EAA Penalties and Enforcement: What Ecommerce Stores Risk in 2025

EAA enforcement began on June 28, 2025. Unlike some EU regulatory frameworks that take years to move from paper to practice, member states had been building enforcement infrastructure since the Directive was adopted in 2019 and were required to transpose it into national law by June 28, 2022. The three-year implementation window meant that national authorities were ready to act from day one of enforcement — not just on paper, but with complaint mechanisms already operational and audit teams already trained.

What penalties does the EAA allow?

Directive 2019/882, Articles 30 and 31, sets the enforcement framework: member states must establish penalties that are effective, proportionate, and dissuasive. Crucially, the Directive does not cap penalty amounts — it leaves that to each member state. As a result, penalty levels vary significantly across the EU:

• France: The DNUM (Direction du numérique) can impose fines of up to €25,000 per violation for digital accessibility failures. Persistent non-compliance after a formal warning can attract repeat fines applied on a per-month basis.
• Germany: Under the German transposition of the EAA, fines reach up to €100,000 for systematic violations — defined as failures affecting multiple access points simultaneously (inaccessible checkout, account management, and product browsing all failing at once).
• Netherlands: The ACM (Authority for Consumers and Markets) applies fines of up to €25,000 per violation for persistent non-compliance after a remediation period has been granted and ignored.
• Denmark: The Agency for Digital Government operates a complaint-resolution model first, escalating to fines when complaints are unresolved. The Danish transposition sets per-violation fines that increase with the number of affected users.

Beyond direct fines, the EAA gives national authorities the power to order services to be withdrawn or suspended. An ecommerce store that remains persistently non-compliant could be required to cease operating in a given member state.

Which member states are most active in EAA enforcement?

Not all member states enforce with equal intensity. Based on published enforcement activity and the scale of their pre-existing digital accessibility programmes, the most active markets are:

• France: DNUM has an established digital accessibility audit programme (RGAA, the French national accessibility standard based on WCAG, predates the EAA). France was among the first member states to begin formal EAA audits of private ecommerce services.
• Germany: The BFIT (Federal Competence Centre for Accessible IT) and multiple Länder-level consumer protection offices run coordinated sweep programmes. Germany's consumer protection culture — including the private Abmahnung cease-and-desist system — creates dual-track enforcement risk from both public authorities and private competitors.
• Netherlands: The ACM is one of the EU's most technically sophisticated regulators, using automated scanning tools to identify high-volume violators before issuing formal complaints.
• Denmark: The Agency for Digital Government has a strong track record on public sector accessibility and has extended its audit methodology to private sector ecommerce services.

What triggers an EAA investigation?

Understanding how investigations start is as important as understanding the penalties. EAA investigations are triggered by three main routes:

1. Consumer complaints: Disabled users who encounter inaccessible checkout flows, unreadable product information, or keyboard-inaccessible navigation can file complaints directly with national enforcement bodies. Most member states have built consumer-facing complaint portals as part of their EAA transposition.
2. Competitor complaints: EU law allows businesses to report competitors for regulatory violations. In markets where accessibility is already a competitive signal, some businesses have begun using EAA complaints as a tool against non-compliant competitors.
3. Proactive sweeps: National authorities run automated sweeps of high-traffic ecommerce sites, typically using tools like axe-core or similar WCAG checkers to identify obvious violations at scale before deciding which stores to investigate further.

The three most common EAA violations in ecommerce

Across published enforcement guidance and accessibility audit data, three violation types dominate EAA findings for ecommerce stores:

1. Images without alt text: Product images without descriptive alternative text are invisible to screen reader users. This is the easiest violation to detect automatically — and one of the most widespread. Many stores have alt text policies that break down when product images are uploaded without alt text being added.
2. Form inputs without labels: Checkout forms are the most business-critical part of an ecommerce store and also the most commonly inaccessible. Input fields for name, address, card details, and delivery options frequently lack properly associated <label> elements, making them unusable with screen readers.
3. Colour contrast failures: Text that does not meet the WCAG 2.1 AA minimum contrast ratio of 4.5:1 for normal text or 3:1 for large text is a Level AA failure. Price display, call-to-action buttons, and form hint text are the most common failure points in ecommerce themes.

How to prepare your store now

WCAG 2.1 Level AA is the compliance baseline the EAA requires. The practical preparation sequence for most ecommerce stores is:

• Run automated checks first: Automated tools (axe, WAVE, Lighthouse accessibility audit) reliably find approximately 30 to 40 percent of WCAG issues. This is the fastest way to identify obvious violations and prioritise your remediation effort.
• Prioritise the checkout flow: The checkout is both the highest-revenue path and the most likely target of enforcement, since accessibility barriers at checkout directly prevent disabled users from completing purchases.
• Fix alt text at scale: Audit your product catalogue for missing alt text. Most ecommerce platforms allow bulk alt text updates via their API or admin export and import tools.
• Test keyboard navigation: Tab through your entire store using only a keyboard. Every interactive element — navigation menus, product filters, cart, checkout — must be reachable and operable without a mouse.
• Document your efforts: Maintain an accessibility statement on your store (required by the EAA) describing your current compliance status, known issues, and your remediation plan.

EuroGPSR runs more than 20 EAA accessibility checks across your store automatically — covering alt text, form labels, colour contrast, keyboard navigation signals, and more. Run a free scan to get a scored accessibility report and a concrete list of what needs fixing before enforcement authorities find it first.