What you actually risk if your site is not accessible

Published 19 September 2026 · 9 min read

If you have searched for «web accessibility fines» you will have found figures up to a million euros, country-by-country sanction lists and sites claiming they are already being issued. Here is something almost no accessibility vendor will tell you: fifteen months after the European Accessibility Act became enforceable, there is not a single final fine anywhere in the European Union. Not in Spain, not in Germany, not in France.

That is not an opinion. It is the result of searching, case by case and in five languages, for a file with an identifiable company, authority and amount. None comes up.

So why are we telling you this, when we sell audits? Because the real risk does exist, and it is more uncomfortable than a fine. It is just not the one being sold to you.

What has happened: a court has ruled against Carrefour

On 4 June 2026 the Judicial Court of Caen ordered Carrefour France to make its website and mobile app fully accessible within six months, under a daily penalty payment.

The ruling matters less than the argument the court rejected. Carrefour claimed it was 71 % compliant. The court replied that accessibility is an obligation of result, not of means: trying is not enough.

That changes the maths for anyone who installed a widget, made «some improvements» or commissioned a report that then sat in a drawer. 71 % does not protect you. And the claimants were not the State: they were two associations, apiDV and Droit Pluriel, which already have cases filed against other chains.

In Germany the risk is called Abmahnung, and it has a price

In Germany the fast lane is not the administration but unfair-competition law. A competitor or an association can send you a formal warning — an Abmahnung — for breaching the BFSG, and you pay their legal costs even without a trial.

There is a documented case from February 2026: €2,706.18 in fees and technical analysis of the site. The first waves in 2025 were around €600. It is not a fine: it is worse, because it arrives without notice and it is sent by whoever competes with you.

Regulators are already looking, and they publish what they see

• Sweden. The PTS authority has 28 online shops under inspection, named: Ikea, H&M, Coop, ICA, Systembolaget, Boozt. Eleven were added on 3 March 2026. No fines, but a public list. —
• Netherlands. The ACM reviewed 63 online shops. Only one fully complied. Keyboard navigation was implemented in 13 % and screen-reader compatibility in 11 %. —
• France. On 6 July 2026 Arcom formally notified the Ministry of Finance itself over impots.gouv.fr. If the State is not spared, your shop will not be either. —
• Spain. Royal Decree 143/2026 of 25 February created the technical unit coordinating the surveillance authorities. No new sanctioning regime; for the first time, machinery to supervise. —
• Germany. The MLBF, created by the sixteen Länder, already operates with automated checks and priority handling of complaints. —

The pattern repeats everywhere: before sanctioning they require, before requiring they inspect, and they publish who is on the list. Reputational damage arrives long before any fine.

What it can cost, when it comes

These are legal ceilings, not typical amounts, and none has yet been applied under the EAA.

What does not protect you

An accessibility widget. In April 2025 the US FTC made accessiBe pay one million dollars for claiming its widget made a site compliant without evidence. In August 2026, 134 of the 432 new US accessibility lawsuits targeted sites that had a widget installed. The German surveillance authority puts it in writing: an inaccessible site does not become accessible by adding an overlay tool.

An «official certificate». It does not exist. Services carry no CE marking, there is no notified body, and the W3C states literally that it does not verify any conformance claim. Anyone selling you an official EAA certificate is selling something that cannot exist. What does exist — and what the law requires you to have — is a truthful, dated accessibility statement with a defined scope, and a report behind it.

What to do with this

We are not going to tell you that you will be fined tomorrow. It is not true and we will not say it. What is true:

• If you sell in France, you can already be sued, and claimants have already won.
• If you sell in Germany, a competitor can invoice you €2,700 by letter.
• If you sell in Sweden or the Netherlands, the regulator already has your sector on a public list.
• 71 % does not count. Nor does the widget. Nor the certificate nobody can issue.

What counts is knowing exactly what fails on your site, fixing it, and holding the document that proves it, with a date and a scope. For context: 95.9 % of the top million home pages have detectable failures, averaging 56 errors per page. Almost nobody complies; the difference is knowing it and being able to show you are fixing it.

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