarian transposition of the European Accessibility Act has a detailed criteria system for evaluating disproportionate burden and claiming an exemption from accessibility requirements. 

First, businesses must compare the cost of making a product or service accessible—both one-time (e.g., hiring experts, training staff) and ongoing (e.g., accessibility testing, documentation)—to their total operational and capital expenses. Second, businesses must weigh these costs against the expected benefits for people with disabilities, considering how often and widely the product or service will be used. Finally, they must compare accessibility costs to their net sales revenue. All findings must be documented and may be requested by regulators to justify any exemption.

 For additional details, read the full text of the law, linked above.

Transition period

Hungary’s law allows for more entities to take advantage of the 5-year transition period. It states that “Until 28 June 2030, service providers may continue to provide services using products that do not meet the requirements of this Act and that were lawfully used to provide similar services before 28 June 2030.” 

There is no mention that websites cannot have been updated or edited.

Read the law: Ireland: S.I. No. 636/2023 – European Union (Accessibility Requirements of Products and Services) Regulations 2023 or Ireland’s Official Guidance for Businesses

Responsible authority

The National Standards Authority of Ireland (NSAI) is responsible for establishing accessibility standards and conformity assessments. The Competition and Consumer Protection Commission (CCPC) and the Commission for Communications Regulation (ComReg) are designated as market surveillance authorities for enforcing the law, depending on the type of service (e.g., e-commerce, telecommunications).

Enforcement triggers

Websites can be found out of compliance in several ways:

• Market surveillance inspections are conducted proactively by regulatory authorities.
• Complaints from users or advocacy organizations submitted to CCPC, ComReg, or NSAI.
• Monitoring obligations require service providers to conduct self-assessments and maintain technical documentation showing conformity.

Businesses are required to notify the CCPC of a non-compliant product/service or if they plan to claim an exemption. Notify the CCPC here.

Corrective measures

Authorities may issue:

• Improvement notices requiring specific accessibility fixes by a set deadline.
• Directions mandating the suspension or restriction of digital services until issues are resolved.

Website owners must retain documentation proving ongoing compliance and respond to requests from regulators.

Penalties

Failure to comply with the accessibility requirements for websites under the Irish EAA law can lead to both administrative fines and criminal penalties, depending on the nature and severity of the offense.

Administrative Fines

Regulatory authorities such as the Competition and Consumer Protection Commission (CCPC) or ComReg may impose administrative penalties in cases where a service provider:

• Fails to comply with an improvement notice.
• Does not cooperate with the surveillance authority.
• Does not maintain or provide required documentation of accessibility compliance.

While the exact administrative fine amounts are determined case-by-case, daily fines may be applied for continuing non-compliance, and repeated violations may lead to elevated enforcement actions, including court intervention.

Criminal Penalties

Where a service provider (individual or corporate entity) commits an offense under the regulations, the following criminal penalties apply:

• Summary conviction:
  • Fine of up to €5,000
  • And/or imprisonment for up to 6 months
• Conviction on indictment (more serious or repeated offenses):
  • Fine of up to €60,000
  • And/or imprisonment for up to 18 months

Stronger penalties may be applied where:

• A business continues to offer inaccessible digital services after being directed to fix them.
• The service provider obstructs regulatory oversight.
• False declarations of conformity are made.

Courts may also issue prohibition orders to stop ongoing violations or confiscate profits gained from non-compliant services.

Exceptions

Schedule 4 of Ireland’s EAA law includes a list of relevant criteria for determining disproportionate burden. To determine whether this applies to your website, review the linked law above and evaluate each specific accessibility requirement on your website independently, weighing cost versus benefit. It’s important to note that Ireland’s disproportionate burden applies per individual requirement, not globally to your entire website. So you will likely need to make some parts of the website accessible, even if taking the exception for other parts.

Disproportionate burden assessments must be documented in writing and kept for at least 5 years. Microenterprises are exempt from detailed documentation, but larger providers must retain full records.

If you rely on this exception, you must inform the relevant Irish authority (e.g., CCPC for general services or Central Bank for financial services) that you’ve invoked it. You must also review and reassess at least once every 5 years.

Transition period

The law came into effect on June 28, 2025, and a transition period extends until June 28, 2030. During this time, service providers may continue offering services using websites that were lawfully deployed before the law took effect. 

Importantly, this extension applies only if those services or websites are not updated after June 28, 2025. Any updates made—whether to layout, features, content, or e-commerce functionality—will trigger full compliance requirements immediately, removing the transition protection.

Read the law: Italy: Legislative Decree, 27 May 2022, No. 82 (in Italian) or read the Accessibility and Usability Information from AgID.

Responsible authority

The Agency for Digital Italy (AgID) is the “competent Supervisory Authority” responsible for enforcing compliance and overseeing implementation of Legislative Decree no. 82/202,2 which implemented the European Accessibility Act in Italy. AgID is required to:

• Annually monitor the accessibility of a representative sample of public and private websites and apps that provide services of public interest.
• Publish a report on the outcomes of this monitoring.
• Notify organizations that are out of compliance and may issue enforcement notices or administrative penalties for ongoing violations.

Accessibility Statement

Entities covered by Italy’s law are required to publish an Accessibility Declaration that explains how accessible their website or mobile app is. This declaration must follow the template provided in Attachment 1 of AgID’s Accessibility Guidelines.

The footer of every page on the website must include a link labeled “Accessibility Declaration” or simply “Accessibility.” That link must go to either:

• a page that directly contains the full Accessibility Declaration, or
• a page with more information, which in turn links to the full Accessibility Declaration.

This ensures transparency and public accountability for digital accessibility. It also aligns with EU requirements under the European Accessibility Act, which mandates that covered digital services provide information about their level of accessibility and compliance.

Enforcement triggers

In Italy, websites can be found out of compliance with accessibility requirements through a combination of proactive oversight, user reporting, and audits conducted by the designated authority. Below are the main enforcement triggers as outlined in Italian law (particularly Law 4/2004, as amended, and its implementing decrees), and the guidelines from AgID:

• Complaints: Any user—particularly people with disabilities—can report accessibility issues they encounter on websites or apps to AgID.
• Absence or Nonconformity of Accessibility Declarations: AgID conducts automated and manual monitoring of government and certain private sector websites. Enforcement is triggered if:
  • There is no Accessibility Declaration published.
  • The declaration does not follow the official model (as required by the AgID guidelines).
  • The information is incomplete or misleading, such as claiming full accessibility when issues exist.
• Random audits: Websites that do not conform to the WCAG 2.1 Level AA standards, as required by Italian law and EN 301 549, are considered noncompliant. AgID or another designated enforcement body may initiate action if a random sampling of websites finds WCAG failures.

Corrective measures

AgID or the designated enforcement authority (for example, the Ministry of Economic Development for market surveillance) typically follows a progressive approach:

• The business is notified of the noncompliance, either as a result of:
  • A user complaint,
  • Monitoring/audit by AgID,
  • Or absence of a required Accessibility Declaration.
• The website operator is asked to respond and correct the issues within a specified period (typically 30–90 days).

Penalties

If the issues are not addressed in time, the company may face financial penalties:

• Fines can range from €1,000 to €50,000, depending on the severity, persistence, and whether it’s a first-time or repeat offense.
• Fines may be higher if:
  • The site is operated by a large enterprise.
  • The lack of accessibility causes significant barriers to disabled users.
  • There is no published Accessibility Declaration.

Companies already under the Stanca Law (a pre-existing accessibility law targeting very large enterprises) are given a 90-day notice to meet accessibility requirements, and may be fined up to 5% of their annual turnover if they fail to comply.

AgID may also publish the results of monitoring on its website, naming noncompliant organizations. This can damage public trust, lead to reputational harm and negative media attention, or trigger complaints to consumer protection authorities.

In addition to administrative enforcement, website users or advocacy organizations may pursue legal claims under civil or anti-discrimination law.

In extreme cases, Italy’s Consumer Code could apply if inaccessibility is seen as a deceptive or unfair commercial practice, especially if accessibility is falsely claimed.

Exceptions

Under Italy’s implementation of the European Accessibility Act (EAA) through Legislative Decree No. 82/2022, Law 4/2004, and the AgID Accessibility Guidelines, a few limited exceptions are allowed for websites and digital services. These are primarily based on disproportionate burden, technical impossibility, and non-updated legacy content.

The standard EAA exemptions apply:

• Content published before and not edited since June 28, 2025, including legacy documents and files (PDF, Word, Excel).
• Third-party content is not controlled by the website.

Even when exceptions apply, organizations are still expected to offer alternative access where possible and document their decisions.

Transition period

Italy provides a transition period for websites under the European Accessibility Act. Websites and mobile apps published before June 28, 2025, are not required to meet accessibility requirements if they are not updated after that date. 

However, if any updates are made—such as adding new content, redesigning pages, or changing functionality—the entire site or app must comply with accessibility rules going forward. This exception is limited to static, legacy content that remains untouched and would not apply to WordPress websites.

Read the law: Latvia: Law on Accessibility of Goods and Services (in Latvian)

Responsible authority

Several bodies oversee compliance with Latvia’s Law on Accessibility of Goods and Services, depending on the service type. These authorities handle complaints and proactive supervision:

• Public Service Regulation Commission for electronic communications, including websites.
• National Electronic Media Council for audiovisual services.
• Consumer Protection Center for e‑commerce, financial services, e‑books, etc.

Accessibility Statements

Service providers (including websites) must include in their terms of use (or equivalent public documents):

• A clear declaration of compliance or reasons for non‑compliance based on exemptions.
• Accessible information explaining the design, operation, and accessibility features.

This information must be maintained in accessible formats and updated as needed.

Enforcement triggers

Non‑compliance can be identified through:

• User complaints, which providers must address within 1–3 months. Unresolved issues can be escalated to competent authorities.
• Proactive checks by authorities, including reviewing accessibility assessments, documentation of disproportionate burden claims, and testing services against requirements.

Corrective measures

When non‑compliance is found, authorities can:

• Order service providers to remedy the issues within a specified timeframe.
• If ignored, issue binding decisions mandating corrective actions.

Website owners must cooperate, submit documentation, and implement fixes.

Penalties

Failure to comply with orders can lead to further legal action, including administrative decisions enforceable by courts. Providers may face public disclosure of non‑compliance, reputational harm, and, depending on the sector, fines or additional measures per national law.

The text of Latvia’s Law on Accessibility of Goods and Services does not include specific fines or fixed monetary penalties for non-compliance. Instead, it relies on enforcement authorities and procedures to impose corrective orders and, if necessary, restrict or prohibit non-compliant services or products. The law outlines these procedures clearly but leaves the imposition of penalties and fines to be addressed through secondary legislation or administrative processes, such as those under the “Conformity Assessment” or general administrative law frameworks.

Exceptions

There are no unique exceptions to the law in Latvia. Exceptions exist for microenterprises, audio recordings, video articles, and office file formats published by June 27, 2025.

Transition period

Websites and mobile apps not updated or edited before June 27, 2025, are exempt until that date. Afterward, all new or updated digital content must meet accessibility standards.

Read the law: Lithuania: Accessibility Requirements for Products and Services (in Lithuanian)

Responsible authority

The Consumer Rights Protection Authority (Valstybinė vartotojų teisių apsaugos tarnyba) is designated to oversee compliance with accessibility obligations related to services, including websites and mobile applications.

Accessibility Statement

The law requires service providers to publish an accessibility statement indicating whether the service complies with accessibility requirements. Service providers (including website owners) must publish clear information—such as terms of use, project and operation descriptions—demonstrating compliance. The statement must be updated regularly and made available in accessible formats.

Enforcement triggers

Websites can be found out of compliance through:

• Complaints submitted by consumers or representatives of people with disabilities.
• Regular checks by the competent authority.
• Failure to publish or maintain an accurate accessibility statement.
• Refusal or failure to respond to information requests from authorities.

Corrective measures

If a website is found to be non-compliant, the responsible authority may:

• Issue warnings.
• Order corrections within a specified deadline.
• Impose restrictions or bans on the service.
• Inform the public of violations.

If a hearing is taking place to examine a violation, website owners must receive at least 14 days’ notice.

Penalties

Administrative fines can be applied for failure to meet accessibility requirements or comply with remediation requests.

• Fines of between €500 and €2,500 for websites that don’t comply with accessibility requirements.
• If the market surveillance authority has ordered the cessation of the service, and the website owner does not comply, fines increase to €1,000 to €6,500.
• If products or services that do not comply with accessibility requirements have caused harm to the health of the consumer and/or end-user, a fine of between €2,500 and €15,000 shall be imposed.

The amount of the fine imposed is determined by the average of the minimum and maximum fines, but can be increased or decreased depending on any mitigating or aggravating conditions. Fines must be paid into the state budget within 30 days.

Exceptions

Micro-enterprises (fewer than 10 employees and annual turnover or balance sheet below €2 million) are exempt from accessibility requirements.

There are also exceptions for third-party content not funded or developed by the service provider, and cases where meeting the requirements would cause a disproportionate burden or fundamental alteration to the service.

The law includes detailed guidance on determining disproportionate burden. Refer to the full text, linked above, for more information.

Transition period

The law enters into force on June 28, 2025. However:

Legacy self-service terminals may be used until the end of their economic life, but no longer than 20 years.

Services and content not updated or modified after that date are exempt.

Contracts concluded before June 28, 2025, must comply if they extend beyond June 28, 2030.

Read the law: Luxembourg: Law of 8 March 2023 on accessibility requirements for products and services (in French and English)

Responsible authority

The Office for the Monitoring of Accessibility of Products and Services (OSAPS), under the Minister responsible for Disability Policy, is the central body for monitoring and enforcement. OSAPS oversees both product and service compliance, including websites, and coordinates with other national authorities as needed.

Enforcement triggers

Websites may be found out of compliance through:

• Market surveillance activities by OSAPS. OSAPS can assess websites and services on its own initiative to check compliance with accessibility standards, without waiting for a complaint.
• Reports or complaints by individuals or organizations. Any individual or organization can report an inaccessible website or service. OSAPS is required to investigate such reports.
• OSAPS’s own initiative based on observed non-compliance.
• Failure to maintain up-to-date information on how services meet accessibility requirements.

OSAPS works with other authorities (e.g., customs, police, regulatory bodies) when necessary and must make certain enforcement data available in accessible formats unless confidentiality applies.

Corrective measures

If a website is found non-compliant, OSAPS may:

• Request corrective action within a specified timeframe.
• Prohibit or restrict access to the service if issues are not addressed.
• Organize the withdrawal or modification of non-compliant service-related products.
• Require updated documentation demonstrating accessibility compliance.

Penalties

Luxembourg imposes both administrative and criminal sanctions:

• Administrative fines range from €250 to €15,000 for failure to provide requested information or comply with enforcement decisions.
• Criminal fines range from €251 to €500,000 for violations of core obligations, and up to €1,000,000 for repeat offenses.

Courts may also confiscate profits or equipment involved in the offense.

Exceptions

The law adopts the term “disproportionate burden” (charge disproportionnée in French) and aligns its definition with Annex VI of Directive (EU) 2019/882, as amended by the European Commission.

According to Article 2 of the law, “‘Disproportionate burden’ means an excessive additional organisational or financial burden imposed on an economic operator, based on the relevant criteria set out in Annex VI of Directive (EU) 2019/882… taking into account, however, the likely benefits that may accrue to persons with disabilities.”

The burden must be excessive, not just inconvenient or costly.

Transition period

As in many other countries, services may continue using legacy products legally in use before that date until June 28, 2030. Existing service contracts signed before the law’s entry into force may remain valid without changes for up to 5 years.

Read the law: Malta: Accessibility Measures (European Accessibility Act) Regulations (in English)

Responsible authority

The Malta Competition and Consumer Affairs Authority (MCCAA) is designated as the national authority responsible for market surveillance and enforcement under SL 627.03. The MCCAA oversees compliance for products and services covered by the European Accessibility Act (EAA) on the Maltese market.

Enforcement triggers

Enforcement can be triggered by:

• Market surveillance inspections are initiated by the MCCAA.
• Complaints from individuals, organizations, or other Member States regarding inaccessible products or services.
• Discovery of non-compliance during product checks or service assessments, including improper CE marking or lack of accessibility documentation.
• Notifications from other EU member states under EU-wide safeguard procedures.

Corrective measures

If a product or service is found non-compliant, the MCCAA may:

• Require the economic operator to make the product or service compliant within a specified timeframe.
• Order the withdrawal or recall of non-compliant products from the market.
• Restrict or prohibit further provision of non-compliant services.
• Require updates to accessibility documentation and conformity declarations.

Website owners are expected to cooperate fully and may be required to provide technical documentation or compliance assessments upon request.

Penalties

Malta’s law allows for administrative fines and criminal penalties for violations:

• Administrative fines may be imposed for failure to cooperate with enforcement activities, provide required information, or comply with orders.
• Criminal penalties, including higher fines, may be applied for placing non-compliant products on the market or repeatedly violating accessibility requirements.

Penalty amounts are determined proportionally to the severity and extent of the non-compliance, but are not explicitly quantified in the regulation. The law also states that all penalties must be accompanied by remediation.

Exceptions

Malta follows the same exceptions as the EAA for microbusinesses. Products and services that would require a fundamental alteration or impose a disproportionate burden, based on criteria aligned with Annex VI of Directive (EU) 2019/882, also have an exception. Such claims must be documented and provided to MCCAA upon request.

Transition period

Malta’s law adopts the standard EU transition period:

Self-service terminals in use before the law’s entry into force may continue until the end of their economically useful life, capped at 20 years from initial deployment.

The law took effect on June 28, 2025.

Products placed on the market before this date are exempt.

Services delivered under contracts concluded before 28 June 2025 may continue until 28 June 2030 without full compliance.

Read the law: Netherlands: Product and Services Accessibility Regulations Implementation Act (Dutch) or Information for Entrepreneurs from the Dutch government.

Responsible authority

The Authority for Consumers & Markets (ACM) oversees the enforcement of accessibility requirements for digital services, including websites, e-commerce, and banking platforms. For products like ATMs and consumer hardware, supervision is handled via the Commodities Act, administered by the Ministry of Health, Welfare, and Sport through the Netherlands Enterprise Agency and linked market surveillance agencies.

Enforcement triggers

The Netherlands’ law states that websites will be determined to be out of compliance through several means:

• Proactive inspections and market surveillance by ACM or related authorities.
• Complaint-driven investigations from users experiencing accessibility issues.
• Required public posting of an Accessibility Statement specifying WCAG conformance, with evidence of compliance.
• Significant updates or redesigns to websites may trigger full compliance obligations, even during the transition period.

Corrective measures

Non-compliant websites receive warnings and deadlines to fix accessibility barriers. In case of failure, authorities may impose prohibitions on service provision until issues are resolved, or even block access temporarily to the website.

Penalties

Fines for non-compliance can reach up to €100,000 under the Commodities Act and The RDI (Rijksinspectie Digitale Infrastructuur a.k.a. The Dutch Authority for Digital Infrastructure), which is part of the Ministry of Economic Affairs. 

The Dutch government provides a detailed table of possible penalty ranges by category of the violation. Accessibility Act violations are considered Category II-III violations based on the severity, negligence, and the number of people impacted. Basic fines for category II violations are €25,000, and for category III are €50,000.

Exceptions

In addition to the EAA exception for microbusinesses, B2B services (not aimed at consumers) are generally outside the scope. 

Transition period

The standard 5-year transition period applies to websites that were live prior to June 28, 2025. However, “significant modifications” to existing websites after mid‑2025 trigger immediate compliance.

Read the law: Poland: Act of April 26, 2024, on Ensuring Compliance with Accessibility Requirements for Certain Products and Services by Economic Operators (in Polish)

Responsible authority

Enforcement of the European Accessibility Act in Poland is distributed among several entities depending on the type of product or service:

• President of the Office of Electronic Communications (UKE) – for telecommunications services.
• President of the Office of Rail Transport (UTK) – for transport-related services.
• Financial Ombudsman – for banking and financial services.
• Provincial Transport Inspection, Maritime and Inland Navigation Offices – for specific transport-related areas.
• PFRON (State Fund for the Rehabilitation of Disabled Persons) – may impose administrative fines and oversee certain compliance issues.

Enforcement triggers

Authorities can initiate enforcement when:

• A complaint is filed by a user or a third party.
• Surveillance authorities identify non-compliant products or services through inspections or market monitoring.
• Required documentation (e.g., conformity assessments) is missing or incomplete.
• A product or service fails to meet accessibility requirements defined by EU harmonized standards (e.g., EN 301 549).

Corrective measures

If non-compliance is identified:

• Authorities can demand documentation to assess compliance.
• Economic operators must implement corrective actions such as adapting services, updating interfaces, or providing alternate formats.
• If corrections are not made, authorities can order product withdrawals or service suspensions.
• Website owners may be required to update conformity documentation and inform users of changes.

Penalties

The Polish European Accessibility Act law allows for financial penalties of up to ten times the average monthly salary in the national economy, based on the previous year’s figures published by the Central Statistical Office in Monitor Polski. However, the fine may not exceed 10% of the business’s turnover from the financial year.

 The amount is determined based on:

• The seriousness of the violation.
• The number of affected products or services.
• The number of users impacted.

Fines are paid into the Accessibility Fund. Repeat violations or failure to act may result in enforcement via administrative procedures.

Exceptions

The standard exceptions under the European Accessibility Act for microbusinesses or if compliance would cause a disproportionate burden. In Poland, Claims of exemption must be documented, renewed at least every 5 years, and shared with authorities upon request.

Transition period

Poland’s law implementing the European Accessibility Act includes a transition period that allows products placed on the market before June 28, 2025, to remain in use without needing to meet new accessibility requirements until June 28, 2030. Contracts signed before the law takes effect can remain valid without modification for up to five years. Additionally, self-service terminals already in use before the law’s start date may continue operating for up to 20 years from their original deployment.

Read the law: Portugal: Decree Law No. 82/2022 (in Portuguese)

Responsible authority

Market surveillance and enforcement are conducted by sector-specific regulators:

• ANACOM (e‑communications, AVMS, e‑books, e‑commerce)
• IMT (transport sector)
• Banco de Portugal, ASF, CMVM (financial services)

Enforcement triggers

Triggers that might cause enforcement action to be taken include:

• Reports or internal findings of non-compliant products/services by regulators or consumers.
• Failure to prepare technical documentation, EU declarations of conformity, CE marking, etc., per detailed infractions listed in Article 28.

Corrective measures

Regulators can:

• Order non-compliant products/services to be corrected or withdrawn.
• Impose recalls, bans, or restrictions on offerings until compliance is achieved.

Penalties

Violations related to website accessibility—such as making inaccessible services available, failing to conduct required accessibility assessments, or failing to cooperate with authorities—are subject to administrative fines and additional sanctions.

Infractions are classified as either serious or very serious:

• Serious offenses (e.g., failure to maintain documentation or minor procedural violations):
  • Natural persons: €650 to €1,500
  • Legal persons (companies): €12,000 to €24,000
• Very serious offenses (e.g., launching or maintaining inaccessible websites or services, repeated noncompliance, refusal to take corrective action, or obstruction of authorities):
  • Natural persons: €2,000 up to the legal maximum under Decree-Law No. 433/82
  • Legal persons: €24,000 up to the legal maximum under Decree-Law No. 433/82

The maximum fine for a very serious offense, based on Decree-Law No. 433/82, sets fines using daily units (up to 300 days) with each day valued up to ~€50.

Additional considerations for fine amounts include:

• Recurrence, scale of noncompliance (number of affected users or inaccessible services), and negligence increase the severity of penalties.
• Fines for attempted or negligent offenses are halved.
• Paying the fine does not relieve the offender of the obligation to fix the accessibility issue.
• Authorities may also impose ancillary sanctions, and in all cases of conviction, the judgment will be publicized at the offender’s expense in at least two national newspapers.

Fines collected under Portugal’s accessibility law are distributed as follows: 40% goes to the State, 10% to the authority that reported the offense, 30% to the entities responsible for investigating the case, 10% to the National Institute for Rehabilitation (INR, I.P.), and 10% to the disability support fund. In the Autonomous Regions, the State’s share becomes local revenue.

Exceptions

There are no unique exceptions in the Portuguese law beyond the standard EAA exceptions.

Transition period

Entities using existing compliant products/services before the publishing of the law may continue using them until June 28, 2030; new websites published after June 28, 2025 must comply and be fully accessible from the date they are published.

Read the law: Romania: LAW no. 232 of July 19, 2022 (in Romanian)

Responsible authority

Enforcement of Romania’s EAA law is overseen jointly by the following bodies:

• The Authority for the Digitization of Romania (ADR) is the key body tasked with enforcing accessibility rules for websites. 
• The National Authority for Consumer Protection (ANPC) is also in charge of e-commerce and consumer services (e.g., websites).
• The National Audiovisual Council (CNA) oversees audiovisual media services, which may apply to online video.
• The Ministry of Transport and Infrastructure is responsible for transport websites, apps, and info screens.

Enforcement triggers

Enforcement of the European Accessibility Act in Romania was expected to begin in June 2025.

Compliance checks are triggered by:

• Complaints from any person or entity.
• Consumer protection authority audits.
• Market surveillance leading to the discovery of non‐compliance.

Authorities may order investigations or compliance reviews when websites or apps are found lacking, including gaps in accessibility statements or technical assessments.

Corrective measures

Once a non-compliance is found, authorities:

• Assess the website or service to identify issues.
• Order website owners to implement corrective actions within a “reasonable, proportional” timeframe.
• For systemic issues, ongoing monitoring or broader enforcement actions may follow.

Penalties

Under Romania’s law implementing the European Accessibility Act (EAA), economic operators—including website service providers—face financial penalties for noncompliance with digital accessibility requirements.

Fines for violations range from 5,000 to 15,000 lei (approximately €1,000 to €3,000), depending on the severity and type of infraction. For example:

• Failing to follow general accessibility obligations for digital services can result in fines from 6,000 to 12,000 lei (~€1,200 to €2,400).
• More specific failures, such as not maintaining accessibility documentation or failing to provide services in an accessible format, may draw fines up to 15,000 lei (~€3,000).
• Improper use of conformity markings (such as CE marks) is also fined, with penalties from 2,500 to 5,000 lei (~€500 to €1,000).

In addition to monetary fines, authorities may impose corrective actions, including removing non-compliant services from the market, suspending business activity, or withdrawing authorizations. Repeat violations or failure to act promptly can increase enforcement severity.

Exceptions

Romania’s implementation of the European Accessibility Act generally follows the EU-wide framework and introduces no unique or country-specific exceptions beyond what the directive already allows. 

Microenterprises are exempt from certain requirements when providing services, and all economic operators may invoke exceptions if compliance would impose a disproportionate burden or require a fundamental change to the nature of a product or service. However, these claims must be justified with documented assessments, and operators receiving external funding to improve accessibility cannot use the burden exception.

Transition period

The law entered into force on June 28, 2025. From that date, websites and digital services must meet applicable accessibility requirements, although micro-enterprises benefit from tailored exemptions and guidance. All e-communication must be accessible moving forward. 

Read the law: Slovakia: 351/2022 Z. z. (in Slovak)

Responsible authority

The Slovak Trade Inspection (Slovenská obchodná inšpekcia, SOI) serves as the national enforcement body for digital accessibility compliance and oversees market surveillance for websites and other online services.

Enforcement triggers

Inspections may be triggered through regular audits, consumer complaints, reports from public bodies, or routine SOI oversight. Websites providing public-facing services, such as e-commerce, banking, transport, digital books, and specialized software, are subject to monitoring.

Corrective measures

When non-compliance is identified, the SOI can require corrective actions within a set timeframe. It may also suspend or restrict the website’s operation, demand withdrawal of inaccessible content, or mandate updates to the Accessibility Statement. Cooperation and documentation must be provided by the operator within one year of discovering issues.

Penalties

Fines vary with the severity of non-compliance and are based on a percentage of revenue. Fines start at €200 and can go up to 3 % of turnover for the last financial year for which the company has filed or finalized accounts, capping at:

• Standard violations: €6,000.
• Severe violations (e.g., obstruction of inspection or missing documentation): €20,000.
• Refusal to cooperate: €30,000.

Exceptions

Slovakia’s implementation of the European Accessibility Act includes common EU-wide exceptions, such as exemptions for microenterprises offering services (businesses with fewer than 10 employees and annual turnover or balance sheet total not exceeding €2 million). 

Additionally, products and services may be exempt if complying with accessibility requirements would impose a disproportionate burden or necessitate a fundamental alteration to their nature. These conditions must be carefully assessed and documented by the economic operator. 

Slovakia has not introduced any unique or country-specific exceptions beyond what is allowed under the EU directive. All claims of exemption are subject to oversight and must be re-evaluated regularly.

Transition period

Legacy websites (those published or unchanged before that date) can continue without compliance until either they’re updated or the transitional period ends in 2030.

Read the law: Slovenia: Accessibility and Services Act (ZDPSI) (in Slovenian)

Responsible authority

The primary authority overseeing implementation is the Ministry of Digital Transformation. For specific sectors, enforcement may also involve other regulators, such as the Agency for Communication Networks and Services (AKOS), particularly for digital content and telecommunications.

Enforcement triggers

Enforcement is triggered when a for-profit organization offers digital products or services—such as e-commerce platforms, mobile apps, or websites—that do not comply with the accessibility requirements set by the law. Complaints from users, market surveillance activities, or lack of a required accessibility statement may all initiate action.

Corrective measures

Authorities can order the company to bring the service into compliance within a specified timeframe. If voluntary corrections are not made, further measures include orders to restrict or suspend access to the service or remove it from the market altogether. An official notice may also be published disclosing the company’s non-compliance.

Penalties

Slovenia imposes a range of financial penalties for businesses that fail to meet digital accessibility standards for products and services, including websites, e-commerce platforms, and e-books.

For general accessibility violations (e.g., missing technical documentation, failure to mark CE conformity, or not correcting non-compliant products), legal entities may face fines from €3,000 to €40,000, while individual entrepreneurs may be fined €2,000 to €15,000. Responsible persons within these organizations can also be fined separately.

For web-related services, such as:

• E-commerce websites: Fines range from €500 to €5,000 for small legal entities and €1,000 to €10,000 for medium or large companies.
  
• Audiovisual media services and e-books: Penalties can reach up to €10,000, especially if providers fail to offer synchronized audio/text, assistive tech compatibility, or accessible metadata.
  
• Electronic communications (e.g., emergency SMS, video relay): Fines range from €500 to €10,000, depending on company size and service scope.
  

Additionally, responsible individuals (such as company directors) may be fined separately, often between €50 and €400, for failing to ensure compliance within their role.

The law also allows for increased fines in repeat or egregious cases, and violations in other sectors—like banking or transport—carry their own specific penalties.

Exceptions

There are no unique exceptions in Slovenia. Standard EAA exceptions apply.

Microenterprises (with fewer than 10 employees and less than €2 million in annual turnover or balance sheet total) are exempt from the accessibility requirements for services. Additionally, exceptions may apply where compliance would impose a disproportionate burden, defined through a formal assessment considering technical feasibility and cost relative to the benefits for people with disabilities. The law has some guidance on determining if a disproportionate burden exemption applies. More detailed criteria for assessing a disproportionate burden shall be determined by the minister responsible for disability care in agreement with the Ministers responsible for market surveillance.

Archived web content and third-party content outside the control of the provider may also be excluded.

Transition period

The law came into force in April 2023, but requirements started to apply to most digital services in June 2025. Products or digital interfaces lawfully used before that date may continue to be used until the end of their service life (not exceeding 20 years). Existing contracts may remain in force until expiry, for up to five years from the enforcement date.

Read the law: Spain: Law 11/2023, of May 8 (in Spanish)

Responsible authority

The Ministry of Social Rights and Agenda 2030 oversees general coordination. For websites and digital services, enforcement is shared with sector-specific regulators such as the Ministry of Economic Affairs and Digital Transformation, and the National Commission on Markets and Competition (CNMC) for telecommunications. Regional authorities may also conduct monitoring and enforcement within their jurisdictions.

Enforcement triggers

Enforcement can be triggered by:

• Complaints from individuals, consumer organizations, or associations representing people with disabilities.
• Market surveillance detects non-compliance during routine or targeted inspections.
• Reports from public entities, especially if services are procured using public funds.

In Spain, websites and digital services subject to Ley 11/2023 do not require routine submission of their self-assessment reports to the government. However, they must:

• Publicly publish an accessibility statement, outlining current compliance, known limitations, and contact information.
• Maintain their technical documentation and conformity records for at least five years, which may be requested during compliance checks.

Though self-assessments aren’t automatically filed with state authorities, government bodies and enforcement agencies can request or audit these documents at any time. Non-compliance, such as failing to publish a statement or prepare documentation, can trigger formal reviews, complaints from users, or even sanctions based on the declared assessments.

Corrective measures

If a website in Spain is found to be non-compliant with digital accessibility requirements under Ley 11/2023, corrective enforcement actions may follow several pathways:

• Consumer Complaints or Market Surveillance: Individuals, consumer associations, or watchdog organizations can submit complaints. Additionally, Spain’s relevant market surveillance authorities (such as the Agencia Española de Consumo, Seguridad Alimentaria y Nutrición, or sector-specific bodies) may initiate reviews on their own.
• Request for Documentation: The website operator may be required to provide technical documentation, conformity assessments, or internal accessibility evaluations proving compliance with EN 301 549 and WCAG 2.1 AA. Failure to provide documentation can be treated as a procedural violation.
• Mandatory Remediation Orders: Authorities can issue formal notices requiring businesses to fix accessibility issues within a specified timeframe. If no corrective action is taken, the case may escalate.
• Sanctions and Fines: Persistent non-compliance, especially in the absence of justified exceptions (such as disproportionate burden), may lead to financial penalties. Fines vary depending on the severity, economic impact, and recurrence of the infraction.
• Public Disclosure: Authorities may also publicize violations, which can damage a company’s reputation and increase pressure to comply.

In essence, Spanish law takes a progressive enforcement approach—encouraging voluntary compliance but empowering regulators to impose binding corrective measures and penalties when digital accessibility is ignored.

Penalties

Article 30 establishes how violations of the Spanish accessibility law will be penalized:

Primary enforcement depends on sector-specific laws. If a company fails to comply with accessibility requirements (like for websites), the sanctions will come from the laws governing that particular sector—for example, e-commerce, telecom, banking, or audiovisual.

If no sectoral law applies, then Spain uses the general disability rights law—specifically, Title III of the Consolidated Text of the General Law on the Rights of Persons with Disabilities and their Social Inclusion (Royal Legislative Decree 1/2013). This law sets penalties ranging from minor to very serious, with fines that can reach up to €1 million for severe and repeated violations.

• Minor infractions (e.g., missing formats or documents):  €301-€30,000.
• Serious infractions (e.g., discriminatory acts, failure to provide accessibility adjustments, ignoring official demands): fines up to €90,000.
• Very serious infractions (e.g., harassment, repeated non‑compliance, pressure on authorities): fines can reach up to €1,000,000.

Exceptions

Spanish law does not allow for any unique exceptions from the standard EAA exceptions. Microenterprises (fewer than 10 employees and less than €2 million in turnover) are exempt from accessibility obligations for websites, unless they are delivering public services under contract. Additionally, economic operators may claim an undue burden, but only after documented analysis and notification to the relevant authorities.

Transition period

Websites and e-commerce services covered under the law must comply by June 28, 2025. However, services or digital tools that were already in use before this date may continue to operate in their existing form until June 28, 2030, provided no substantial changes are made. These “legacy” services are subject to gradual updates and monitoring.

Read the law: Sweden: Implementation of the Accessibility Directive (in Swedish)

Responsible authority

The primary enforcement body for accessibility of online services—such as e‑commerce, electronic communications, and banking—in Sweden is the Post and Telecom Authority (PTS). It coordinates with:

• The Media Authority for audiovisual media services.
• Consumer Agency and Transport Agency for passenger transport services.
• MTM (Swedish Agency for Accessible Media) for e‑book accessibility.

Enforcement triggers

PTS conducts market surveillance through:

• Complaints from end-users or organizations via an online portal.
• Own-initiative checks, focusing on declared exemptions for disproportionate burden or fundamental alterations.
• They also monitor compliance with reporting obligations such as accessibility statements.

Corrective measures

If non-compliance is found, PTS may:

• Order removal or blocking of inaccessible features.
• Impose corrective technical requirements.
• Coordinate withdrawals or fix timelines.
• Publicize breaches to ensure transparency.

Penalties

Sweden has established a system of administrative sanction fees for businesses that fail to meet digital accessibility requirements under its implementation of the European Accessibility Act. These fees are enforced by supervisory and market control authorities and can be imposed for past violations—even if they occurred through negligence and not intentional wrongdoing.

Fines range from SEK 10,000 to SEK 10,000,000 (approximately €870 to €870,000), depending on the severity and extent of the violation, the number of people affected, and whether the business has taken steps to fix the issue. Authorities will also consider whether the issue was repeated, the company’s size and turnover, and whether similar violations have occurred in other EU countries.

Fees are not imposed for minor infractions and can be reduced in full or in part for special reasons (e.g. if the breach was outside the business’s control). However, excuses like poor routines, time constraints, or lack of awareness are not considered valid reasons to avoid fines.

Businesses must pay the sanction within 30 days of the decision becoming final. If unpaid for five years, the fee is nullified.

Importantly, Sweden’s system respects the “no double penalty” rule, meaning a business cannot be punished twice for the same violation. If a fine is already issued or a court process is ongoing, a new penalty can’t be added for the same issue.

Exceptions

Swedish law does not allow for any unique exemptions beyond the standard EAA exceptions for microbusinesses and if compliance would impose a disproportionately high burden or result in a fundamental change to a product or service. In such cases, affected organizations must document their assessment, retain the evaluation for authorities, and inform PTS.

Transition period

Sweden’s transition period under its implementation of the European Accessibility Act aligns with the general EU deadline: the law entered into force on June 28, 2025, the same as in most other EU member states. 

Sweden does not provide any unique or extended transition periods beyond what is outlined in the directive. However, like other countries, certain legacy services and contracts signed before that date may continue temporarily under previous rules. Overall, Sweden follows the standard EU timeline without introducing notable deviations or additional grace periods.