EAA Enforcement in 2025: What Has Actually Happened So Far?

On 28 June 2025, the European Accessibility Act became enforceable across all 27 EU member states. Within days, French disability advocacy organisations had issued formal legal notices to four major grocery retailers demanding their e-commerce platforms meet accessibility standards. That was the opening signal. Nine months later, enforcement authorities across Europe are actively investigating complaints, issuing warnings, and in several countries, imposing fines. If your SaaS product serves EU customers and you have not yet assessed your WCAG 2.1 AA compliance status, this post is your orientation. At Inity Agency, we have been tracking EAA developments closely, including for clients whose products operate in regulated European markets. Here is what has actually happened since June 2025, and what it means for your product.

What Is the EAA and Who Does It Cover?

The European Accessibility Act (Directive (EU) 2019/882) is EU legislation that requires digital products and services to be accessible to people with disabilities. It was adopted in 2019, transposed into national law across member states by June 2022, and became fully enforceable on 28 June 2025.

The EAA covers a broad scope of digital services including e-commerce platforms, banking and financial services, transportation ticketing, telecommunications, e-books, audiovisual media services, and, critically, SaaS platforms that serve EU consumers.

The EAA applies to your product if:

• You operate an e-commerce platform serving EU customers
• You provide a SaaS product used by businesses or consumers in the EU
• You offer banking, financial, or payment services to EU users
• You are headquartered outside the EU but sell to EU customers

This extraterritorial reach is significant. A US-based SaaS company with European customers is covered. A UK company post-Brexit that serves EU clients is covered. The question is not where you are registered, it is where your users are.

The technical standard:

The EAA references EN 301 549, the harmonised European ICT accessibility standard. EN 301 549 incorporates WCAG 2.1 Level AA as its web content baseline. In practical terms: achieving WCAG 2.1 AA compliance satisfies the core digital accessibility requirements of the EAA.

What Has Actually Happened Since June 2025?

The First Days: France Sets the Tone

Within days of the June 28 deadline, French disability advocacy organisations issued formal legal notices to four major grocery retailers citing inaccessible e-commerce platforms. This was not a government action, it was civil society moving immediately once the legal framework was in place. It established the pattern that would follow across Europe: enforcement does not wait for regulators to find violations. Users and advocacy groups file complaints, and regulators investigate.

Q3 2025: Regulators Activate

By July and August 2025, national market surveillance authorities across the EU had activated their monitoring frameworks. Germany’s Federal Network Agency, Italy’s AGID, and France’s enforcement bodies began structured monitoring of digital services. The approach was consistent across member states: first notification, then a remediation window, then escalation to fines if compliance is not achieved within the given timeframe.

Italy, which had been enforcing digital accessibility legislation since 2004 under the Stanca Law, was the most active early mover. AGID began investigations into digital services with penalties applicable up to €100,000 per violation.

Q4 2025: Northern Europe Engages

Sweden and Denmark made their first moves in October 2025. Sweden’s Post and Telecom Authority (PTS) began market surveillance of digital products. Denmark’s enforcement authority started contacting businesses directly about compliance status. Both countries follow the EU pattern of remediation before penalties, but both have built escalation mechanisms that include significant fines for continued non-compliance.

The Netherlands, with one of the most aggressive enforcement frameworks in the EU (up to €900,000 or 10% of annual revenue through the Authority for Consumers and Markets), had already begun its monitoring programme.

Into 2026: Activist Involvement Intensifies

Disability organisations across the EU are actively monitoring websites, mobile apps, and SaaS interfaces for accessibility barriers. A single complaint to a national enforcement authority triggers a formal investigation. Per-violation fines in several countries mean a product with multiple accessibility issues faces multiple simultaneous penalty proceedings.

What Fines Look Like by Country

The EAA does not set a single EU-wide penalty structure. Each member state sets its own fines. Here is the enforcement landscape as of early 2026:

Important context: Most authorities are starting with remediation notices, not immediate fines. The typical enforcement sequence is: complaint filed → investigation opened → notification issued → 30–90 day remediation window → fine if non-compliant after deadline. First-time violations that are fixed within the remediation window may avoid fines entirely. But a product with dozens of accessibility issues cannot be remediated in 30 days if no groundwork has been laid.

What the EAA Requires in Practice for SaaS Products

For a SaaS product serving EU users, EAA compliance in practice means:

1. WCAG 2.1 Level AA for all web content and interfaces

Every screen, modal, form, data table, and interactive element must meet WCAG 2.1 AA standards. This includes: sufficient colour contrast (4.5:1 for normal text), text alternatives for all non-text content, full keyboard navigability, screen reader compatibility, visible focus indicators, and logical heading structure.

2. Accessible onboarding and authentication flows

The signup flow, login, password reset, and MFA steps are the first experiences a user has with your product. These are also the most commonly flagged accessibility failures — forms without proper labels, CAPTCHA without accessible alternatives, error messages that do not identify the specific field.

3. Accessible mobile experience

If your product has a mobile app or responsive web interface, EN 301 549 includes additional criteria for mobile that go beyond standard WCAG.

4. Accessibility statement

Most member states require or strongly recommend a published accessibility statement on your website or product. This statement should document your compliance status, known limitations, and a contact mechanism for users to report issues. France imposes an additional annual penalty (€25,000) specifically for missing accessibility statements.

5. Ongoing monitoring

Compliance is not a one-time audit. As you ship new features, update content, and iterate on design, accessibility must be maintained. Automated scanning tools catch approximately 30–40% of WCAG violations; the remainder require manual testing, including testing with assistive technologies (screen readers, keyboard-only navigation).

The 3 Most Common Accessibility Failures in SaaS Products

Based on WCAG audit data and EAA enforcement guidance, these are the most frequently cited violations in SaaS interfaces:

1. Insufficient colour contrast – Text that does not meet the 4.5:1 contrast ratio against its background. Common in SaaS products that use light grey text on white backgrounds, or subtle state indicators in data tables.

2. Missing or incorrect form labels – Input fields that rely on placeholder text instead of persistent labels, or that use aria-label incorrectly. Particularly common in onboarding flows and filter panels.

3. Keyboard navigation failures – Interactive elements (dropdowns, modals, custom date pickers, drag-and-drop interfaces) that cannot be operated by keyboard alone. This is the most technically complex category and the one most commonly built without accessibility testing.

What Inity Builds Into Every Product

At Inity, accessibility is a design and development constraint, not a post-launch audit. Every product we design is built to WCAG 2.1 AA from the wireframe stage: colour systems are checked for contrast, interactive components are keyboard-navigable by specification, form labels are persistent and correctly associated, and focus management is designed into modal and drawer flows.

For existing products that need a compliance assessment, we conduct structured WCAG 2.1 AA audits covering automated scanning plus manual testing with keyboard and screen reader — producing a prioritised remediation backlog with clear technical specifications.

Conclusion

The EAA is not a future deadline. It is active law with active enforcement across 27 EU member states. Nine months in, the pattern is clear: regulatory authorities are monitoring, disability organisations are filing complaints, and the remediation window before fines is short. For SaaS founders serving European markets, the question is no longer whether accessibility compliance matters — it is whether your product is ready before you receive a notification. Building to WCAG 2.1 AA is not a regulatory checkbox. It is the design standard for products that work for all users, including the 87 million Europeans with disabilities who now have legal grounds to demand it.

Not sure where your product stands on EAA compliance? Inity conducts WCAG 2.1 AA audits and can rebuild non-compliant interfaces to standard. Book a call to find out what your exposure looks like.