One Year of the European Accessibility Act: What Enforcement in Europe Looks Like So Far

From the Netherlands to Scandinavia and France, a clear pattern has emerged, market surveillance bodies are testing real online services, documenting shortcomings and setting deadlines for remediation. Companies that let those deadlines pass are now facing real consequences. Here is what has already happened across Europe, and what it means for any business operating in Germany or across the EU.

One thing stands out across these cases, they are not confined to a single sector. They span online retail, healthcare, telecommunications and financial services. Anyone running one of these kinds of services should read the examples below not as a footnote from abroad, but as a preview of what regulators can test in their own market too.

What the EAA has required since June 2025

The EAA, formally Directive (EU) 2019/882, requires companies in selected sectors to make their digital products and services accessible, with exemptions mainly for micro-enterprises, those with fewer than ten employees and an annual turnover or balance sheet total of no more than two million euros. It specifically covers:

• ✓ E-commerce, the entire online retail sector for consumers
• ✓ Banking services, including ATMs and online banking
• ✓ Telecommunications, including emergency calls and devices such as routers or modems
• ✓ Audiovisual media, streaming services and media libraries
• ✓ E-books, with requirements for accessible reading
• ✓ Passenger transport, across air, rail, bus and waterway

Germany implemented the EAA through its Barrierefreiheitsstärkungsgesetz (BFSG), which is largely identical in substance. Enforcement, however, sits with each country's own market surveillance authority, and that is exactly where the pace has started to diverge since the deadline passed.

The Netherlands, the ACM shows how seriously regulators mean it

The Dutch consumer and market authority, the ACM, is one of the most active regulators in Europe. It requires companies to report critical barriers within a week and moderate issues within a month, each with a binding remediation plan. After sending letters to the leadership of large online shops during 2025, the ACM followed up with a market scan in March 2026 covering roughly 100 of the largest Dutch online shops. The result was stark, placing an order using assistive technology was impossible on 61 percent of the sites tested, and another 33 percent had serious problems. The ACM expects to move to formal enforcement in the second half of 2026, while the Dutch financial regulator AFM has been running its own parallel investigation into banking services since April 2026. For many of the shops tested, the decisive question was the simplest one, whether an order could be completed at all using a keyboard or screen reader, not finer details like color contrast or alt text.

Sweden, France, the Czech Republic and Ireland follow suit

Other member states have moved as well, each with a different focus. In Sweden, the post and telecom authority PTS has started inspecting e-commerce services, with more to follow through 2026. In France, disability rights organizations filed complaints in interim proceedings against four major food retailers that had missed their compliance deadlines. Interim proceedings typically reach a court ruling far faster than an ordinary lawsuit, which adds extra pressure on the companies involved. The Czech authority plans to publish public lists of non-compliant products and services, which amounts to a significant reputational risk for the companies named. In Ireland, the regulator ComReg is processing consumer complaints, including one against the country's largest mobile operator.

Norway, a fine makes the consequences concrete

The clearest example of what is at stake comes from Norway's HelsaMi case. HelsaMi is a patient portal used by roughly 425,000 people in central Norway. The country's authority for universal ICT design found 119 accessibility issues spanning 12 of 14 legal requirements during an inspection. After the first deadline passed, 64 issues remained unresolved, including missing zoom and reflow support up to 400 percent, meaning content could not be enlarged significantly without forcing horizontal scrolling, along with missing form labels and error messages, insufficient color contrast, and weak keyboard focus indicators. The authority then imposed a fine of 50,000 Norwegian kroner per day if the operator failed to fix the remaining issues by 19 December 2025. These kinds of deadlines and fines are no longer isolated incidents but a pattern repeating across Europe.

What this means for businesses operating in Germany

In Germany, market surveillance for the BFSG sits with the individual federal states. A joint coordinating body for the states, intended to take over that role, is based in Saxony-Anhalt but is still being set up. So far, only a handful of states, Bavaria among them, have publicly named which office is actually responsible. As a result, formal enforcement in Germany is starting noticeably slower than in the Netherlands or Norway.

That does not mean German companies are off the hook. Private warning letters brought under competition law are already running in parallel, as a wave of BFSG-related warning letters since summer 2026 has shown. Any company assuming it can get by without solid technical documentation and a coherent accessibility statement is also underestimating how quickly a routine spot check, once state-level market surveillance is fully operational, can turn into a formal procedure with binding deadlines. The Dutch figures are a realistic indicator of how many German online shops would likely perform in a comparable test today.

How SiteCockpit supports EAA compliance

The exact kind of issues regulators in the Netherlands and Norway found can be caught automatically with easyMonitoring, before a regulator finds them first. The tool scans websites, online shops and apps on a regular basis, prioritizes detected barriers by urgency, and makes progress over time traceable. That matches exactly the principle many regulators now apply themselves, namely monitoring accessibility continuously rather than checking it once and moving on. For the documentation obligations that can make the difference between a closed inquiry and a formal procedure, easyStatement generates the matching accessibility statement, without having to be pieced together by hand.

• ✓ Have your website, shop or app scanned, for an honest read on where you stand today
• ✓ Prioritize findings by risk, the same way regulators do in their own inspections
• ✓ Build technical documentation, so you can produce evidence if it is ever requested
• ✓ Monitor continuously instead of checking once, since new content keeps creating new barriers

The European cases from the past year make one thing clear, accessibility is no longer something companies can postpone indefinitely, it is being actively tested, with firm deadlines and, where those deadlines are missed, fines that are far from symbolic. Starting with an honest scan now buys the time to work through the findings in an orderly way, instead of reacting to a regulator's inquiry or a warning letter first.