Research
The EAA hasn't fined anyone yet. Here's why smart shops are fixing accessibility now
The European Accessibility Act has applied to e-commerce and consumer digital services since 28 June 2025 (ACM). If you sell online in the EU, your checkout is in scope. So here is the least convenient fact for the vendors selling accessibility with fear: no monetary EAA fines have been issued anywhere yet. Not one, in any member state. If a cold email tells you a fine is about to land in your inbox, that email is selling you a story.
That does not mean nothing is happening. It means what is happening is testing, public naming, and court-ordered fixes rather than penalties, and those are arguably harder to ignore than a fine. The point of this piece is to give you the accurate picture so you can respond with planning instead of panic, because the shops treating this calmly now are the ones who will not be scrambling later.
What the European Accessibility Act actually requires
The short version: consumer-facing digital services, e-commerce very much included, have to be usable by people with disabilities. In practice that maps to the technical standard EN 301 549, which for the web means conforming to WCAG. The plain-English test a regulator cares about is not whether your code passes a linter. It is whether a real customer using assistive technology, a screen reader and a keyboard, can find a product, add it to the basket, and complete the purchase without hitting a wall.
That framing matters because it tells you what "compliance" is not. It is not a badge you buy or a widget you paste in. It is the end-to-end journey working for a person who cannot use a mouse or see the screen. Which is exactly why the enforcement signals so far all point at the journey, not the paperwork.
Are regulators actually checking? Yes, and publishing the results
In the Netherlands, the regulator ACM tested the roughly 100 largest Dutch webshops and found that 61% fail its core test: a customer using assistive technology cannot complete an order (ACM). Sit with that number. Six in ten of the biggest shops in a wealthy, digitally mature market cannot take money from a disabled customer through to the end. That is not a footnote failing on an obscure page. It is the till not working.
ACM has signalled that formal enforcement steps are expected from mid-2026. Note what its test measures: can the purchase actually be completed with a screen reader and keyboard. That is the same thing every serious accessibility standard is really about, and it is precisely the part an automated scan cannot verify on its own. A scanner can tell you a button has no label. It cannot tell you the checkout is completable. Regulators are testing the second thing.
Courts are already compelling fixes, with a clock attached
The sharpest signal so far comes from France. In June 2026 the Tribunal judiciaire de Caen ordered Carrefour to make its website and app fully accessible within six months, under a daily penalty for non-compliance (LSA Conso, handicap.fr). Read the shape of that remedy carefully. The court did not write a cheque and move on. It set a deadline to fix the actual thing, and it attached a daily penalty that starts running if the deadline slips. That is compulsion with a stopwatch.
This is the model worth watching, because it is more demanding than a one-off fine. A fine you can budget for and forget. A court order says: do the work, do it within six months, and every day you are late costs you. And in the same case the court declined, for now, to impose the same obligation on a competitor, which tells you these outcomes turn on the specific facts of who was brought to court. It is litigation, and litigation is unpredictable and expensive to be on the wrong side of.
What about enforcement against the shortcuts?
Look across the Atlantic for the other data point. In January 2025 the US Federal Trade Commission ordered the overlay vendor accessiBe to pay $1,000,000 over deceptive claims that its AI product could make websites WCAG-compliant (FTC). To be precise, and we are always precise about enforcement, that was a consumer-protection action about false advertising, not a fine under any accessibility statute. But it is a useful reminder that the quick fixes are drawing scrutiny of their own. If your plan for the EAA is to paste in a compliance widget, the regulator most likely to notice you may be the one policing the widget's claims. We dig into why those widgets fail in the piece on overlays.
Why the honest argument is the stronger one
Here is the pitch we actually believe, and it does not need a single invented fine. Because no penalties have been issued, you still hold the cheap option: fix your site once, calmly, on your own schedule, at normal rates. The expensive option is doing the identical work later under a Carrefour-style deadline, at panic prices, with a daily penalty ticking and a competitor watching. Enforcement escalates on the regulator's timetable, not yours, and the calm window is open right now.
There is also a reason to act that has nothing to do with the law at all. Enterprise and public-sector buyers already ask for a conformance statement before they sign, so deals are quietly being lost today while the legal risk is still theoretical. And around 1 in 6 people worldwide have a significant disability, a group whose spending you are turning away at the checkout every day the site stays broken. The regulation is just a deadline. The customers were always the point. If you want to see how we approach the fixes, that is what our service is built to do: audit to the standard, then ship the corrections.
Common questions
Has anyone actually been fined under the EAA?
No. As of this writing, no monetary EAA fines have been issued in any member state. The enforcement so far has taken the form of regulator testing and public findings, plus court orders like the Carrefour ruling that compel fixes under a daily penalty rather than levying a flat fine.
Does the EAA apply to my small online shop?
The Act covers e-commerce and consumer digital services broadly, so most shops selling to EU consumers are in scope. There are limited exceptions for microenterprises providing services, and the details depend on how each member state transposed the law. The safe assumption for a typical webshop is that you are covered.
What is the single most important thing to check?
Whether a customer using only a screen reader and a keyboard can complete a purchase end to end. That is the test ACM ran to get its 61% failure figure, and it is the test that a court or a real customer will apply. Everything else is secondary to the checkout actually working.
The way we handle this is the way a regulator would: we audit your site against the WCAG success criteria using the WCAG-EM methodology, then a human goes through the real purchase journey with a screen reader to confirm it can be completed, and we deliver the corrections as reviewable pull requests plus an EN 301 549 conformance statement you can hand to a buyer. No fine threats, because there are no fines to threaten with.
See where your own shop stands. Our free scan runs the same automated checks a regulator's tester starts with, then a human goes through your site with a screen reader and emails you the findings, in plain language. If your shop passes, we say so.
Get a free scanSources
- ACM (Netherlands Authority for Consumers and Markets), EAA scope since 28 June 2025 and 61% webshop failure finding: https://www.acm.nl/
- Carrefour ruling (Tribunal judiciaire de Caen, June 2026): LSA Conso and handicap.fr.
- FTC order against accessiBe, January 2025: https://www.ftc.gov/news-events/news/press-releases/2025/01/ftc-order-requires-online-marketer-pay-1-million-deceptive-claims-its-ai-product-could-make-websites