The European Accessibility Act deadline has passed — what happens now

The deadline has passed

28 June 2025 came and went. If your business serves EU consumers online, the European Accessibility Act (EAA) has applied to you since that date — whether or not you've done anything about it.

Nothing changed in your code that day. What changed is that a missing accessibility statement, an inaccessible checkout, or a WCAG failure stopped being a design nice-to-have and became a live obligation you can be asked to document.

What's actually happening, country by country

It's worth being precise here, because a lot of vendors reach straight for fear. Here's what's verifiably true as of mid-2026:

France — On 12 November 2025, emergency injunctions were filed in commercial court against Auchan, Carrefour, E.Leclerc, and Picard. The targets: inaccessible checkout flows, product browsing, and — notably — missing accessibility statements. If you sell online in France, that last one is worth checking today.

Netherlands — The ACM (the regulator covering e-commerce and telecom; the AFM covers financial services) set 15 October 2025 as a non-conformance reporting deadline. Companies that missed it are now on the priority list for audits starting spring 2026.

Italy — AgID, Italy's digital agency, published a new enforcement regulation on 16 May 2026, and its Director General called 2026 "the year of enforcement." Businesses found non-conformant get 90 days to remediate before a financial penalty applies. Private entities with average turnover above €500m have an annual declaration due every 23 September.

Germany — Enforcement activity is confirmed underway and ramping through 2026.

What hasn't happened yet

To be direct about it: no confirmed monetary fine has been issued under any EAA-transposed national law as of mid-2026. Year one has been formal notices, injunctions, monitoring programmes, and warning letters — not fines yet. That matters, because the actual obligation right now isn't "avoid a fine," it's "have the paperwork a regulator can ask you for."

What that paperwork actually is

Three things:

1. An accessibility statement — published, describing your conformance status and how users report problems.
2. A report — evidence you actually tested against WCAG 2.1 AA / EN 301 549, not just a claim.
3. A reassessment schedule — Article 14 requires this to be reassessed at least every 5 years, or whenever your service changes materially, whichever comes first.

If you don't have all three, that's not a hypothetical gap — it's exactly what France, the Netherlands, and Italy are now actively checking for.

Check if your site has a statement, in under a minute →