June 28, 2026, was a milestone moment in the history of digital accessibility. We might call it the day the European Accessibility Act (EAA) turned one year old, as it was one year ago that the act went into effect.
We’ve been having quite the celebration. Over the past week, members of the Deque team and I have hosted EAA-focused events in The Hague, Barcelona, Munich, Paris, and London. Between the beautiful locations and the inspiring groups of experts, advocates, and practitioners, it’s been a very memorable time. You can read more about these Axe-con Mini events here: Recapping our multi-city European roadshow celebrating the EAA’s one-year anniversary.
You are also encouraged to register for free for our upcoming virtual Axe-con Mini event on June 30: The EAA anniversary: Compliance, community, and what’s next. As added incentive, you’ll get access to all the recordings from these locations AND the event on Jun 30 with your registration! You’ll really, really want to take in all the insights from industry experts, regulators, and, of course, the legal experts at Intérêt à Agir (the organization that helped bring the case against four major grocers in France).
With the events now behind me, I have the opportunity to pause and reflect on what’s transpired in the past year, what’s going on now, and what may happen in year two.
One thing is certain: the EAA is now actively assuming conformance, and if ever enforcement seemed theoretical or abstract before, it isn’t any more. It’s very real, and it’s happening all over Europe.
Back in December of 2025, I was already reporting on signs of enforcement. And just as recently as this month, I was writing about the latest lawsuit activity in France, where a major grocer was just given a six-month compliance deadline, under threat of daily fines if they fail to meet their requirements.
Now, much of the proactivity I’m seeing revolves around the actions of monitoring bodies charged with ensuring EAA compliance.
Monitoring bodies across Europe are expanding the scope and scale of their activity, with Poland, Sweden, Ireland, and the Netherlands—to name just a few—all indicating plans for larger-scale monitoring efforts in the spring and summer of 2026. The Netherlands Authority for Consumers and Markets (NL-ACM), for example, has begun visiting sites to communicate the results, set expectations, and showcase people with disabilities using assistive technology to help raise awareness.
How monitoring bodies select targets is also becoming clearer. Patterns of non-compliance in one area are being treated as a signal of potential non-compliance in others, and organizations that failed to submit required non-conformance reports, or that submitted reports considered weak or inadequate, are being moved toward the front of the audit queue.
When monitoring bodies engage with an organization, they follow a deliberate sequence (whether things start with a complaint or their own monitoring obligation): automated scanning and validation of non-conformance first, then outreach, then escalating scrutiny for organizations that do not respond, including more frequent communications, potential on-site visits, and ultimately the possibility of formal sanctions. In Austria, financial penalties can be enforced by the authority without the need for litigation.
Beyond their individual efforts, monitoring bodies are also coordinating with each other. In May 2026, regulators from the Netherlands, Sweden, Germany, Austria, Ireland, and other countries met in Norway, independently and self-organized, to compare approaches and share what is working. And they are investing in capacity to back it up: Germany has hired approximately 70 auditors, and the Netherlands has added accessibility subject-matter experts.
Even as enforcement activity accelerates, most organizations are not operationally ready. Based on our work with clients across Europe, we’re consistently seeing legal, compliance, and product teams working in silos, with legal teams lacking the technical accessibility expertise needed to vigorously evaluate risk. The result is that risk levels are either unknown or significantly underestimated. Many organizations are still waiting for formal complaints or formal notification from an authority before taking any action, and those that do receive complaints often have no established process for responding to them.
The monitoring bodies themselves are flagging similar issues. Specific signals they have identified as indicators of concern include missing, weak, or unreasonable accessibility plans; poor reporting of known issues; repeated consumer complaints; unclear routes to conformance; and limited evidence of forward movement.
These are surmountable issues. In fact, the organizations we work with that have made the most meaningful progress are often starting from exactly this position.
To ensure we’re providing our clients with the strategic guidance they need, we regularly communicate with monitoring bodies across the EU. Based on what they’ve communicated directly to us about what they are looking for, we’ve identified three concrete steps that are critical for organizations to take:
- Step one: Understanding current risk. This means testing customer journeys against EN 301 549, not just WCAG.
- Step two: Establishing a documented accessibility program. This means having a published roadmap and a clear plan for evidencing conformance.
- Step three: Creating internal structures. This means achieving cross-functional alignment among legal, compliance, and product teams, establishing a process for handling complaints as they arise, and ensuring the organization can engage constructively with a regulator.
These are just some of the key specific things regulators are looking for when they assess whether an organization is making reasonable progress.
As we move into year two of the EAA, progress is really what it’s all about. The conformance ecosystem the EAA established is functioning, and everything is building toward greater scale and coordination.
The organizations best positioned to succeed are those that can report on known issues and demonstrate forward progress. They have a documented accessibility program. Their legal, compliance, and product teams are aligned. And when a monitoring body makes contact, they know how to respond and tell a thorough and complete story.
Achieving this level of progress is a journey from exposed and uncertain to confident and prepared. If your organization is still in the former category, now is the time to act. If you’ve already advanced to the ‘confident and prepared’ stage, you can look forward to your business and your customers reaping the rewards of being accessible under the EAA—including less financial and legal risk, greater market share, enhanced brand reputation, and more.
I’ll leave you with two simple predictions and one takeaway. Prediction one is that there will be more accessibility lawsuits. Many of them. Prediction two is that compliance will actually get easier, not harder. With one year of the EAA now behind us, there are fewer unknowns and more resources, tools, and ways to get the support and outcomes your organization needs.
Moving now is essential, and deliberate action is required. Fortunately, the earlier your organization starts, the more options there are. If you’re ready to take the next step, you can request a strategic consultation with our Deque experts today.
