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The European Accessibility Act, country by country

Updated 2 July 2026 7 min read Legal sources cited

In short

The European Accessibility Act (EAA) is a single EU directive — Directive (EU) 2019/882 — but it has no direct effect: each country transposed it into its own national law, with its own supervising authority and its own scale of fines. What to remember:

  • the technical baseline is the same everywhere: the EN 301 549 standard, which incorporates WCAG 2.1 level AA;
  • the obligation has applied since 28 June 2025 in most Member States;
  • what changes from one country to the next: the name of the law, the regulator that enforces it and the maximum fine (from €40,000 in Italy to €1M in Spain);
  • what triggers the obligation is the market you sell into, not where your company is based: if you sell in several countries, you accumulate the corresponding regimes.

You sell online in several European countries and you're wondering "which accessibility law applies to me"? There isn't one — there are as many as the markets you serve. This page compares the national regimes and, for each country, points you to the detailed guide for that market.

Choose your market

Each card sums up the transposing law, the supervising authority and the maximum fine for that country, then links to the full guide — in English where we have one, otherwise in the market's own language.

The common ground: a single technical baseline

Despite eight different laws, the technical target does not change from one country to another. Everywhere in the Union, a web service is presumed compliant when it meets the European harmonised standards; for a website, the relevant standard is EN 301 549, which incorporates WCAG 2.1 level AA. In other words: an online store built to WCAG 2.1 AA satisfies the core of the requirements in all of these countries at once. What remains country-specific is mainly the legal document (the accessibility information or statement, in the right language) and knowing the local regulator in case of a complaint.

Same standard, different fines

The technical bar is identical across the EU, but the financial risk is not. Here is the maximum-fine comparison for the markets we cover — figures taken as they stand from each country's transposing law.

National maximum fines under each transposing law. Figures are ceilings and depend on the assessment of the relevant regulator.
CountryLawMaximum fine
ItalyD.Lgs. 82/2022 (art. 24)€5,000–€40,000
FranceOrdonnance 2023-859€50,000
BelgiumCode of Economic Law (2023)€80,000–€200,000
GermanyBFSG (§ 37)€100,000
NetherlandsImplementatiewet€900,000
SpainLey 11/2023€1,000,000
SwedenLag 2023:254up to SEK 10M

What really changes from one country to another

  • The size of the fine. The ceiling runs from €40,000 in Italy to €1M in Spain — without the technical requirement changing at all. The financial risk therefore depends on the market, not just on your website.
  • The form of the law. Some countries passed a dedicated act (BFSG in Germany, Lag 2023:254 in Sweden); others grafted the obligation onto existing texts (Belgium into the Code of Economic Law, the Netherlands onto the Commodities Act and civil law). That's why "finding the accessibility law" is harder in those countries.
  • The supervising authority. DGCCRF/ARCOM in France, the Economic Inspection in Belgium, ACM in the Netherlands, PTS in Sweden: the body handling a complaint differs each time.
  • The language of the mandatory document. The accessibility information must be published in the market's language (French, Dutch, German, Italian, Spanish, Swedish…).
Selling in several countries? You don't pick "one" regime: you accumulate those of the markets you target. The good news is that the technical work is shared (a single WCAG 2.1 AA effort covers every country); what's left is mostly documentary — one accessibility statement per market language.

Check your exposure in 2 minutes

DeclareAccess scans a page of your site (WCAG 2.1 AA), sends you a scored report of the non-conformities, then generates the accessibility document ready to publish to your target country's template — France (RGAA), Belgium (FR/NL information), Germany (BFSG), Italy (Allegato IV), Spain (art. 13) or the Netherlands. Free audit, no credit card.

WCAG report by email within 1 business day.

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Frequently asked questions

Is there a single "EAA law" that applies across all of Europe?

No. The European Accessibility Act is an EU directive (2019/882) with no direct effect: each Member State had to transpose it into its own national law, with its own supervising authority and its own scale of penalties. The technical baseline (EN 301 549 / WCAG 2.1 AA), on the other hand, is identical everywhere.

I sell in several EU countries: which regimes apply?

All those of the markets you target. What triggers the obligation is the market you sell into, not where your company is based. A French store that also sells in Belgium, Germany and Spain falls under the four national regimes for those markets. The good news is that the WCAG 2.1 AA technical work is shared; it's mainly the legal document that has to be produced per country and per language.

Why are the fine amounts so different from one country to another?

Because each country set its own scale when transposing the directive. The ceiling runs from about €40,000 in Italy to €1M in Spain (and percentages of turnover in some regimes), while the technical requirement itself does not change. The financial risk therefore depends as much on the target market as on the state of your site.

Which language should I publish my accessibility statement in?

In the language of the target market: French in France, French or Dutch in Belgium, German in Germany, Italian in Italy, Spanish in Spain, Dutch in the Netherlands, Swedish in Sweden. If you sell in several countries, plan for one version per market language. Each country's guide sets out the template and the expected content.

Read next

France E-commerce Accessibility Barometer 2026: 92% of stores fail (original data, 144 sites) European Accessibility Act for e-commerce: the 2025 compliance guide Does the EAA apply to my online store? EAA compliance checklist for e-commerce: the 24 points EAA compliance test: is your online store accessible? (2 min) Accessibility statement: the mandatory content and a template EAA Belgium: the Belgian accessibility law EAA Netherlands: the Dutch accessibility rules (ACM oversight) EAA Spain (Ley 11/2023): the Spanish accessibility law EAA Italy (D.Lgs. 82/2022): the Italian accessibility law 🇫🇷 En français : l'EAA pays par pays DeclareAccess — free audit + legal accessibility statement