EAA monitoring: the story so far

Six months on from the June 2025 implementation deadline of the European Accessibility Act (EAA), we outline the experiences so far of how the Act is being monitored, and share expert advice from enforcers about what you might still need to do.

What does the data reveal?

Following our dedicated research into EAA preparations in April, which found that only 11% of organisations felt confident they would be ready for the June deadline, the EAA-related findings from our 2025 Attitudes to Digital Accessibility survey revealed that 45% of organisations report that ‘nothing has changed since the EAA took effect.

With this in mind, we look at how different EU member countries are approaching enforcement of the EAA directive so far, and how you can ensure you are putting in place measures to address your responsibilities.

What are the initial enforcement cases in member states?

Reports from the Nordic Accessibility Community Group, which has been logging developments in the EU about EAA conformance monitoring, notes the latest information about current enforcement:

• France: Following a public call for testimonies, four leading supermarket chains were flagged for failing to meet digital accessibility standards in July 2025. Issues cited included incompatibility with screen readers, poor keyboard navigation and inaccessible "click & collect" options. ApiDV and Droit Pluriel - two prominent disability rights organisations representing people with visual impairments - issued formal legal notices. These actions were reinforced by Intérêt à Agir, a legal collective committed to protecting public interest and fundamental rights.
• Denmark: Authorities in Denmark began in mid-2025 to notify at least one major online retailer of accessibility issues on their website, framed as a warning rather than formal enforcement. No fines or other measures have been reported so far.
• Sweden: The post and telecommunication agency (PTS) has started examining laptops, smartphones and tablets from well known brands to ensure that there is an EU declaration of conformity for the product as well as reviewing the accessibility of product information when that information is available digitally. PTS is also starting to examine websites of large e-commerce companies active in Sweden. They appear to be assessing the accessibility of the homepages, product pages and Search functionality of these websites.
• The Netherlands: The Consumer and Market Authority (ACM) is taking a very proactive approach to warn businesses that they are in its line of sight. It has sent letters to companies around the globe that have e-commerce services in The Netherlands. It has started monitoring those who were unresponsive. Enforcement is expected to start in mid 2026.

What advice do EU enforcement leads have?

Speaking at this year's AbilityNet TechShare Pro conference in London, Hanneke van Rooijen, Senior Enforcement Official at the department for consumer protection at the Netherlands Authority for Consumers and Markets (ACM) outlined how the Netherlands is tackling enforcement of the EAA directive with a firm but understanding approach:

"Our general impression so far is that changes are indeed being made. There is movement, for example, we see a lot of improvements on the keyboard accessibility of cookie banners and adding of skip links... But there is a very big gap between the status of the industry and compliance with the EAA. And indeed it will be a process, we understand that. So we take that into account in our approach."

Hanneke is leading the multidisciplinary team that is responsible for the supervision on companies that have to be compliant with the EAA. The ACM is the Dutch enforcement agency on the accessibility of e-commerce services and electronic communication services. Hanneke shared how how the Netherlands' monitoring body is highlighting the commercial benefits as a motivating factor to businesses: 

"We will in our approach urge and try to motivate businesses as much as possible to make the necessary changes and recognise how important accessibility is and also the chances it brings in terms of inclusion, but also commercially."

How have businesses been made aware of what they need to do?

"What we have done also is send letters to selection of businesses... a call to action. What we have done in the letter is brought the EAA under the attention of the companies and we ask them to make sure to comply or else notify the ACM when they are not complying. There's also an obligation in the EAA to do that," Hanneke continued.

"And with the notification, the businesses are able to add a detailed plan or add a plan as detailed as possible to gain insight, give us insight about what they are actually doing and the measures they have taken or will be taken in the future to be compliant with the EAA.

We have looked at how important the businesses are for to a large number of consumers and we also act on complaints of consumers."

What advice do enforcement bodies suggest?

Hanneke was part of a panel at the London conference which included Lui Asquith, Associate Solicitor from Russell-Cooke; Abi James, Senior Digital Accessibility Consultant at Barclays; Susanna Laurin, Managing Director and Chair of the Funka Foundation and Representative to the EU at IAAP and G3ict; and Malin Rygg, head of the Norwegian Authority for Universal Design of ICT.

Malin provided her insights into how organisations can become more compliant with the EAA:

"I think my best advice to all businesses will be to just start, although you might not have everything in control yet." 

She also noted that interested organisations can "contact us as an authority. We have had very good experiences in Norway with that. When you get started and you start doing things and it gets difficult, ask because the dialogue is very important. We learn from it, you learn from it, and we can move forward together."

Lui Asquith (pictured), of Russell Cooke Solicitors (AbilityNet's EAA Compliance Service partners), highlighted that honesty is likely to be the best solution:

"Regulators ask for and expect a transparent approach and often, even if you're not doing anything, if you're upfront about it, you can put yourself in a far better position than if you were quiet hiding away and then you're found out." 

Susanna Laurin highlighted a set of resources about the European Accessibility Act on LinkedIn.

What should you do now?

Alice Taylor, Principal Digital Accessibility consultant at AbilityNet (pictured) is leading our work on the EAA.

She mirrors advice shared by Lui at the TechShare Pro panel discussion and notes that evidencing the steps you have taken towards EAA compliance may make a difference in the severity of enforcement penalties. 

"The goal is to move from reactive fixes to a sustainable strategy. By auditing your current state and empowering your teams now, you ensure that EAA compliance becomes a seamless part of business as usual," says Alice.

Some core first steps you should be taking towards compliance:

1. Provide documentation of your compliance activity to outline what actions you have taken, and will take, to address the EAA directive.
2. Conduct an accessibility audit to identify issues you need to address
3. Seek advice from accessibility experts - AbilityNet can help you build a long-term strategy to maintain compliance and accessibility best practices.
4. Communicate with your teams and provide training where needed to ensure standards are upheld and that staff understand their role in maintaining compliance.
    

EAA Further resources:

What should we expect in the future for enforcement?

AbilityNet’s Head of Consultancy, Will Sutton (pictured), suggests:

"We recognise that navigating a multi-market landscape with differing national requirements is incredibly complex. While AbilityNet is here to help organisations untangle those regional nuances, do not let the complexity of the macro view delay your immediate action.

The universal signal from market authorities is that they value proactivity over immediate perfection. The businesses most at risk of severe penalties, like personal liability or product withdrawal, are not those working through a roadmap, but those ignoring the issue entirely.

Silence is the biggest risk. Advocacy groups and regulators will target those who are standing still. Developing a roadmap and showing genuine momentum is the best way to start mitigating the risk. In this new regulatory era, doing nothing is the only wrong move, it leaves your business exposed and disabled users behind.”

Ask about AbilityNet's EAA Compliance Support Service