EAA enforcement, Q1 2026: what UK B2Bs serving EU traffic must do now

The European Accessibility Act took effect mid-2025. By Q1 2026, the first enforcement cases are public and the cost is concrete. UK exporters who serve EU traffic — even tangentially — are now in scope.

What changed

EAA’s main provisions kicked in June 2025. The Member State enforcement bodies spent six months building case backlogs from automated audits. Q1 2026 saw the first wave of penalty letters: three I can name from press coverage, plus eight more I’ve heard about from UK consultancies handling the response.

The three cited cases

• Dublin-based B2B SaaS, fined €11,000. WCAG 2.1 AA failures on the pricing-page form and the sign-up flow. Automatically detected by the Irish enforcement body’s scanner. The company had a US-headquartered marketing team that hadn’t budgeted for EAA at all.
• Dutch retailer, fined €34,000. Catalogue navigation failed keyboard testing; product-page CTA wasn’t focusable. The fine was on the lower end of the available band — the regulator cited “good-faith remediation effort” as the reason it wasn’t higher.
• French insurance broker, fined €92,000. Quote-comparison tool was wholly unusable with NVDA. The €92k figure included a one-time administrative penalty and a daily fine for the 60 days between formal notice and remediation.

Who’s actually in scope

EAA applies to “consumer-facing products and services” offered to EU consumers. The trap for UK exporters: the test is not “is your business based in the EU?” but “do you offer products or services to EU consumers?” If you have an EU-targeted CTA, an EU-language locale, or an EU-billing currency, you’re in scope on those surfaces.

The bright lines, as I read the Q1 2026 enforcement pattern: a UK marketing site with a French/German/Italian locale is in scope on the localised pages. A UK SaaS with EU customers is in scope across the whole product. A UK marketing site that’s purely English with no EU-targeted copy is not in scope, but should still meet WCAG 2.2 AA because UK regulation (the EQA) is heading the same direction.

What “remediation” actually looks like

The Q1 2026 cases all triggered automated scans. The Q2 — Q4 2026 cases will increasingly involve manual screen-reader testing as the enforcement bodies build that capability. Automated tools find 30 — 50% of real WCAG issues; the rest needs manual NVDA / VoiceOver / keyboard testing per locale.

If you’re starting from scratch: an Accessibility Sprint (21 days, £4,500 in my Sprint Catalogue) covers most B2B service sites including documentation. If you’ve already shipped a remediation effort, an audit-only engagement (£1,200 — £3,500) confirms whether the fixes hold under manual testing.

The deadline that isn’t optional

The enforcement bodies are not pausing. By Q3 2026 most of them will have ramped from automated scans to manual audits. The marginal cost of getting ahead of this in Q2 is small — a 21-day Sprint. The marginal cost of getting caught in Q3 is a five-figure fine plus emergency-rate consulting plus the brand damage of being on a public enforcement list.

If your site has EU traffic and you haven’t done a manual SR pass since 2024: do it now.