Whether a fine is imposed for failing to comply with the European Accessibility Act, and how much it is, depends on the country where the breach is identified. The directive itself prescribes the technical standard — EN 301 549, in practice WCAG 2.1 level AA — but leaves the enforcement and sanctions to the member states. This means that the same defect, for example a checkout process that cannot be operated with a keyboard, can result in a warning in one country and a formal procedure with an administrative penalty in another.
For a company that only sells in the Netherlands, this is a theoretical question. For an online shop or service provider with customers in multiple EU countries, it is something to take seriously, not because the risk of enforcement is higher somewhere — this article makes no claim about that — but because the rules you must comply with can simply differ by country.
Why sanctions vary
The European Accessibility Act is a directive, not a regulation. A regulation applies directly and identically in all member states; a directive sets out an objective and a standard, and each country translates that into its own national legislation. This also includes the choice of enforcement instrument: which supervisory authority is responsible, what steps it can take, and what sanction can be imposed at the end of those steps. This national implementation is precisely why there is no European list of penalty amounts that you can benchmark your situation against.
This difference is not only in the amount of any fine. It is also in the type of sanction. Some countries work with administrative enforcement: the supervisory authority can require a company to remedy a defect within a certain period, without an immediate monetary penalty. Other countries also have a civil law route, where a third party can directly pursue a company. Germany is the best-known example, with the so-called Abmahnung as a separate phenomenon alongside public law supervision.
What you may encounter in practice
In most countries, the process goes through a supervisory authority that first engages with the company, requesting a self-assessment and an improvement plan with deadlines. Only if this is not provided or if defects are not remedied does a formal sanction come into play. In a number of countries there is also the possibility that a sanction is published, which has a different consequence for a company than a monetary amount. The exact amounts, periods and powers are set out in the national legislation of the relevant country, and these deliberately vary by member state.
The Netherlands as a starting point, not as a benchmark
For companies that primarily operate in the Netherlands, the Dutch supervisory authority and the Dutch implementation of the directive provide the relevant framework. As soon as you also sell in other EU countries — through a website offered in multiple languages, or through a business service with cross-border customers — the supervisory authority of that other country may become involved, with its own reporting route and sanction framework. Which supervisory authority is competent in your case depends on where you operate and how the directive has been implemented in that country; if in doubt, this is something to discuss with a lawyer or the competent supervisory authority itself.
What this practically means if you operate in multiple countries
The key point is that one improvement plan and one accessibility statement do not automatically meet the requirements of every country in which you operate. The technical standard is the same everywhere, but the format of the statement, the reporting route and the sanction framework may differ. In the knowledge base by topic is worked out per country which supervisory authority applies and which declaration format is expected, so you don't have to figure that out yourself per country.
A free first step is to check whether the directive applies to your business at all and what risks are involved; you can do that with the quick-scan of your core pages. How we arrive at that assessment and where the information comes from, you can read on the page about our methodology. For country-specific sections with reporting route, supervisory authority and declaration format per EU country, including the associated deadlines, you need a subscription; what that concretely entails can be found on the overview of our subscriptions.
If you are unsure whether your situation falls under one of these national differences, that is not a question an automated scan can answer for you. Start with the free scope-check and quick-scan, and always involve a lawyer or the supervisory authority of the country in question if you have concrete doubts about penalties or jurisdiction.