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What the Act actually covers
The EAA (Directive (EU) 2019/882) sets accessibility requirements for a defined list of products and services: consumer banking, e-commerce, e-books, transport ticketing and information, telecoms, and the self-service terminals people use for all of them — ATMs, ticket machines, check-in kiosks, payment terminals. It applies to any organisation selling those services to EU consumers, wherever it’s headquartered.
It is not a building code. But two things pull the built environment into scope. First, Annex III lets member states apply the Act’s requirements to the physical environment where a service is delivered — the branch, the store, the station. Several have. Second, and more importantly, the Act is enforced through the same question every accessibility regime eventually asks: can you show what you knew, and what you did?
Has anyone been fined under the EAA yet?
Not yet. What actually happened in the first twelve months looks like this:
- France moved first. The DGCCRF issued formal notices to major retailers — Auchan, Carrefour, Leclerc and Picard among them — and in June 2026 a Paris court ordered Carrefour to bring its services into full accessibility within six months, with daily penalties for every day of delay.
- Sweden’s regulator, PTS, launched a surveillance programme auditing around 200 platforms against the Act.
- The Netherlands’ ACM published its audit prioritisation — a public statement of who it intends to look at first.
- Germany saw the private route open up: Abmahnungen (formal cease-and-desist letters) from competitors and associations, which don’t need a regulator at all.
Notice the pattern. None of these is a fine. Every one of them is a record — a dated, documented moment when an organisation was told what it knew. From that point on, “we weren’t aware” is no longer available as a defence.