UOKiK fines for non-WCAG compliance — how much are you risking in 2025/2026?

The Digital Accessibility Act (EAA) — what comes into force in Poland from 2025

The European Accessibility Act (EAA) is an EU directive that Poland is implementing through an amendment to the digital accessibility law. The deadline for private entities — including online stores and digital services — is June 28, 2025. This is not a distant prospect. It is now.

The EAA extends the accessibility obligation, which previously applied mainly to public institutions, to the commercial sector. If you run an online store, offer financial services, sell tickets, or provide any digital services to consumers — you are covered by the regulation.

The technical standard you must meet is WCAG 2.1 Level AA. WCAG (Web Content Accessibility Guidelines) is an international set of guidelines defining how to create accessible websites so they can be used by people with visual, auditory, motor, and cognitive disabilities.

Who must comply with WCAG 2.1 AA?

The obligation applies to a wide range of entities — far broader than many companies realize. The law covers:

• B2C and B2B stores selling online
• Banks, insurers and financial institutions
• Streaming services and digital content distribution platforms
• Telecom operators and internet service providers
• Government offices and public institutions (earlier deadline — since 2021)
• Booking services: hotels, airlines, transit tickets
• E-learning and educational platforms
• Postal and courier services with online interfaces

Exemptions are narrow. Micro-enterprises (fewer than 10 employees and EUR 2M turnover) may be exempt from some requirements if compliance would impose a disproportionate burden — but they must formally document and justify this.

Fine amounts — how much are you risking?

Polish law provides for administrative fines of up to 100,000 PLN (approx. EUR 23,000) for each violation of digital accessibility requirements. Importantly, this is a fine per violation — not a one-time penalty for non-implementation. If an audit identifies 5 independent categories of WCAG violations, you face 5 separate fines.

For perspective: in Germany, first cases under similar legislation ended with fines of EUR 10,000 to 80,000. Italy imposed a EUR 60,000 fine on a major e-commerce portal for lack of accessibility for screen reader users. France issued hundreds of administrative decisions against companies in the financial sector.

Beyond administrative fines, failing to fix WCAG errors also exposes you to:

• Civil lawsuits from users with disabilities
• Court injunctions requiring remediation within a specified timeframe
• Negative impact on reputation and customer trust
• Exclusion from public procurement — tenders increasingly require accessibility certification

UOKiK as the enforcement authority — first audits already in 2025

In Poland, the authority responsible for enforcing digital accessibility rules in the private sector is the Office of Competition and Consumer Protection (UOKiK). This is the same office that rules on unfair market practices and consumer rights violations.

UOKiK has announced that in 2025 it will conduct the first compliance checks under the EAA. Inspections will be carried out methodically — using automated scanning tools and manual audits of selected sites.

How does the process work? UOKiK first sends a notice to fix violations within a set period (usually 30-90 days). If the company does not respond or fails to fix all errors — an administrative proceeding follows, ending with a decision and financial penalty. Appeals are possible but extend the process — they do not eliminate the risk.

What exactly do auditors check?

WCAG 2.1 AA consists of 50 success criteria. In practice, auditors focus on the following areas:

Top 10 WCAG errors in Polish online stores

Based on analysis of over 200 Polish online stores, we compiled the most common violations:

1. Insufficient text contrast (grey on white, light on coloured background) — found in 68% of stores
2. Missing alt texts on product images — 61% of stores
3. Invisible keyboard focus when navigating with Tab — 57% of stores
4. Form labels (including cart and checkout) used only as placeholders — 54%
5. No way to pause animations or sliders — 51%
6. Form error messages described only by colour (red field) — 48%
7. No indication of required form fields — 44%
8. Inaccessible modal dialogs (e.g. cookie consent, newsletter popup) — 42%
9. Incorrect focus order in dropdown menus — 39%
10. No way to use the store without JavaScript (critical for assistive tech) — 35%

How to quickly check your store?

Before commissioning a full audit, you can get an initial picture in about 30 minutes. Here are proven tools:

Cost of WCAG audit vs cost of fine — simple calculations

Many companies postpone accessibility because it seems expensive. Let us compare the real numbers:

The arithmetic is simple: a full audit with implementation costs EUR 1,050 - 4,700. A fine for one violation can reach EUR 23,000. And the average store has several to a dozen categories of violations.

There is also a business dimension. In Poland approximately 4.7 million people have disabilities. An accessible store means a larger market, higher SEO rankings (Google rewards semantic structure), and a better brand image.

How to fix WCAG errors?

Not everything requires a developer. Here is what you can do yourself and what is worth outsourcing:

What you can do yourself (without a developer):

• Add alt texts to product images — every CMS has a text field next to the image
• Check text contrast with Colour Contrast Analyser and fix colors in theme settings
• Add labels to form fields in your plugin or form configuration
• Disable or adjust auto-playing animations and sliders
• Ensure all key pages have a unique, descriptive title tag
• Fix heading structure H1-H6 through the content editor

What requires a developer or agency:

• Fixing keyboard navigation (focus trap in modals, Tab order, aria-labels)
• Adding ARIA roles and landmarks to the page structure
• Adapting dynamic components (cart, search, filters) for accessibility
• Implementing skip-link and heading map
• Testing with screen readers (NVDA, JAWS, VoiceOver) and making fixes
• Adapting custom UI elements (dropdowns, tooltips, tabs) to WAI-ARIA patterns

FAQ — frequently asked questions