EU

Digital Accessibility Laws in Major EU Member States

Legal Status, Penalties & Sector-Based Exemptions

🔷 Common Legal Basis:

All EU countries must comply with the EU Web Accessibility Directive, which requires public sector websites and mobile apps to meet WCAG 2.1 Level AA. Each country transposes this into national law with variations in penalties, enforcement, and exemptions for sectors and types of organizations.

🇫🇷 France

• Law: Référentiel Général d’Amélioration de l’Accessibilité (RGAA)

• Scope:
  • All public sector organizations

  • Some private entities performing public service missions (e.g., transportation, health)

• Penalties:
  • Administrative enforcement, public complaints via La Défenseure des droits

  • Legal action and reputational damage

• Exemptions (Sectors/Companies):
  • Private companies not providing public services

  • Very small organizations or websites not intended for the public

  • Archived content and third-party plugins

🇩🇪 Germany

• Law: BITV 2.0

• Scope:
  • Federal, state, and municipal websites and apps

  • Public law institutions and public transport providers

• Penalties:
  • Formal orders by state-level ombuds offices

  • Legal liability in cases of discrimination

• Exemptions (Sectors/Companies):
  • Private-sector companies (unless performing a public function)

  • Non-government-funded services

  • Archived or legacy content
    

🇪🇸 Spain

• Law: Real Decreto 1112/2018

• Scope:
  • Public administration and education

  • Private entities providing public services (e.g., utilities, banks, transport, telecom, healthcare)

• Penalties:
  • Financial fines issued by the Observatorio de Accesibilidad Web

  • Lawsuits and administrative sanctions

• Exemptions (Sectors/Companies):
  • Private companies not offering public-interest services

  • SMEs with limited digital reach

  • Archived or non-essential legacy content
    

🇮🇹 Italy

• Law: Legge Stanca (Law 4/2004), updated in 2020

• Scope:
  • Public administrations

  • Private companies with over €500M annual turnover or receiving public funding

  • Technology vendors to the public sector

• Penalties:
  • Fines; suspension of contracts

  • Legal challenges possible from end users

• Exemptions (Sectors/Companies):
  • Private SMEs under the turnover threshold

  • Organizations not providing essential services

  • Archived or emergency content

🇳🇱 Netherlands

• Law: Tijdelijk besluit digitale toegankelijkheid overheid

• Scope:
  • National, regional, and local public sector bodies

• Penalties:
  • Public “naming and shaming” in compliance register

  • No automatic fines, but legal consequences possible

• Exemptions (Sectors/Companies):
  • All private companies

  • Third-party content and legacy websites in transition

🇸🇪 Sweden

• Law: Lagen om tillgänglighet till digital offentlig service

• Scope:
  • Government agencies and municipal services

• Penalties:
  • Fines and compliance notices via the Agency for Digital Government

• Exemptions (Sectors/Companies):
  • Private companies not performing public tasks

  • Archived and third-party content

🇵🇱 Poland

• Law: Act on Digital Accessibility (2019)

• Scope:
  • All public websites and apps

  • Educational, cultural, and healthcare institutions

• Penalties:
  • Fines up to PLN 50,000 (~€10,000)

• Exemptions (Sectors/Companies):
  • Private businesses not performing public functions

  • Temporary exemptions for content in transition

🇧🇪 Belgium

• Law: Royal Decree (2019)

• Scope:
  • All public websites and apps at federal, regional, and municipal levels

• Penalties:
  • Fines and enforcement orders

• Exemptions (Sectors/Companies):
  • Private sector companies are currently exempt

  • Archived and third-party content exempt under EU directive