The EAA across Europe: how EU countries implemented it

The European Accessibility Act has applied across the entire EU since 28 June 2025 – but every country implemented it with its own national law. This overview shows which rules, fines and authorities apply where.

One directive, 27 implementations

The European Accessibility Act (EAA) is Directive (EU) 2019/882. As an EU directive, it does not apply directly – every member state had to transpose it into national law by 28 June 2022. The obligations themselves have applied since 28 June 2025, in all 27 EU countries. Anyone offering products or services in scope – such as an online shop, online banking or e-books – has had to meet the accessibility requirements since that date. What that means in detail is covered in our foundational article on the BFSG and the EAA.

In practice, however, this also means there is no single EAA law. Germany has its Barrierefreiheitsstärkungsgesetz, Austria its Barrierefreiheitsgesetz, France a mix of statute, decree and order, Spain an omnibus act. The substantive basis is the same everywhere, but when it comes to fines, authorities and procedures, the countries go their own ways. Those differences are exactly what we look at here.

What is the same in every country

Because the EAA aims at full harmonisation, all national laws share the same core:

• The same technical benchmark: The requirements are worded functionally and are made concrete in practice through the European standard EN 301 549, which for websites and apps points to the WCAG at level AA. If you build to WCAG conformance, you are working on the right basis in every EU country.
• The same scope: Covered areas include e-commerce, consumer banking services, telecommunications, e-books, self-service terminals and parts of passenger transport.
• The microenterprise exemption: Service providers with fewer than 10 employees and an annual turnover or balance sheet total not exceeding 2 million euros are exempt from the service obligations. This exemption comes directly from the directive and applies in all member states.
• Transition periods: Service contracts concluded before 28 June 2025 may continue unchanged until 28 June 2030 at the latest. Longer periods apply to self-service terminals already in use. For new or substantially changed offerings, the obligations apply immediately.

Where the countries differ

The directive left member states discretion mainly on enforcement and sanctions – and they used it. Three patterns stand out:

• Fine ranges: They span from a few tens of thousands of euros (for example Portugal or Slovakia) through six-figure amounts (Germany, Luxembourg, Spain) up to turnover-based penalties (Belgium, Poland). Ireland additionally relies on criminal law – up to and including prison sentences for those responsible.
• Supervisory structure: Some countries concentrate enforcement in one central body (Germany, Austria, Luxembourg, Finland), others distribute it across several sector regulators (Netherlands, Poland, Denmark).
• Implementation style: Some states created a stand-alone accessibility act, others amended existing laws or packed the EAA into an omnibus act. This makes little difference for the obligations themselves, but quite a lot when researching a specific case.

Country table: transposition laws at a glance

The table lists 20 EU countries with their transposition law and – where reliably documented – fine ranges and the competent authority. All information without guarantee; the official legal texts are authoritative.

The remaining member states – including Bulgaria, Latvia, Lithuania, Malta, Romania, Slovenia and Cyprus – have also adopted or initiated their own transposition acts. Several states were late with transposition or had to make corrections after objections from the European Commission. If you sell into these markets, check the current status directly with the national authorities.

What does this mean for cross-border shops?

Which law applies does not depend on where your company is based, but on the market you serve: anyone offering products or services to consumers in an EU country must comply with that country's EAA implementation. A German online shop delivering to France, Austria and Spain formally deals with four laws – and, if things go wrong, with the supervisory authority of each individual country.

The good news: in substance this is not a fourfold effort. Since all the laws build on the same requirements of the directive and on EN 301 549, a website that properly implements WCAG 2.1 AA (better: 2.2 AA) meets the core technical requirement in every member state. Differences remain mainly in three places:

• Accessibility information: Your accessibility statement should be available in the languages of your target markets and contain the details required there.
• Sanction risk: How expensive a violation gets depends on the country of the supervising authority – from a few thousand euros to turnover-based fines or criminal consequences.
• Complaint channels: Consumers and associations can turn to the respective national authority. In France and Sweden, authorities started their first proceedings and market checks shortly after the deadline.

In practical terms: build one technical foundation for all markets, document your accessibility, and keep an eye on your target markets. Whether you fall within the scope at all is something our free EAA check clarifies in a few minutes.

Conclusion

The EAA has turned a patchwork of national requirements into a common European foundation – even if the implementation comes as 27 laws with different fines and authorities. If you make your website or shop consistently accessible according to WCAG and EN 301 549, you are on the right track in every EU country. Waiting is not worth it: the obligations have applied since 28 June 2025, and the first supervisory authorities are already actively enforcing them.

Sources

• Directive (EU) 2019/882 (European Accessibility Act) – EUR-Lex
• European Accessibility Act – European Commission
• Barrierefreiheitsstärkungsgesetz (BFSG) – Gesetze im Internet (Germany)
• Barrierefreiheitsgesetz (BaFG) – Austrian Ministry of Social Affairs
• Décret n° 2023-931 – Légifrance (France)
• Ley 11/2023 – Boletín Oficial del Estado (Spain)
• Implementatiewet toegankelijkheidsvoorschriften – Eerste Kamer (Netherlands)
• Act of 26 April 2024 – ISAP (Polish Sejm)
• Lag (2023:254) – Swedish Riksdag
• Act No. 801 of 7 June 2022 – Retsinformation (Denmark)
• S.I. No. 636/2023 – Irish Statute Book
• New accessibility requirements – Traficom (Finland)
• Accessibility of products and services – INR, I.P. (Portugal)
• Accessibility of products and services – Czech Trade Inspection (ČOI)
• Accessibility of products and services (OSAPS) – Luxembourg
• Accessibility of services – TTJA (Estonia)
• Act No. 351/2022 – Slov-Lex (Slovakia)
• Act on accessibility requirements for products and services – Croatian Ministry of Labour and Social Policy
• Act XVII of 2022 – National Legislation Database (Hungary)
• Infringement procedure against Greece – AccessibleEU / European Commission