Greece Can't Fine You for an Inaccessible Product — It Can Only Stop You Selling It
Greece is filed under "no fixed fine," which is true but misses the more useful fact: for products, the law provides no monetary penalty at all. Its entire toolkit is a recommendation, a seizure and a market ban. And in July 2025 Greece amended the act — not to add a figure, but to let disability organisations go to court.
Quick answer
Greece's EAA law (Ν. 4994/2022, ΦΕΚ Α' 215) says only that sanctions are applied «βάσει της αρχής της αναλογικότητας» — on the basis of the principle of proportionality. No minimum, no maximum, no formula. For products, Article 26(3) lists three measures and none of them is a fine: a corrective recommendation, temporary seizure, and prohibition on market circulation. For services, monetary sanctions come from whichever sector law already applies — telecoms via EETT, audiovisual media via the National Council for Radio and Television. In July 2025 an amending act added a collective-action route for disability associations.
The proportionality clause, and what sits under it
Article 26(1) is the whole basis for sanctions:
« …βάσει της αρχής της αναλογικότητας »
("…on the basis of the principle of proportionality")
— Ν. 4994/2022, Art. 26(1) (Εθνικό Τυπογραφείο)
That is the entire statutory guidance on how much. No ceiling is stated in the article and none is cross-referenced from it. Any published figure presented as "the Greek EAA fine" has no basis in this text.
Article 26(2), as restated by the 2025 amendment, at least tells you what gets weighed: the extent of the non-compliance, the operator's role and company size, the circumstances of the breach, the findings and their implications, the corrective action taken, and the degree of cooperation with the inspection teams. Factors, not amounts.
For products, the law simply has no fine
This is the part worth reporting, and it isn't the same as "no fixed figure." Article 26(3) gives the market surveillance authority three measures on finding a non-compliant product:
- a recommendation for corrective action;
- temporary seizure or freezing of the product;
- prohibition on its circulation and availability on the market.
No monetary penalty appears. For a manufacturer, importer or distributor, the Greek consequence of non-compliance is not a bill — it is losing access to the market. That puts Greece alongside Belgium, whose products decree also carries no fine, in a small group where the products track relies on restriction rather than punishment.
It also means the honest answer to "what's the fine for a non-compliant product in Greece?" is: there isn't one. That is a stronger and more checkable claim than "no fixed figure."
Four authorities share product surveillance under Art. 19(2):
| Products | Authority |
|---|---|
| General hardware, e-readers, payment terminals, ATMs | Directorate for Safety and Compliance of Industrial Products, Ministry of Development |
| Consumer terminal equipment for electronic communications | EETT |
| Ticketing, check-in and information kiosks | General Secretariat for Transport, jointly with the Industrial Products Directorate |
| Terminal equipment for audiovisual media access | National Council for Radio and Television, jointly with the same Directorate |
Inspection teams — κλιμάκια ελέγχου — are convened on annual planning and in response to complaints (Art. 19(3)).
For services, the fine is a telecoms or broadcasting fine
Where money does enter, it comes from outside the accessibility act. Article 26 hands off to whichever pre-existing sectoral regime governs the service:
| Sector | Authority | Penalty law |
|---|---|---|
| Electronic communications | EETT | Ν. 4727/2020 |
| Audiovisual media services | National Council for Radio and Television | Ν. 4779/2021 Art. 36(3), or Ν. 2328/1995 Art. 4 |
| Built environment obligations | — | Existing urban planning and port-zone accessibility law |
Those regimes have their own schedules, set for telecoms and broadcasting misconduct generally rather than for accessibility. So a euro figure quoted for Greece is most likely a general EETT or broadcasting penalty presented as though it were a unified accessibility sanction — the same error as attaching Arcom's €50,000 to the French EAA regime, or the Dutch sixth fine category to accessibility.
We have not been able to establish what an accessibility-specific fine would look like in practice under either sectoral regime, and we would rather say so than publish a number. Public procurement is expressly excluded from Article 26 altogether by Art. 26(7).
The July 2025 amendment: no figure, but a courtroom
Just over two weeks after the EAA became applicable, Greece amended the act — via Ν. 5218/2025, Articles 67–69 (ΦΕΚ Α' 125, 14 July 2025), inserted, oddly, into a law whose main subject is training for public-procurement staff.
It did not add a penalty figure. Article 69 touched only Art. 26(2)'s list of factors and added a 30-day appeal to the sanctioning body's hierarchical superior. Articles 26(1) and 26(3) — the proportionality clause and the non-monetary products toolkit — were left exactly as they were. Greece looked at its penalty regime after the deadline and chose not to put a number in it.
What it did add is Article 25A: collective action. Associations representing persons with disabilities (under Civil Code Art. 61) and public bodies charged with defending disabled persons' collective interests may bring court proceedings seeking:
- an injunction against the non-compliant conduct, and
- precautionary measures.
| Article 25A | |
|---|---|
| Who can sue | Disability associations (Civil Code Art. 61) and public bodies defending disabled persons' collective interests |
| What they can seek | Injunctions and precautionary measures |
| Time limit | 18 months from becoming aware of the violation, and no more than 3 years from its last occurrence |
| Court | Multi-Member Court of First Instance of the defendant's domicile (exclusive) |
| Enforcement | Provisional enforcement available |
That last detail matters: provisional enforcement means an injunction can bite before appeals are exhausted. Greece's enforcement story is therefore heading the same way as France's — not a regulator issuing fines, but organised disability associations obtaining court orders. The June 2026 Caen ruling in France shows what that produces.
A pricing rule we haven't seen elsewhere
Article 24 bars operators from applying discriminatory or selective pricing against consumers whose access is improved as a result of accessibility compliance. In plain terms: you cannot make the accessible route the expensive one.
We have not found an equivalent provision in any of the other 26 transpositions. It closes a gap the Directive itself leaves open, and it is worth knowing about if your accessible channel carries different fees, surcharges or product tiers from your standard one.
Two dates and an exemption
The 112 emergency number obligations apply only from 28 June 2027 (Art. 3(3)) — two years after everything else, an option the Directive allows and several member states have taken.
Transitional periods follow the standard pattern (Art. 28): pre-existing service contracts run to expiry, capped at five years from 28 June 2025; self-service terminals lawfully in use before that date may continue for up to 20 years from first use.
Micro-enterprises providing services are fully exempt (Art. 5(4)) — from the Section III/IV requirements and from any obligation to demonstrate compliance with them, the full exemption the Directive allows.
Separately, Art. 25 folds the Annex I accessibility requirements directly into Greek public procurement law (Ν. 4412/2016) as mandatory technical specifications — a more explicit procurement integration than most transpositions manage.
Has it been enforced yet?
Nothing has been reported. No sanctions under Art. 26, and no collective actions under the new Art. 25A — which has only existed since July 2025 and carries an 18-month filing window, so the first cases would not necessarily be expected yet.
Greece
