Sweden's EAA Fines: The Sanction Fee Everyone Misses (and the Vite)
What Sweden's European Accessibility Act penalties actually are — a capped sanction fee up to SEK 10 million, plus an open-ended "until you comply" fine — straight from Lag (2023:254).
Quick answer
Sweden is often listed as having "no fixed EAA fine." That's wrong. Its law sets a sanction fee (sanktionsavgift) of between SEK 10,000 and SEK 10,000,000 — roughly €900 to €900,000 — plus a separate open-ended penalty (vite) that repeats until you fix the problem. Enforcement is split across five authorities.
The penalty, in plain English
Sweden gives its regulators two different tools, and it's worth knowing which is which.
The first is the sanction fee (sanktionsavgift) — a one-off financial penalty for a breach, set somewhere between SEK 10,000 and SEK 10,000,000. This is the part most summaries miss when they file Sweden under "no fixed figure": there is a cap, it's just denominated in kronor.
The second is the vite — a conditional penalty attached to an order to fix something. It isn't a fixed amount; it's set by the authority and only becomes payable if you ignore the order. Because it can be re-imposed, it functions as an open-ended "keep paying until you comply" pressure, separate from the sanction fee above.
| Sanction fee (sanktionsavgift) | Conditional penalty (vite) | |
|---|---|---|
| What it is | A one-off fine for a breach | A penalty attached to an order to fix something |
| Amount | SEK 10,000 – 10,000,000 (≈ €900 – €900,000) | Set case by case by the authority |
| When you pay | When the authority decides on the breach | Only if you ignore the order |
| Legal basis | Lag (2023:254), §§ 37–40 | Lag (2023:254), § 35 |
What the law actually says
The sanction fee's range is set out in black and white in Lag (2023:254), § 39:
"Sanktionsavgiften ska bestämmas till lägst 10 000 kronor och högst 10 000 000 kronor."
("The sanction fee shall be set at no less than SEK 10,000 and no more than SEK 10,000,000.")
— Lag (2023:254), § 39 (Riksdagen)
The vite is authorised separately, in § 35:
"Ett beslut om föreläggande enligt 32–34 §§ får förenas med vite."
("An order under sections 32–34 may be combined with a conditional financial penalty.")
— Lag (2023:254), § 35
And the law is explicit that you can't be hit with both for the same thing — § 38 blocks a sanction fee where the breach is already covered by a vite order. So the two tools are alternatives, not a double penalty.
How the amount is set
There's no formula. Within the SEK 10,000–10,000,000 band, § 39 tells the authority to set the figure according to "the seriousness and extent of the breach and the circumstances in general," and it can be reduced — even to zero — where there are special reasons. A sanction fee also can't be imposed more than five years after the breach ended (§ 37).
In euros, at current exchange rates, that's a ceiling of roughly €900,000 and a floor of about €900 — which is why the honest headline is "up to ~€900,000," not "no fixed fine."
Who enforces it
This is where Sweden is genuinely unusual: there's no single accessibility regulator. Enforcement of the private-sector law is split across five bodies, by sector:
| Authority | Covers |
|---|---|
| PTS (Post- och telestyrelsen) | Market surveillance for all products; plus electronic communications, banking and e-commerce services; and coordination across the others |
| Mediemyndigheten | Access services for audiovisual media (subtitling, audio description) |
| MTM (Myndigheten för tillgängliga medier) | E-books |
| Konsumentverket | Certain passenger transport services |
| Transportstyrelsen | Certain passenger transport services |
In practice, PTS is the one to know — it handles all products and coordinates cases that span more than one authority. A regulator can order you to bring a product or service into conformity within a deadline and, if you don't, restrict or prohibit it from the market.
What this means for your business
If you sell into Sweden, the realistic risk today isn't a surprise fine — it's a regulator ordering you to fix an inaccessible product or service on a deadline, with a sanction fee (up to ~€900,000) or a market ban if you don't. The practical move is the same one that protects you across the EU: get to EN 301 549 / WCAG 2.1 AA and keep the documentation that proves it. Sweden's own regulators are on record that automated scans alone can't prove compliance — so a real audit, not just a scanner, is what stands up.
Frequently asked questions
Does Sweden have a fixed EAA fine?
Yes — a sanction fee of SEK 10,000 to SEK 10,000,000 (about €900 to €900,000), set in Lag (2023:254) § 39. It's frequently mislabelled online as "no fixed fine."
Who enforces the EAA in Sweden?
Five authorities by sector — PTS, Mediemyndigheten, MTM, Konsumentverket and Transportstyrelsen. PTS handles all products and coordinates.
Can competitors sue over accessibility in Sweden, like in Germany?
No. Sweden has no competitor-warning-letter (Abmahnung) route; enforcement is only through the regulators.
Have any Swedish EAA fines been issued?
Not as of now. The law has only applied since 28 June 2025.
Related
- ← Back to EAA Fines by Country — the full 27-state comparison
- Germany's EAA fines — the competitor-lawsuit risk Sweden doesn't have
- How we verified all 27 national laws — our sourcing method
