More than a year has passed since European Accessibility Act enforcement began on June 28, 2025, which is enough time to start asking what’s actually happened since, rather than just what the law says on paper. The short version: the legal machinery is in place and penalties are defined, but the early evidence on actual compliance suggests a large gap between the law taking effect and businesses catching up to it.
The enforcement timeline, restated plainly
The EAA’s core enforcement date, June 28, 2025, applies to new products and services. It’s not a single hard cutoff for everyone, though. Contracts for services signed before that date have until June 28, 2027 to come into compliance, and certain products already in service get until June 28, 2030, according to Level Access’s EAA compliance overview. That staggered structure means a business can be in a legally compliant transition period today and still need a plan for a hard deadline that’s coming regardless.
Penalties are set nationally, not centrally
One detail that surprises a lot of businesses operating across the EU: the European Accessibility Act is a directive, not a regulation, which means each member state transposes it into its own national law and sets its own enforcement mechanism and penalty structure. That’s why the fines aren’t a single EU-wide number. Maximum penalties member states have set range from roughly 60,000 euros to around 900,000 euros, alongside possible product withdrawal and market bans, per the same Level Access overview. A business selling into several EU countries can, in practice, face meaningfully different maximum exposure depending on which country’s authority takes action.
What compliance is actually measured against
Enforcement only matters if there’s a clear technical bar to measure against, and the EAA has one: EN 301 549 v3.2.1, the harmonized European accessibility standard, fully incorporates WCAG 2.1 AA. Conforming to EN 301 549 creates a presumption of EAA compliance, which is a genuinely useful anchor point for any business trying to map a single accessibility effort to several countries’ legal requirements at once, rather than treating each market as a separate project.
Who actually enforces it
Because the EAA is transposed into national law rather than enforced centrally from Brussels, each member state designates its own market surveillance authority responsible for checking compliance and acting on complaints. That means the practical experience of enforcement, how proactive an authority is about auditing sites versus only responding to complaints, how quickly a case moves, and what documentation a business needs to demonstrate a good-faith effort, varies from country to country even though the underlying legal obligation is the same EU directive. A business operating in several EU markets is effectively dealing with several separate enforcement regimes layered on top of one shared technical standard.
Early evidence of a gap between law and practice
The clearest available signal on how compliance is actually going, rather than how the law reads, comes from a Wawsome market scan of Romanian company websites: roughly nine in ten of the sites analyzed still failed basic accessibility checks a year after EAA enforcement began, according to reporting on the scan by RomaniaTV. That’s one country and one scan, not an EU-wide census, so it shouldn’t be read as a precise figure for every member state. But it lines up with a pattern that shows up in accessibility data generally: legal deadlines tend to move faster than the underlying remediation work, and a law taking effect doesn’t automatically translate into websites getting fixed on the same timeline.
What this means for businesses still catching up
If your business falls under EAA scope and hasn’t done a conformance check against EN 301 549 yet, the transition periods running through 2027 and 2030 buy time for existing contracts and products, not a reason to wait until a deadline is imminent to start. Given how widely fine structures vary by country and how much remediation work tends to take once you actually start testing, closer to now than to a deadline is the more defensible place to begin. Businesses selling primarily into markets like Romania, where Wawsome’s data suggests a particularly wide compliance gap right now, have a genuine first-mover advantage available simply by being ahead of where most competitors currently are.
The staggered deadlines running through 2027 and 2030 are also worth treating as a planning tool rather than a reason to relax. A contract signed today for a new product or service falls under the June 2025 enforcement date immediately, with no grace period, while only existing contracts and products already in service benefit from the later dates. Sorting out which category a given product or service actually falls into, before assuming a later deadline applies, is one of the more common and avoidable mistakes businesses make when reading the EAA’s transition rules.