Romania's EAA Penalties: Ten Violation Categories, Explained
Romania's law lists ten types of accessibility violation, each with its own fine — but the euro amounts are modest (roughly €1,000–€3,000). The real bite is what comes with them: suspension of your business activity, and seven different regulators.
Quick answer
Romania (Law No. 232/2022) fines EAA breaches across ten contravention categories, in bands from 5,000 to 15,000 lei — roughly €1,000 to €3,000 — plus a separate 2,500–5,000 lei band for misusing the CE marking. So the headline fines are small. But alongside any fine, the inspecting officer can propose product withdrawal, suspension of your business activity, or withdrawal of your operating licence — which matters far more. Enforcement is split across seven sector authorities.
What Romania's penalty structure looks like
Romania took a granular approach. Rather than one ceiling, Article 27 of Law 232/2022 breaks non-compliance into ten distinct categories (lettered a to j), each with its own fine band, covering every link in the chain — manufacturers, importers, distributors and service providers. It reads like a serious, detailed regime, and in structure it is.
But convert the numbers and the fines themselves are among the lightest in the EU: the top band is 15,000 lei, about €3,000. The mistake would be to conclude Romania is low-risk. The fines are small; the other sanctions are not — and neither is the burden of dealing with seven different regulators.
What the law says
Article 27 opens by classifying non-compliance as a contravenție (an administrative offence, unless it rises to a criminal one), then sets the ten bands:
"Următoarele fapte constituie contravenții, dacă nu au fost săvârșite în astfel de condiții încât, potrivit legii penale, să fie considerate infracțiuni, și se sancționează după cum urmează: … a) încălcarea de către producătorii, importatorii, respectiv distribuitorii … se sancționează cu amendă de la 6.000 lei la 12.000 lei; … c) … amendă de la 7.000 lei la 15.000 lei; … e) … amendă de la 5.000 lei la 10.000 lei; f) încălcarea de către furnizorii serviciilor … a dispozițiilor art. 13 alin. (1) … amendă de la 6.000 lei la 12.000 lei …"
("The following acts constitute contraventions, unless committed under conditions making them criminal offences, and are penalised as follows: … producers, importers or distributors [breaching the core accessibility duty] … a fine of 6,000 to 12,000 lei; … 7,000 to 15,000 lei; … 5,000 to 10,000 lei; service providers [breaching Art. 13(1)] … 6,000 to 12,000 lei …")
— Legea nr. 232/2022, Art. 27(1) (Portal Legislativ)
The full set of bands:
| Violation category (Art. 27(1)) | Fine (lei) | ≈ EUR |
|---|---|---|
| Core non-compliance — products (a) | 6,000–12,000 | ~€1,200–€2,400 |
| Conformity assessment / documentation (b) | 6,000–12,000 | ~€1,200–€2,400 |
| Labelling, contact info, instructions (c) | 7,000–15,000 | ~€1,400–€3,000 |
| Corrective action / non-compliance register (d) | 7,000–15,000 | ~€1,400–€3,000 |
| Documentation / cooperation with authorities (e) | 5,000–10,000 | ~€1,000–€2,000 |
| Core non-compliance — services (f) | 6,000–12,000 | ~€1,200–€2,400 |
| Service accessibility-information duties (g) | 7,000–15,000 | ~€1,400–€3,000 |
| Service change-management duties (h) | 6,000–12,000 | ~€1,200–€2,400 |
| Service corrective action / notification (i) | 7,000–15,000 | ~€1,400–€3,000 |
| Service documentation / cooperation (j) | 5,000–10,000 | ~€1,000–€2,000 |
(Euro conversions approximate, at ~5 lei to the euro.)
The part that bites
Here's what a fine schedule hides. Article 27(2) lets the inspecting officer attach a complementary measure to any fine:
"Odată cu aplicarea amenzii contravenționale, agentul constatator poate propune una dintre următoarele măsuri complementare: a) retragerea/rechemarea produsului de pe piață …; b) suspendarea activității producătorului/distribuitorului/importatorului pe perioada nerespectării prevederilor prezentei legi; c) suspendarea/retragerea avizului, acordului sau autorizației de exercitare a activității …"
("Together with the fine, the inspecting officer may propose one of the following complementary measures: (a) withdrawal/recall of the product; (b) suspension of the operator's activity for the period of non-compliance; (c) suspension/withdrawal of the operating permit, approval or authorisation …")
— Legea nr. 232/2022, Art. 27(2)
For most businesses, a €2,000 fine is a rounding error — but having your activity suspended or your operating licence pulled is existential. That's where Romania's real leverage sits, and it's why the small fine numbers are misleading as a risk measure.
There's also a separate, smaller band for CE-marking abuse: under Art. 27(3), improper affixing of the conformity marking is fined 2,500 to 5,000 lei, plus market withdrawal and/or a ban on the mismarked products.
Who enforces it — seven authorities
Romania spreads enforcement across seven bodies, by sector (Article 19):
| Authority | Covers |
|---|---|
| National Authority for Consumer Protection (ANPC) | General hardware, terminals, e-readers, banking |
| Ministry of Economy | Self-service payment terminals |
| ANCOM (communications regulator) | Electronic communications |
| Authority for the Digitalization of Romania (ADR) | E-books, e-commerce |
| National Audiovisual Council (CNA) | Audiovisual media access |
| Ministry of Transport and Infrastructure | Transport services |
| Competition Council | Micro-enterprise guidance compliance |
Each applies the fines within its own sector. A business spanning categories — say, an e-commerce operator that also offers banking — can answer to more than one.
There's also a collective-enforcement route (Article 26): consumers, public bodies and associations can take a non-compliance case to court or to the relevant authority, including on a complainant's behalf.
Has it been enforced yet?
No confirmed Romanian EAA fines have surfaced. The law only applied from 28 June 2025 (with the 112 emergency-service requirement deferred to 28 June 2027), and the seven-authority structure is still bedding in. As elsewhere, "no fines yet" reflects the early stage, not a soft regime.
What this means for your business
Don't price Romania by its fines — price it by the suspension powers. Meeting EN 301 549 / WCAG 2.1 AA and holding the documentation (conformity records, the non-compliance register, the disproportionate-burden assessment) is what keeps you clear of the corrective-action and cooperation-failure bands — which carry not just fines but the escalation to activity suspension. And identify which of the seven authorities governs your product or service, because that's who you'll be dealing with.
Frequently asked questions
How big are Romania's EAA fines?
Small — 5,000 to 15,000 lei (roughly €1,000–€3,000) across ten contravention categories under Article 27 of Law 232/2022, plus 2,500–5,000 lei for misusing the CE marking.
So is Romania low-risk?
Not really. The fines are modest, but the inspecting officer can also propose product withdrawal, suspension of your business activity, or withdrawal of your operating licence — those are the real consequences.
Who enforces the EAA in Romania?
Seven sector authorities, including consumer protection (ANPC), the communications regulator (ANCOM), and the digitalization authority (ADR).
When did it take effect?
28 June 2025, with the 112 emergency-communications requirement deferred to 28 June 2027.
Related
- ← Back to EAA Fines by Country — the full 27-state comparison
- Spain's EAA fines — another fragmented, multi-authority regime
- How we verified all 27 national laws — our sourcing method
