EU Accessibility Act (EAA): Developments in EU Countries

The European Accessibility Act (EAA) will officially come into effect on June 28, 2025. Recently, more and more local companies have begun to closely monitor the impact of the Act on the EU market and actively take corresponding measures. Currently, there are only a few months left until the implementation of the bill. How is the progress of each country in translating the bill into its own laws? How should overseas enterprises plan in advance to smoothly pass compliance requirements?

Only a few countries have not yet translated EAA into their own laws

The EU's regulatory mechanism for implementing the European Accessibility Act in various countries is a comprehensive framework aimed at ensuring effective implementation of accessibility requirements by member states.

For example, countries such as Denmark and Estonia failed to fully translate the European Accessibility Act into their own laws by the deadline of June 28, 2022. Therefore, the European Commission has issued formal notices to these countries, requiring them to rectify within two months, otherwise further measures may be taken.

Germany has issued the BFSG Act on July 22, 2021, which converts EAA into domestic law and requires products to have technical documents, conformity assessment procedures, conformity declarations, and CE marks.

*The CE mark is an abbreviation for Conformit é Europ é enne, meaning European conformity. It is a self declaration mark completed by the manufacturer or its authorized representative and affixed to the product or its packaging, indicating that the product complies with all relevant EU regulations and safety standards.

Italy implemented EAA through Legislative Decree No. 82/2022 on May 27, 2022, which requires manufacturers to ensure that product design and manufacturing comply with accessibility requirements, and distributors to verify whether products have the CE mark, accompanied by required documents and Italian or English versions of instructions and safety information.

France has transformed EAA into law on March 9, 2023, and the Audiovisual and Digital Communications Regulatory Authority (ARCOM) is responsible for clarifying the terms and has the authority to investigate violations.

Ireland has also translated EAA into domestic law on December 15, 2023, known as the "EU (Accessibility Requirements for Products and Services) Regulation 2023". The regulation designates the Competition and Consumer Protection Commission (CCPC) as the market regulatory authority responsible for enforcing compliance.

As of today, only two EU countries have not yet translated the European Accessibility Act into their own laws, including Bulgaria and Cyprus.

The EU ensures effective implementation of accessibility requirements by member states through a regulatory mechanism

In addition, the EU requires member states to conduct regular compliance checks, review and follow up on complaints about accessibility, ensure that companies take necessary corrective measures, and clearly inform the public on how to file complaints with authoritative institutions to ensure compliance with accessibility requirements, while monitoring the translation of the European Accessibility Act into national law.

Various countries have introduced punishment mechanisms of varying degrees

In order to strengthen the enforcement of regulations, countries have implemented a series of penalty measures for non-compliance in the process of translating the European Accessibility Act into their own laws. The fine is only a preliminary punishment, and continued non-compliance may lead to more severe legal consequences, including mandatory corrective measures, public exposure, and business suspension, which will have a serious impact on the company's profits and image. The following are punishment measures introduced by some countries:

Germany: Fines for non-compliance can reach up to 500000 euros, making it one of the countries with the highest penalty thresholds. Companies that fail to meet accessibility standards may also face service suspensions.

France: Non compliant companies may be fined between 5000 and 250000 euros. In addition, the French authorities reserve the right to publicly expose companies that do not comply with accessibility standards, which may seriously damage the company's brand reputation.

Spain: Fines range from 5000 euros to an astonishing 300000 euros. In addition to financial penalties, the company may need to take corrective measures and face the risk of public exposure.

Italy: Penalties for non compliant organizations may reach up to 5% of turnover or fines ranging from 5000 to 40000 euros.

Finland: Fines may reach up to 150000 euros, and companies may also be required to undergo mandatory accessibility audits.

Belgium: Fines range from 1000 to 50000 euros, and continued non-compliance may result in business suspension.

Sweden: Fines can reach up to 200000 euros, and corrective measures may need to be taken if necessary.

Ireland: Serious non-compliance can result in fines of up to 60000 euros and/or imprisonment for up to 18 months