EAA enforcement in Denmark: tilgængelighedsloven and webshops
Denmark transposed the Act early, in June 2022, and the duties apply to webshops from 28 June 2025. The law sets no fixed fine ceiling: a breach is punished with a fine sized by the courts. We found no published fine so far.
At a glance
- Law
- Lov nr. 801 af 7. juni 2022 om tilgængelighedskrav for produkter og tjenester, applies since 28 June 2025
- Who enforces
- Sikkerhedsstyrelsen is named as control authority for e-commerce in Section 45(2); later government material describes Erhvervsstyrelsen in this role (presentation)
- Complaint routes
- Report to the control authority; no dedicated online form confirmed
- Maximum fine
- No fixed ceiling: a criminal fine (bøde) under Section 57, sized by the court
- Enforcement so far
- No published fine or named case found as of 1 October 2026.
Which law applies
Act no. 801 of 7 June 2022 covers e-commerce services offered to consumers. Section 6 requires services to meet the accessibility requirements in Annex 1, and Section 6(3) exempts microenterprises that provide services.
The Directive exempts microenterprises that provide services: fewer than 10 staff and an annual turnover or balance sheet total of EUR 2 million or less (Article 4(5)). Both conditions have to hold. Everyone above that line who sells to consumers online is in scope from 28 June 2025.
The Act itself describes outcomes (perceivable, operable, understandable, robust) rather than naming WCAG. In practice authorities and courts measure websites against the harmonised European standard EN 301 549, whose web chapter in version 3.2.1 maps to WCAG 2.1 level AA. Working to WCAG 2.2 AA covers those criteria plus the six new level A and AA criteria WCAG 2.2 added.
Who enforces it for online shops
Section 45(2) of the Act names Sikkerhedsstyrelsen (the Danish Safety Technology Authority) as control authority for products and for services including e-commerce. Other bodies cover electronic communications and transport. A 2026 government presentation describes Erhvervsstyrelsen (the Danish Business Authority) exercising supervision under the Act (presentation), so check which name appears on any letter you receive. The control authority can demand information and issue orders to comply.
How a complaint reaches a shop
Complaints go to the control authority. We could not confirm a dedicated online accessibility complaint form for Danish webshops as of 1 October 2026. We found no Danish court case on webshop accessibility under the Act.
Fines and other sanctions
Section 57 of the Act makes a breach of the core requirements punishable by a fine (bøde) "unless a higher penalty is due under other legislation". There is no fixed minimum or maximum: the court sets the amount. Before that, the authority can order a business to comply and, in serious cases, restrict the product or service (DI Handel).
What has actually happened so far
We found no published Danish fine, prosecution or named enforcement case under the Act as of 1 October 2026. Agency reporting suggests the authority began contacting businesses about their compliance in autumn 2025, but we could not confirm that from an official source.
What to do if you sell into Denmark
If you sell to consumers in Denmark and you are above the microenterprise line, the defensible position is the same as everywhere else in the EU: fix the barriers in your own code, keep dated evidence of what you tested and changed, and publish the accessibility information the law asks for.
- Scan your key templates (home, category, product, cart, checkout, account) for the failures a script can verify. Our free scan does this for up to 10 pages.
- Test the purchase journey with a keyboard only and with a screen reader. A script cannot judge whether alt text makes sense or a checkout error is announced.
- Fix the issues in the theme or codebase, not with an overlay widget. Overlays vs code fixes explains why.
- Publish the service information the Act requires, in an accessible format. See what an EAA accessibility statement must contain.
- Re-test after every redesign, theme update or new app, and keep the reports.
A Fix Sprint covers steps 1, 2, 3 and 5 for a fixed price. None of this is legal advice, and no audit can promise that a regulator or court will agree with it. It is the work that makes a complaint easy to answer.
Questions people ask
Is there a maximum fine in the Danish accessibility law?
No. Section 57 of Act 801 of 2022 makes a breach punishable by a fine without a fixed amount; the court decides (retsinformation.dk).
Who controls webshop accessibility in Denmark?
The Act names Sikkerhedsstyrelsen as control authority for e-commerce services (Section 45(2)). Later government material describes Erhvervsstyrelsen in this role (presentation).
Are small Danish webshops exempt?
Microenterprises that provide services (fewer than 10 staff and turnover or balance sheet of EUR 2 million or less) are exempt under Section 6(3) of the Act.
Will an accessibility overlay widget protect us from complaints?
Not on the evidence so far. The European Disability Forum and IAAP said in 2023 that overlays "do not make the website accessible or compliant with European accessibility legislation" (statement). In the US, the FTC made accessiBe pay USD 1 million in 2025 over claims that its widget made sites WCAG compliant (FTC). See overlays vs code fixes.
How do I find out what fails on my own shop?
Start with an automated scan of your main templates, then test checkout with a keyboard and a screen reader. Our free scan checks up to 10 pages against WCAG 2.2 AA and lists each failure with the page and element. It finds the mechanical issues only; the manual part is in a Fix Sprint.
Find out what fails on your own site
A free scan of up to 10 pages lists the WCAG 2.2 AA failures a script can verify, ranked by severity, with the page and element for each. A Fix Sprint then fixes them in your own code, reviewed by a person and proven with a re-scan. No overlay.