Czechia's EAA Fine Is €400,000 — and "Your Service Isn't Accessible" Sits in the Top Tier
Most countries reserve their highest penalty for CE-marking fraud and paperwork offences. Czechia puts the plainest breach of all — a service that simply doesn't meet the accessibility requirements — in the same 10-million-koruna band. And a regulator can impose it directly, with no court involved.
Quick answer
Czechia's EAA law (Zákon č. 424/2023 Sb.) sets a four-tier penalty scale topping out at 10,000,000 Kč — roughly €400,000 at about 25 Kč to the euro. There is no criminal track: unlike Luxembourg or Ireland, every penalty here is administrative, imposed by a regulator. The top tier isn't limited to fraud — under § 25(7)(a) a service provider that "fails to ensure that the service provided meets the accessibility requirements" is in it. Oversight is split across eight authorities, with the Czech Trade Inspection Authority (ČOI) as the default, and those authorities must publish lists of non-compliant products and services.
One of the largest fines a regulator can impose directly
Luxembourg's €500,000 is bigger on paper, but it's a criminal fine requiring a prosecution and a conviction. Czechia's €400,000 needs neither. A regulator can impose it directly, through ordinary administrative proceedings — which puts it among the heaviest fixed, regulator-issued accessibility penalties in the EU. (Only Italy's 5%-of-turnover sanction for very large providers, and Spain's €1,000,000 fallback under its general disability law, go higher on the administrative side.)
And it isn't a single number. § 25 defines offences operator by operator — manufacturer, authorised representative, importer, distributor, service provider — then § 25(8) assigns each lettered offence to one of four ceilings:
| Tier | Ceiling | Approx. | What typically sits here |
|---|---|---|---|
| a) | 10,000,000 Kč | ~€400,000 | Core non-compliance — including a service that doesn't meet the accessibility requirements |
| b) | 5,000,000 Kč | ~€200,000 | Documentation and retention failures |
| c) | 2,000,000 Kč | ~€80,000 | Labelling, identification and assessment-content failures |
| d) | 1,000,000 Kč | ~€40,000 | Information, cooperation and publication failures |
What the law says
The ceilings are set by cross-reference, which is why they're easy to misreport — the amount appears nowhere near the offence it punishes:
« Za přestupek lze uložit pokutu do 10 000 000 Kč, jde-li o přestupek podle odstavce 2 písm. a) nebo g), odstavce 4 písm. a) nebo f), odstavce 5 písm. a) nebo d) nebo odstavce 7 písm. a), b) nebo l) »
("A fine of up to 10,000,000 Kč may be imposed for an offence under paragraph 2(a) or (g), paragraph 4(a) or (f), paragraph 5(a) or (d), or paragraph 7(a), (b) or (l).")
— Zákon č. 424/2023 Sb., § 25(8)(a) (e-Sbírka)
Follow paragraph 7 and you find who it means and what they did. The opening is « Poskytovatel služby se dopustí přestupku tím, že » — "a service provider commits an offence where it" — and letter (a) is as basic as accessibility law gets:
« nezajistí, aby poskytovaná služba splňovala požadavky na přístupnost v souladu s § 13 odst. 1 »
("fails to ensure that the service provided meets the accessibility requirements in accordance with § 13(1)")
— § 25(7)(a)
Letter (b) covers failing to take prompt corrective measures once you know, and letter (l) failing to act within a reasonable deadline on a regulator's order under § 24(1).
That placement is the thing to notice. In most member states the maximum ceiling is reserved for CE-marking violations and conformity fraud, with plain inaccessibility sitting a tier or two down. In Czechia, an inaccessible e-commerce checkout and a forged declaration of conformity are in the same band.
The lower tiers descend through documentation and retention failures (5,000,000 Kč), labelling, identification and assessment-content failures (2,000,000 Kč), and information, cooperation and publication failures (1,000,000 Kč) — still €40,000 for what is essentially not answering the regulator properly.
Who imposes them is handled in a single sentence:
« Přestupky podle tohoto zákona projednává správní orgán, který podle § 19 vykonává dozor »
("Offences under this Act are dealt with by the administrative authority which exercises supervision under § 19.")
— § 26
Whichever of the eight regulators covers your sector both imposes the fine and collects it.
Eight regulators, one statute
Czechia splits oversight eight ways, but inside a single consolidated law rather than across separate instruments. § 19 allocates it as follows:
| Authority | Covers |
|---|---|
| ČOI (Czech Trade Inspection Authority) | All products, and any service not assigned elsewhere — the default, and for most businesses the answer |
| ČTÚ (Czech Telecommunication Office) | Electronic communications services |
| RRTV (Council for Radio and Television Broadcasting) | Access to audiovisual media services |
| Regional authority (krajský úřad) | Scheduled public transport, excluding urban bus |
| Drážní úřad | Rail passenger transport |
| Úřad pro civilní letectví | Air passenger transport |
| Státní plavební správa | Water passenger transport |
| Prague City Hall / municipalities with extended competence | Urban bus, tram, trolleybus and cable railway |
ČOI confirms its own role plainly: « Orgánem dozoru nad dodržováním povinností stanovených zákonem pro výrobky je Česká obchodní inspekce » — the supervisory authority for the obligations the law sets for products is the Czech Trade Inspection Authority.
Worth knowing what kind of regulator that is. ČOI is one of Europe's more active consumer authorities in ordinary e-commerce enforcement — in a single recent quarter it ran 103 e-shop inspections and found breaches in 94 of them. That's its general consumer-law work, not accessibility, but it tells you the inspection capacity and the institutional habit already exist.
The naming-and-shaming duty
This is the provision that deserves more attention than the €400,000. Under § 22 and § 24(2), the supervising authorities must publish lists of non-compliant products and services on their websites.
Not may — must. In most member states a regulator's finding stays between you and the regulator unless it escalates to a fine and the fine becomes public. In Czechia, publication is a standing obligation attached to the finding itself. For a consumer brand, that is a materially different exposure from a quiet administrative penalty, and it arrives earlier.
Product paperwork in Czech, no English option
Czechia is the mirror image of Luxembourg here. Safety instructions accompanying a product must be in Czech (§ 5(5)), and the EU declaration of conformity must be drawn up in Czech (§ 11(2)). No English alternative is offered for either. For an international manufacturer used to filing one English pack across the EU, that's a real, budgetable cost that most country comparisons omit entirely.
Two more Czech specifics
The micro-enterprise carve-out is narrower than it looks. Micro-enterprise manufacturers, importers and distributors are exempt from submitting the disproportionate-burden assessment on request — but not from preparing it (§ 15). If you're relying on a micro-enterprise exemption you read about in another market, check which version applies here. Micro-enterprises providing services do get the full EAA exemption.
Terminals get up to twenty years. Self-service terminals lawfully in use before the law took effect may run up to 20 years from first commissioning (§ 28) — the same allowance as Luxembourg, and, as in most member states, a straight adoption of the EAA's own optional transitional text. Services may keep using pre-existing non-compliant products, and pre-existing contracts may run, until 28 June 2030.
Has it been enforced yet?
No accessibility fines have been published. ČOI's guidance pages for businesses set out the obligations, the exemptions and the notification route — a written disproportionate-burden assessment, filed with the regional inspectorate by data mailbox — but carry no inspection or penalty statistics.
That said, Czechia is a market where the absence of published fines should be read cautiously. The publication duty in § 22 and § 24(2) means the first visible enforcement here may not be a fine at all — it may be a name on a list.
What this means for your business
Czechia inverts the usual advice. In most markets you can reasonably assume the headline ceiling is reserved for egregious conduct and that a good-faith but imperfect website sits in a lower band. Here, § 25(7)(a) puts "the service isn't accessible" in the top tier. The number to plan against is €400,000, not a comfortable fraction of it.
Three practical moves:
- Work out which of the eight authorities covers you. For most businesses it's ČOI, but a transport or media operator answers elsewhere.
- Budget for Czech-language conformity documentation, because no English declaration or safety instructions are accepted.
- Treat the § 22 / § 24(2) publication duty as the near-term reputational risk rather than the fine: it attaches to the finding, and it doesn't wait for a penalty decision.
Frequently asked questions
What is the EAA fine in Czechia?
Up to 10,000,000 Kč (about €400,000) for the top tier, then 5,000,000 Kč (€200,000), 2,000,000 Kč (€80,000) and 1,000,000 Kč (~€40,000), depending on which lettered offence in § 25 you committed.
Is it a criminal penalty?
No. Czechia's regime is purely administrative — the regulator imposes and collects the fine directly, with no prosecution required.
Does the top tier only apply to serious fraud?
No, and this is the distinctive part. Under § 25(7)(a), a service provider that fails to ensure its service meets the accessibility requirements is already in the 10,000,000 Kč band.
Who enforces it?
Eight authorities by sector, with ČOI as the default for all products and for any service not otherwise assigned. Whichever authority supervises also imposes and collects the fine (§ 26).
Can I file my documentation in English?
Not for products. Safety instructions (§ 5(5)) and the EU declaration of conformity (§ 11(2)) must be in Czech.
Related
- ← Back to EAA Fines by Country — the full 27-state comparison
- Official text: Zákon č. 424/2023 Sb. (e-Sbírka)
- Luxembourg's EAA fine — a bigger number, but criminal and court-imposed
- Austria's EAA fines — another regulator-imposed grid, at a fifth of the ceiling
