The European Accessibility Act doesn't set one fixed EU-wide fine — it requires member states to define their own "effective, proportionate and dissuasive" penalties in national law, which is why the actual numbers vary a lot from country to country.
Maximum penalties by country
Based on national transposition laws as published:
| Country | Maximum penalty |
|---|---|
| Hungary | €1,260,000 |
| Spain | €1,000,000 |
| Netherlands | up to €900,000 |
| Sweden | approximately €900,000 |
| Italy | up to 5% of annual turnover |
| France | €250,000 |
| Germany | €100,000 |
| Ireland | €60,000 |
Two things stand out here. First, the range is enormous — a business found non-compliant in Hungary faces a maximum penalty over 20 times higher than the same violation in Ireland. Second, Italy's structure is different in kind, not just amount: tying the penalty to a percentage of turnover means the fine scales with the size of the business, rather than being a fixed cap everyone faces regardless of company size.
Enforcement isn't only about the government fine
All 27 EU member states transposed the directive into national law and enforcement began 28 June 2025. The first EAA lawsuits were filed in France in November 2025, and several other member states — the Netherlands among them — have signaled enforcement activity through 2026.
Beyond a formal regulatory fine, enforcement mechanisms in various countries include: ordering a non-compliant product or service withdrawn from the market, requiring an accessibility audit, daily penalties that continue accruing until an issue is fixed (rather than a single fixed fine), and — in some jurisdictions — publicly naming non-compliant organizations. In Germany specifically, private actors (not just the state) have reportedly begun sending warning letters to non-compliant sites within weeks of the law taking effect, which is a separate, faster-moving risk than waiting for a formal government enforcement action.
What this means practically
If your business operates across multiple EU countries, the penalty you'd actually face depends on which member state's law applies to your case — which in turn generally follows from where your business is established or where the service is provided, not simply "the EU" as a single bloc. That's not a reason to treat this loosely in a low-penalty country; a €60,000 Irish maximum is still a real, material cost for most small and mid-size businesses, and non-monetary enforcement (product withdrawal, mandatory audits) applies regardless of the fine cap.
The reliable way to reduce this risk in either direction — regulatory fine or a private warning letter — is the same: know what's actually failing on your site and fix it, rather than finding out from an enforcement notice.
Penalty figures above are sourced from published national transposition summaries as of mid-2026 and may be revised by individual member states — always confirm the current figure for your specific jurisdiction before relying on it for a compliance decision.
I write about EU web accessibility law at Cluesia — this post originally appeared there, where you can also run a free check on your own site.
