EAA & ADA Hub
EAA fines by country
Reported penalty ranges for non-compliance with the European Accessibility Act, and why the 'per product' basis matters for apps.
Updated 20 July 2026 · Technical readiness assessment — not legal advice.
The European Accessibility Act (EAA) has applied since June 2025. It is a directive, so each EU member state sets its own penalties in national law — which means there is no single "EAA fine". The figures below are reported ranges to give a sense of scale; they are not a substitute for advice from counsel in the relevant jurisdiction.
Reported penalty ranges
| Member state | Reported maximum | Basis |
|---|---|---|
| Germany | up to €100,000 | per non-compliant product |
| France | up to €50,000 | plus additional obligations / repeat penalties |
| Italy | up to 5% of turnover | proportionate to revenue |
Reported figures, subject to change and to national implementation. Confirm the current position with local counsel.
Why "per product" changes the math
A penalty assessed per product does not stop at one number. An organization shipping several apps, or several regional variants, can be exposed on each. That is why a reproducible, per-app assessment — one you can show for each product — is worth more than a single blanket statement.
Who is in scope
None of the figures above mean anything until scope is settled, and scope is narrower than the headlines suggest. Article 2(2) of the Act is a list, not a catch-all: electronic communications, access to audiovisual media, passenger transport, consumer banking, e-books and dedicated software, and e-commerce — plus answering emergency communications to 112 under Article 2(3). An app outside that list is outside the Act's service scope whatever its size. The list is broader than it first reads, though: an app a consumer can buy something in is an e-commerce service.
Two further facts narrow it again. A micro-enterprise — fewer than 10 people, and turnover or balance sheet total at or under €2M — that provides a service is exempt under Article 4(5); the exemption does not extend to a micro-enterprise placing a physical product on the market. And what does not narrow it is where you are: the Act follows the service to the consumer, so a company outside the EU serving EU consumers in a listed sector is in scope.
Four questions that tell you which of these you are →
What reduces exposure
Documentation. If a dispute arises, the useful artifact is evidence: what was tested, when, against which standard, and what was found. An audit that hands back the value measured, the value required, the criterion it maps to, and an explicit count of the checks it could not run is exactly that kind of artifact — which is what ReadyAudit is built to produce.
None of this is how the United States works. There is no US penalty schedule for an inaccessible app, because there is no US regulation for a private one — the exposure there is litigation, and the numbers usually quoted about it are counting websites. What the US filings actually claim →
This is not legal advice. It is a technical readiness perspective. For obligations and penalties specific to your situation, consult a qualified lawyer.