A roundup of recent regulatory and legal developments you can reference in discussions with your risk and legal teams.
As 2025 comes to a close, we wanted to be sure you’re aware of some recent EU and European Accessibility Act (EAA)-related news items that may be of use in your conversations with internal risk and legal teams.
These items include everything from urgent compliance gaps in the Netherlands and e-commerce regulatory cases in Sweden to a summons for interim relief in France and pending exposure of non-compliant products in the Czech Republic.
Being proactive is the only effective way to steer clear of legal risk, and stories like these can help you drive essential conversations and make the case for increased resourcing for digital accessibility in the new year.
The Netherlands
In our recent article about Digital accessibility in a post-EAA deadline world, we shared details and guidance with you regarding the October 15 deadline for non-conformance reporting established by the Dutch Authority for Consumers and Markets (ACM).
The ACM has since advised that, while many reports have been delivered, gaps remain, and companies that failed to report or submitted incomplete reports should expect to be prioritized for audits in early spring of 2026.
Hanneke van Rooijen, project leader and senior supervisory officer at the Netherlands Authority for Consumers and Markets (ACM), spoke on this at AbilityNet’s TechShare Pro conference:
“There is a very big gap between the status of the industry and the compliance with EAA. It will indeed be a process. We [the authority] understand that. So we take that into account in our approach.”
She went on to note that fines and penalties are “absolutely not the goal.” She said that the authority tries to be “mission and value driven in this work, which means that we try to contribute with our oversight to equal access and no exclusion for people using webshops and electronic communication services. In our approach, we will urge—and try to motivate businesses as much as possible—to make the necessary changes.”
Hanneke was also very clear about what to expect in the coming days and months:
“We have started testing the companies that didn’t reply at all to our letter and to the request for reporting non-compliance. After that, we will analyze the results. From there, we will select some businesses that didn’t reply and seem to be underperforming in the results of the audit testing. We will do further investigations into these companies and, if needed, take further enforcement measures.”
The key takeaway here is that if you have not reported yet, you are encouraged to work with the authority to do so. Otherwise, you’ll need to be prepared to respond to their audit findings, as the authority has stated they will commence interventions soon.
Should it be helpful to you, the English version of the NL-ACM’s website is now live.
Ireland
The Commission for Communications Regulation (ComReg) has started to process consumer complaints, including one against Ireland’s largest mobile telecommunications company, Three. It’s been reported that Three has been responsive and active in the wake of the formal processing of the complaint.
Sweden
The Swedish Post and Telecom Agency (PTS) has announced that it has now started its first regulatory cases specifically related to e-commerce with inspections to check that operators are compliant with the Accessibility Act. The review of e-commerce services will continue in 2026.
France
We previously reported in September that in France, disability organizations working with legal partners had issued a demand against four major grocery retailers for failing to make their digital services accessible.
The grocers did not meet the compliance deadline, so a summons for interim relief was entered before the Commercial Court in November. In an article on the proceedings, legal collective Intérêt à Agir wrote that, “having observed a certain indifference regarding respect for the law and the rights of people with disabilities, the associations decided to bring summary proceedings against the four companies in November 2025, so that the courts would put an end to a situation deemed discriminatory for people with visual impairments.”
When asked about the particular approach the plaintiffs are taking, Otto Sleeking, Partner at Taylor Wessing, replied, “It is interesting to note that the plaintiffs chose interim proceedings, which can be done if the focus is on compliance and not damages. This should result in a judgment on short notice.”
Deque will continue to monitor the progress of this case as it moves through the courts.
Czech Republic
The Czech Republic’s supervisory authority plans to publish lists of non-compliant products and services, particularly under the new General Product Safety Regulation (GPSR) and the European Accessibility Act (EAA), enabling market surveillance and enforcement.
Norway
Norway is not a member of the EU and therefore not governed by EAA. However, as they are following and implementing many EU laws and regulations, we thought it important to share this item for our customers that operate within this jurisdiction:
The situation began when the Norwegian Health Authority sent a notification of regulatory non-compliance to HelsaMi (a medical app used by nearly half a million residents in central Norway). They had identified many digital accessibility errors and issued an order of correction accordingly. HelsMI worked to reduce the defect list, but many errors remained even as the initial deadline passed. The authority then issued a decision imposing a compulsory fine and set a December 19 deadline to correct the remaining errors. After this, daily fines of 50,000 kroner (approximately USD$5,360) will start.
Next steps
What these examples make clear is that while the EAA’s impact is already being felt, its real-world implications are still evolving. In a situation this fluid, informed decision-making becomes critical, and our experts continue to monitor and report on the latest developments.
You can reach out to Deque today for strategic consulting on what to do with this information, what your organization should be addressing now and in the near future, and how to use these insights to reinvigorate internal conversations with colleagues and partners.
