European Accessibility Act: What’s Next in 2026

European Accessibility Act: What Early Enforcement Tells Us About 2026

As 2025 draws to a close, the European Accessibility Act (EAA) has been enforceable for just over six months. Since 28 June 2025, accessibility is no longer a recommendation or a public-sector obligation. For many digital products and services offered in the EU, it is now a legal requirement.

So far, enforcement has been quiet. There have been no widely publicised fines and few visible cases. For some organisations, this has raised a reasonable question: will accessibility enforcement actually happen?

The short answer is yes — but not in the way many expect.

What we are seeing in late 2025 is the same early enforcement phase that has preceded other major EU regulations. It is subtle, procedural, and easy to underestimate.

Accessibility enforcement starts with real user impact

The EAA is not enforced through broad technical audits or abstract WCAG scorecards. It is enforced through use cases that fail real people.

Most early enforcement activity is triggered when users cannot complete essential tasks: logging in, making a payment, submitting a form, accessing customer support, or reading critical information. When these failures occur, accessibility becomes a consumer protection issue, not a technical debate.

In these early cases, regulators are not asking whether a service meets every WCAG success criterion. They are asking more practical questions: did the organisation know about the problem, and did it take reasonable steps to address it?

Those questions matter more than perfect conformance claims.

Why enforcement feels quiet in 2025

The European Accessibility Act is enforced at national level. Each EU member state applies it through its own laws, authorities, and procedures. As a result, early enforcement actions are often administrative and rarely public.

Throughout the second half of 2025, authorities have been setting expectations, responding to complaints, and establishing internal enforcement routines. This work does not generate headlines, but it creates something more important: a record.

This is the same pattern seen after GDPR came into force. The first year focused on guidance, warnings, and observation. The consequences followed later.

What changes in 2026

The key shift heading into 2026 is not stricter rules, but accountability over time.

Accessibility is increasingly treated as an ongoing responsibility, not a one-time state. A single audit or a static accessibility statement will carry limited weight on its own. What matters is whether accessibility is being monitored, whether recurring issues are addressed, and whether progress can be demonstrated.

In enforcement discussions, the decisive question is unlikely to be “Are you fully compliant today?”
It is far more likely to be: what have you been doing since accessibility became mandatory?

This mirrors how GDPR enforcement evolved once regulators could point to ignored warnings and missed remediation timelines.

The role of automated accessibility testing

Automated accessibility testing is often misunderstood. It does not guarantee WCAG conformance, and regulators are fully aware of its limitations. But that does not make it irrelevant.

Authorities themselves use automation to identify patterns, recurring failures, and risk areas. For organisations, automated monitoring serves the same purpose. It helps surface issues consistently, track changes over time, and document effort.

In enforcement contexts, automation is not about claiming compliance. It is about demonstrating awareness and continuity — showing that accessibility is actively managed rather than ignored.

What companies should take away from this

The absence of public fines in 2025 should not be reassuring. It should be instructive.

As 2026 approaches, the organisations most exposed to enforcement risk are not those with unresolved issues, but those with no visibility into their issues at all. Regulators are far more likely to escalate cases where there is no evidence of monitoring, prioritisation, or follow-up.

The safest position is not to claim accessibility is “done,” but to be able to show that it is being taken seriously: issues are known, tracked, prioritised, and improved over time.

That is the standard accessibility enforcement is moving toward.

And in 2026, it is the difference between being part of an early enforcement case — or simply another organisation that can show it acted responsibly when the law changed.