EAA enforcement so far: what has actually happened

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The European Accessibility Act (EAA) became applicable on 28 June 2025. Since then, a lot of marketing has leaned on big scary numbers — six-figure fines, criminal liability — to sell accessibility services. This post does the opposite: it sets out, honestly, what EAA enforcement has actually looked like so far, so you can make a calm decision rather than a panicked one.

No EAA fine has been publicly reported yet

As things stand, there is no publicly reported case of a business being fined under the EAA anywhere in the EU. The headline penalty figures you see quoted — up to €100,000 in Germany, up to €60,000 plus possible imprisonment in Ireland, up to €40,000 or 5% of turnover in Italy — are statutory maximums written into national law. They are ceilings for the most serious cases, not amounts that have been handed to merchants.

Enforcement is national and complaints-driven

Because the EAA is a directive, each member state enforces its own transposed version, usually through a market-surveillance authority. In practice that means enforcement tends to start with a complaint — from a consumer, a disability organisation, or a competitor — rather than proactive sweeps. It is early, it is uneven across the 27 states, and it is still finding its feet.

So what is the real near-term risk?

For a Shopify merchant, the realistic near-term risk is not a surprise penalty. It is a complaint or a demand letter you have to answer — and, if you also sell to US customers, the far more active ADA demand-letter climate, where 5,114 US digital-accessibility lawsuits were filed in 2025 (UsableNet) and eCommerce was roughly 70% of them. In both cases, what determines how badly it goes is whether you can show, in writing, that you found your barriers, fixed what could be fixed, and documented the rest.

What this means you should actually do

• Don't panic-buy an overlay widget — overlay users are still sued, and it fixes nothing in your code.
• Scan your store against WCAG 2.2 AA so you know your real exposure.
• Fix what can be fixed at the source, and flag honestly what still needs a person.
• Publish an accessibility statement and keep a dated evidence pack, so a complaint meets a documented answer, not a blank page.

Early enforcement is a window, not a reprieve. The merchants who use it to get documented and defensible are the ones who won't be scrambling when the first letter arrives. That is exactly what StoreProof is built to do — honestly, without promising a compliance guarantee no one can keep. This is general information, not legal advice.

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