Artifact GuideEU

EU Accessibility Act penalties and fines

Directive (EU) 2019/882 does not create one EU-wide fine table. It requires each Member State to set penalties for infringements of its national transposition rules.

To determine exposure, identify the applicable national law and authority, then separate product market surveillance, service compliance checks, consumer enforcement routes, corrective measures, and penalties.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 24, 2026
Sections
4

Structured answer sets in this page tree.

Primary sources
4

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 24, 2026
Overview

There is no single EU Accessibility Act fine amount. Article 30 of Directive (EU) 2019/882 requires each Member State to set and implement penalties for infringements of its national transposition rules. Those penalties must be effective, proportionate, and dissuasive, must be accompanied by effective remedial action, and must account for the extent and seriousness of the non-compliance, the number of non-complying product or service units, and the number of people affected. An actual amount or sanction therefore requires the 's role, the current national law, the competent authority's powers, and the case facts.

Section 1

What Article 30 actually says about EAA penalties

Directive (EU) 2019/882 sets the penalty standard and leaves the sanction types, amounts, calculation methods, procedures, and responsible authorities to Member States. The Directive supports statements about required penalty characteristics, Commission notification, and EU-level assessment criteria; it does not support a single EU-wide maximum fine.

Article 30 also requires effective remedial action when an does not comply. Depending on national law and the product or service procedure, exposure may therefore include an order to correct non-compliance, a restriction or withdrawal affecting a product, another national remedy, and a penalty. Do not use a fine estimate as a substitute for the remediation plan.

The procurement exclusion is narrow. Article 30(5) says Article 30 does not apply to procurement procedures subject to Directives 2014/24/EU or 2014/25/EU, and Article 29 contains the same exclusion for its enforcement routes. It does not say that covered products or services, contracting authorities, or economic operators are generally exempt from accessibility or procurement law.

  • Member States set the penalty rules for infringements of their national EAA transposition provisions.
  • Member States must notify the Commission of those rules and any later amendments.
  • Penalty assessment must take account of the extent and seriousness of non-compliance, the number of non-complying product or service units, and the number of persons affected.
  • Articles 29 and 30 do not apply to procurement procedures covered by Directives 2014/24/EU or 2014/25/EU; use the remedies and enforcement framework applicable to those procurement procedures.
Section 2

Product enforcement: market surveillance and corrective action

For products, the Directive uses market surveillance. Article 19 applies specified provisions of Regulation (EC) No 765/2008 and requires authorities to check the assessment, result, and Annex VI criteria when an relies on Article 14 fundamental alteration or disproportionate burden.

Under Article 20, an authority with sufficient reason to believe that a covered product does not comply evaluates it against the Directive and the relevant economic operators must cooperate. If the authority finds non-compliance, it requires appropriate corrective action within a reasonable period. It requires withdrawal within an additional reasonable period only if the operator does not take adequate corrective action. Cross-border cases can also trigger notification to the Commission and other Member States and the Union safeguard procedure.

Article 22 covers formal non-compliance separately. The listed defects include missing or improperly affixed CE marking, a missing or incorrect EU declaration of conformity, unavailable or incomplete technical documentation, and missing, false, or incomplete manufacturer or importer information. Persistent formal non-compliance can lead to restriction, prohibition, or withdrawal.

  • Keep the EU declaration of conformity, technical documentation, accessibility assessment records, Article 14 assessments where used, and the evidence behind any claimed presumption of conformity.
  • Be prepared to identify the non-compliant product, origin, nature of the alleged non-compliance, affected accessibility requirements, national measures taken, and the 's arguments.
  • In an authority response, identify the model or batch, the affected requirement, where the product was made available, the economic operators in the supply chain, the evidence reviewed, the corrective action, the completion date, and whether withdrawal or customer communication is required.
Section 3

Service enforcement: compliance checks and complaints

Services follow a different compliance architecture from products. Article 23 requires Member States to establish, implement, and periodically update procedures for checking service compliance, following up complaints or reports, and verifying that the has taken the necessary corrective action.

Member States must designate the authorities responsible for those procedures and inform the public about the authorities' existence, responsibilities, identity, work, and decisions. That information must be available in accessible formats on request. Article 13 separately requires a service provider that identifies non-compliance to take corrective measures and immediately inform the competent national authorities in every Member State where the service is provided, including details of the non-compliance and measures taken.

  • For service providers, keep the Article 13 information explaining how the service meets the applicable accessibility requirements.
  • Keep procedures showing how changes in the service, accessibility requirements, harmonised standards, or technical specifications are taken into account.
  • Keep complaint logs, accessibility reports, corrective-action records, and evidence that the service remains aligned with the applicable requirements.
  • If relying on Article 14, keep the documented assessment, record the information sent to the relevant authority, and be prepared to provide the assessment on request. Microenterprises are excepted from the Article 14(8) information duty.
  • For each affected Member State, record the competent authority, notification route, date notified, service and requirement affected, consumer impact, interim measure, permanent correction, verification result, and closure evidence.
Section 4

Enforcement routes for consumers and organisations

Article 29 requires Member States to provide adequate and effective means to ensure compliance. Those means must include routes for a consumer to act under national law before a court or competent administrative body. It does not create a single EU complaint portal, filing deadline, remedy, or appeal route.

The same Article also requires routes for public bodies or private associations, organisations, or other legal entities with a legitimate interest to engage in judicial or administrative procedures, either on behalf of or in support of the complainant, with that complainant's approval. As with penalties, the detailed procedure is national law.

For a country-specific exposure check, identify the Member State and role first. Then locate the notified transposition measure, verify the current operative text in the national official legal database, identify the competent authority and procedure, and map the alleged conduct to the national provision. Only then record the available corrective measures, fine range or calculation rule, appeal route, and deadlines.

  • Do not describe Article 29 as a single EU complaint form; it requires national legal routes.
  • Do not treat consumer enforcement, service-compliance checks, product market surveillance, and penalties as the same procedure.
  • Do not publish national fine caps, appeal windows, competent authority names, administrative measures, or criminal sanctions unless current jurisdiction-specific sources support them.
  • Use the EUR-Lex national transposition collection to locate measures notified by a Member State, then verify the operative text in that country's official legal database. EUR-Lex states that Member States are responsible for the notified information and that notification does not prejudge the Commission's assessment of complete and correct transposition.
Recommended next step

Review EAA enforcement exposure with citations

Use the EAA enforcement structure to separate product market-surveillance risks, service compliance checks, consumer enforcement routes, and the national law that sets the actual penalty rules in your Member State.

Primary sources

References and citations

eur-lex.europa.eu
Referenced sections
  • Commission guidance explaining EU product-rule market surveillance, economic-operator cooperation, CE marking supervision, and Member State sanctions for CE marking misuse.
"supervision of the CE marking"
Related guides

Explore more topics

EAA Accessibility Conformance Statement Template
Template language for an EU Accessibility Act conformance statement covering scope, Annex I mapping, service information, standards, support routes, evidence, and limits.
EAA Article 14 disproportionate burden workflow
A cited EU Accessibility Act workflow for Article 14 fundamental alteration and disproportionate burden assessments, records, reassessment triggers, and evidence.
EAA conformance statements: products, services, EN 301 549 evidence
What an EU Accessibility Act conformance statement should include, with product EU declarations, service information, EN 301 549 and WCAG evidence boundaries.
EAA e-commerce checkout accessibility FAQ
How to test an e-commerce checkout under the European Accessibility Act, including service scope, payment and identification flows, service information, and evidence.
EAA e-commerce checkout accessibility guide
EU Accessibility Act guide for e-commerce checkout scope, payment and identification requirements, evidence, standards mapping, and customer information.
EAA EN 301 549 and WCAG mapping
Map European Accessibility Act Annex I requirements to EN 301 549 and WCAG evidence without overstating what WCAG tests can prove.
EAA EN 301 549 clause mapping for ICT evidence
Map EN 301 549 clauses to EU Accessibility Act evidence, Annex I outcomes, product and service records, and gaps that need non-ICT support.
EAA procurement clauses and accessibility acceptance criteria
Buyer-side EU Accessibility Act procurement language for covered products and services, with supplier evidence, EN 301 549 limits, Article 14 exception records, and acceptance criteria.
EAA scope classifier workflow for products and services
Classify EU Accessibility Act scope by product or service category, consumer use, market or service date, operator role, exclusions, exemptions, Article 14 records, and evidence.
EAA testing and conformance evidence | Annex I, EN 301 549 and Article 14
How to document European Accessibility Act testing evidence: Annex I mappings, product technical files, service information, EN 301 549 boundaries, harmonised-standard limits, and Article 14 exception records.
EAA WCAG evidence and procurement acceptance
How to use EN 301 549 and WCAG evidence in EU Accessibility Act procurement acceptance without overstating presumption of conformity.
EN 301 549 clause mapping for the EU Accessibility Act | EAA FAQ
How to map EN 301 549 and WCAG evidence to EU Accessibility Act Annex I requirements without overclaiming presumption of conformity.
EN 301 549 evidence matrix workflow for EAA readiness
Build an EN 301 549 evidence matrix for European Accessibility Act work: scope rows, clause mapping, test evidence, owner sign-off, exception records, and limits of standards evidence.
EN 301 549 vs WCAG for EAA evidence
Compare EN 301 549 and WCAG for European Accessibility Act planning: ICT scope, web-content overlap, harmonised-standard limits, and evidence beyond WCAG-only tests.
EU Accessibility Act Applicability Test
Check whether the European Accessibility Act covers a product or consumer service, which role applies, which date matters, and what evidence to keep.
EU Accessibility Act authority request response FAQ
How to answer EU Accessibility Act checks from market surveillance or service authorities with technical documentation, service information, Article 14 records, and corrective actions.
EU Accessibility Act checklist for products and services
Checklist for EAA scope, operator role, Annex I mapping, product technical files, service information, Article 14 assessments, supplier evidence, release checks, and monitoring.
EU Accessibility Act compliance operating model
Build an EU Accessibility Act compliance file for covered products and services: scope, operator roles, Annex I mapping, conformity evidence, Article 14 assessments, corrective actions, and records.
EU Accessibility Act deadlines and compliance calendar
Calendar for the EU Accessibility Act: 2022 transposition, 2025 application, 2027 emergency communications timing, 2030 transition rules, owner actions, and evidence records.
EU Accessibility Act deadlines and transition plan
Plan for the European Accessibility Act application date, service-contract transition, self-service terminal transition, 112 derogation, and evidence gates.
EU Accessibility Act disproportionate burden decision
How to document an EU Accessibility Act Article 14 disproportionate burden decision with supported criteria, retained evidence, limits, notifications, and review triggers.
EU Accessibility Act exemptions and disproportionate burden
Article 14 EAA guide covering fundamental alteration, disproportionate burden, service microenterprise exemptions, content exclusions, transition limits, and documentation.
EU Accessibility Act FAQ: scope, dates, services, Article 14
Clear answers on EU Accessibility Act scope, 28 June 2025 application, covered products and services, microenterprises, Article 14, service information, standards, and penalties.
EU Accessibility Act for ecommerce websites
EU Accessibility Act guide for ecommerce teams covering consumer checkout journeys, service information, accessibility evidence, and exceptions.
EU Accessibility Act microenterprise exemption and disproportionate burden FAQ
FAQ explaining when EAA microenterprise relief applies, how Article 14 disproportionate-burden assessments work, what Annex VI requires, and what records to keep.
EU Accessibility Act procurement acceptance criteria | EAA FAQ
How to write EAA procurement acceptance criteria that ask suppliers for scoped accessibility evidence, standards mappings, declarations, and exception records without overclaiming conformity.
EU Accessibility Act Product and Service Scope
Scope products and services under the EU Accessibility Act using Article 2 categories, Article 3 definitions, limited content exclusions, microenterprise treatment, and evidence records.
EU Accessibility Act products and services in scope
Article 2 scope guide for the European Accessibility Act: covered products, covered consumer services, economic-operator roles, Article 3 definitions, and evidence records.
EU Accessibility Act Requirements: Annex I, Products, Services
Map EU Accessibility Act requirements by Article 4, Annex I, product and service obligations, Article 13 evidence, standards, and Article 14 exceptions.
EU Accessibility Act service transition rules under Article 32 | EAA FAQ
FAQ on EU Accessibility Act Article 32 transition rules for service providers, pre-28 June 2025 contracts, 2030 limits, self-service terminals, evidence records, and change triggers.
EU Accessibility Act services: banking, transport, media and e-books
FAQ on which consumer banking, transport, audiovisual media access, electronic communications, e-book, and e-commerce services fall under the EU Accessibility Act.
EU Accessibility Act vs ADA and Section 508
Compare EAA product and consumer-service duties with ADA Title II and III accessibility duties and US federal Section 508 ICT requirements.
EU Accessibility Act vs Web Accessibility Directive
Compare the European Accessibility Act with the Web Accessibility Directive: scope, covered actors, services, standards, evidence, monitoring, enforcement, and key dates.
WCAG Evidence for the EU Accessibility Act and EN 301 549 | EAA FAQ
When WCAG test evidence helps EAA work, how it maps through EN 301 549, and why WCAG alone does not prove European Accessibility Act compliance.
Which products and services does the EU Accessibility Act cover? | EAA FAQ
Article 2 and Article 3 scope summary for EU Accessibility Act covered products, services, exclusions, product-service boundaries, and records to keep.