Every EU country now has a named authority whose job is to check whether consumer-facing websites and apps meet the European Accessibility Act. In Germany, that authority has been in an active control phase since January 2026. Wherever you sell in the EU, someone specific now holds the mandate to look at your site.

The EAA applies since 28 June 2025, but the enforcement machinery took time to stand up. It now exists. This article maps who does the checking in Germany, Austria, Czechia, and Poland, how each authority works, and what the first court rulings in Europe suggest about where this is heading.

Germany: one central authority for the whole private sector

Authority: the Marktüberwachungsstelle der Länder für die Barrierefreiheit von Produkten und Dienstleistungen (MLBF), seated in Magdeburg. This is a market surveillance authority: the public office that checks whether companies actually follow the law. All 16 Länder pooled private-sector EAA surveillance into this single body by state treaty. One address for every online shop, bank, and telecom in Germany.

How it works: the MLBF adopted its market-surveillance strategies on 29 January 2026 and has been in an active control phase since January 2026 (source: ms.sachsen-anhalt.de, mlbf-barrierefrei.de, BFSG press round-up July 2026). Its published approach is two-track:

  • Reactive, complaints-first: any consumer or association can file a complaint; complaints are sorted by priority and investigated.
  • Active, systematic controls: the authority runs its own checks, partly automated, focusing on high-reach services and providers with a history of defects.

The procedure is graduated, meaning it escalates in stages: investigation first, then a formal request to fix the problems by a deadline, and only then a fine procedure. BFSG § 37 sets a maximum fine of €100,000 for supplying a non-compliant product or service, and €10,000 for breaches of the information and documentation duties (source: gesetze-im-internet.de/bfsg, § 37).

Don't confuse it with: the 16 public-sector Überwachungsstellen, which monitor government and public-body websites under the older Web Accessibility Directive / BITV regime. Different law, different bodies, different reporting. If you are a private company, MLBF is your regulator.

Austria: one authority, one address

Authority: the Sozialministeriumservice, with the competence seated in Linz, is the sole national authority for EAA (BaFG) market surveillance. The simplest enforcement setup of the four countries.

Fines: administrative penalties up to €80,000, with a reduced ceiling of €50,000 for SMEs (source: BaFG, Austrian federal law information system ris.bka.gv.at).

Austria's e-commerce obligations went live on 28 June 2025 with no meaningful transition for services. One authority and a mid-range fine ceiling make for simple math: if a complaint about your shop lands in Linz, there is no doubt about who acts on it.

Czechia: split up by sector

Law: Act No. 424/2023 Sb. on accessibility requirements for certain products and services (source: zakonyprolidi.cz).

Czechia split enforcement across sector regulators:

  • ČOI (Czech Trade Inspection Authority): e-commerce and general retail, i.e. most online shops (coi.cz).
  • ČTÚ (Czech Telecommunication Office): electronic communications services.
  • RRTV (Council for Radio and TV Broadcasting): access to audiovisual media services.
  • Drážní úřad (Rail Authority) and ÚCL (Civil Aviation Authority): passenger transport elements in their sectors.

Fines: up to CZK 5 million (roughly €200,000) at the top end, nominally the highest ceiling on this map (source: Act 424/2023 Sb.).

The split cuts both ways. Enforcement heat has been lower than in Germany so far, but an online shop answers to ČOI, an inspection body with decades of routine practice in checking Czech e-commerce for other consumer-law duties. The machinery is familiar; accessibility is a new item on an existing checklist.

Poland: a central coordinator plus sector enforcers

Law: Poland's accessibility act of 2024 transposing (writing into national law) the EAA.

Architecture: PFRON (the State Fund for Rehabilitation of Disabled Persons) acts as the central complaint coordinator, the front door where consumer complaints arrive and get routed (pfron.org.pl). Enforcement then sits with sector bodies:

  • UKE (Office of Electronic Communications): telecom.
  • Rzecznik Finansowy (Financial Ombudsman): consumer banking services.
  • UTK (Office of Rail Transport): rail passenger services.

Fines: up to ten times average monthly salary per violation, or up to 10% of turnover in the more serious constructions under the act. The ceiling scales with company size rather than being a fixed number (source: Polish accessibility act of 26 April 2024, Dz.U. 2024 poz. 731, Art. 12).

And PFRON has already funded a market-surveillance system development project ("Budowa i rozwój systemu nadzoru rynku"). Poland intends to check at scale, not just react to individual complaints.

What the first court rulings signal

Enforcement is not only administrative. In France, under the same EU directive, the first private-enforcement rulings landed in June 2026:

  • Carrefour (Tribunal judiciaire de Caen, 4 June 2026): the court ordered Carrefour to make its website and app accessible within 6 months, under a penalty of €500 per day of delay, and framed accessibility as an obligation of result. In plain terms: it is not enough to try, the site actually has to end up accessible (sources: droitpluriel.fr, ecommercemag.fr).
  • The counterweight: a parallel case against Auchan was dismissed in Lille and is now on appeal, and a further case (E.Leclerc) is listed for hearing in September 2026 (source: LSA).

The fair reading: this is developing law, and outcomes differ between courts. But the Caen ruling shows what one court was already willing to order under this directive (a hard deadline with daily penalties), and disability associations across the EU are watching.

What this map means in practice

Three things follow from the setup above:

  1. There is always a specific addressee. "Nobody checks this" stopped being true in 2025. In every one of these markets, a complaint about your site has a defined destination and a defined procedure behind it.
  2. The graduated procedure is your window. Every regime on this map starts with a request to fix things by a deadline before fines. A company that can answer such a letter with evidence (an audit, a prioritized fix plan, a published accessibility statement) is in a categorically different conversation than a company starting from zero.
  3. Selling cross-border multiplies regulators, not obligations. The technical standard (EN 301 549 / WCAG 2.1 AA) is the same everywhere. Fix the site once, document it once per the national requirements, and you have answered all four authorities.

FAQ

Q: Which authority is relevant if we sell into several of these countries? A: Each country's authority supervises services offered to consumers in its market. A German-Czech shop can, in principle, hear from both the MLBF and ČOI. The remediation work is the same; the statement and correspondence duties are per-country.

Q: Do these authorities scan proactively, or only react to complaints? A: Germany's MLBF explicitly does both: complaints first, plus systematic, partly automated active controls. The others are currently more complaint-driven, but Poland's funded surveillance-system project points the same direction.

Q: Are the fines the real risk? A: Fines are the endpoint of a process, not the opening move. The realistic near-term scenario is a remediation request with a deadline. The cost that matters is being unable to answer it. And, as Caen shows, courts can impose their own deadlines with daily penalties independent of the administrative track.

Q: What about public-sector websites? A: Different regime (Web Accessibility Directive / national equivalents like BITV in Germany), different monitoring bodies, different reporting duties. This article covers the private-sector EAA track.

Sources

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Related article: Am I in scope? The EAA scope guide for online businesses

This article is informational and does not constitute legal advice.