EAA Enforcement in Europe: the Verified Cases You Actually Need to Cite

All verified enforcement cases — sources included

Every row below is backed by an identified source. No invented figures, no speculative maximums.

🇪🇸 Spain: the firm judicial precedent nobody is citing

Vueling matters for one reason that most commentators are missing: this case was ratified by the Audiencia Nacional (Spain's High Court, Contentious-Administrative Chamber Section 8) in February 2024, after Vueling had already been inspected and sanctioned for the same matter back in 2016. It is not just an administrative resolution that could be challenged and reversed. It is a firm judicial ruling on a recurring infringement.

The sanctioning regime applied to Vueling is the subsidiary regime of RDL 1/2013, specifically Article 95.3.e) for serious infringements under the rules applicable to the General State Administration. That is the same Title III to which Article 30 of Ley 11/2023 now refers as supplementary law. Which means Vueling is a relevant judicial validation of the post-EAA Spanish sanctioning framework, even though the infraction predates the Ley 11/2023 entering into force.

The Endesa 2018 case (€30,001, filed by CERMI following a complaint about endesaclientes.com, resolved by the Secretaría de Estado de Servicios Sociales) remains the most thoroughly documented precedent, confirmed by technical reports from CENTAC and OADI certifying WCAG AA non-compliance. Sources: Europa Press, El Economista, COCEMFE.

🇫🇷 France: the first major EAA-era lawsuit

The French case is significant not just because of who was sued, but because of how it was constructed. ApiDV and Droit Pluriel issued the formal notice (mise en demeure) on 7 July 2025 — just nine days after the EAA came into force — with a 1 September 2025 compliance deadline. When that deadline passed without adequate response, they filed emergency summary proceedings on 12 November 2025.

The E. Leclerc accessibility statement is a documented example of what does not work: it showed 32% RGAA compliance in May 2023, updated to 50% in August 2025. Still legally insufficient. Advocacy groups and their legal teams clearly had this case prepared well in advance of the EAA effective date.

Context: as of June 2025, only 3.4% of major French company websites were accessible, according to the Observatoire de la Fédération des aveugles et amblyopes de France.

🇺🇸 United States: why the FTC accessiBe case matters for Europe

The FTC case closes the argument that was still open in some compliance circles: can an overlay widget substitute for genuine WCAG remediation? The answer from the FTC is no, and the answer carries a $1 million price tag for the vendor that claimed otherwise.

Hundreds of US businesses with accessibility overlays installed have been sued in recent years for ADA violations: in May 2025 alone, 119 defendants were reported as having been sued while using a third-party accessibility-related control (widget), according to UsableNet. Courts have consistently ruled that overlays do not provide a defense against WCAG non-compliance claims. European regulators — ARCOM (France), ACM (Netherlands), AgID (Italy) — have signaled the same position: overlays are not EAA compliance.

If your EU business has an accessibility overlay installed and no underlying WCAG remediation, you are as exposed as a business with nothing installed at all. The overlay does not reduce your legal risk under the EAA.

The other EU countries: why this landing won't invent numbers

Every other English-language source on EAA enforcement lists maximum fines by country. Those lists contradict each other because the figures come from different interpretations of national laws, different versions of the same law, or secondary sources that themselves cite secondary sources.

The absence of documented cases does not mean zero risk. It means enforcement is earlier-stage in those markets. Spain and France have a longer track record of civil society enforcement and advocacy litigation, which is why their cases appear first.