EAA enforcement tracker

Transposition is still being litigated between the Commission and the Member States. Letters of formal notice went to 24 Member States in July 2022 for non-notification, a further wave to Denmark, Estonia and Italy in April 2023 for incomplete transposition, and on 30 January 2026 the Commission issued reasoned opinions to Belgium, Czechia, France, Latvia and Finland, plus escalated reasoned opinions to Cyprus, the Netherlands, Slovenia and Sweden — notably over emergency-communications accessibility and scope and enforcement provisions. No referral to the Court of Justice over the EAA has been confirmed.

Ruling in référé on a claim brought by the associations apiDV and Droit Pluriel, the court ordered Carrefour France to make carrefour.fr and its mobile application fully accessible within six months, backed by a coercive daily penalty (astreinte) of €500 per day of delay after that deadline. Carrefour's position that 71% RGAA conformity was sufficient was rejected: the court held the obligation is full accessibility, not substantial accessibility. No money has fallen due — the compliance deadline is around December 2026, and the astreinte only starts if it passes unmet.

Secondary source only — we could not reach a primary document for this row.

Ruling in référé on a claim by the same associations, the court dismissed the case against Auchan E-Commerce France on a threshold ground: it applied article 47 of the 2005 disability law, whose digital-accessibility duty attaches above a €250 million turnover, and held the defendant did not meet it — while separately observing that the site's accessibility was deficient (around 41% conformity). A dismissal on who is covered, not a finding that the site is accessible. The associations have appealed.

Secondary source only — we could not reach a primary document for this row.

France supervises digital accessibility along two separate tracks, and which one applies decides who is covered. Arcom oversees online public communication services under article 47 of the 2005 disability law, as reinforced by ordonnance n° 2023-859: after a formal notice it may fine a non-conforming service, and fine separately for failures of the declaratory duties — the accessibility statement, the multi-year action plan and the contact channel — renewable every six months while the breach continues.

The second French track is the EAA transposition proper: the DGCCRF supervises accessibility of consumer-facing products and services under the Code de la consommation (article L.412-13, detailed by décret n° 2023-931), covering e-commerce, banking, transport, telephony, e-books and audiovisual media, at the EAA's own thresholds rather than the €250 million one. The seam between the two tracks is not academic — it is what the Lille court decided the Auchan case on.

Secondary source only — we could not reach a primary document for this row.

ACM published the results of testing roughly 100 of the largest Dutch web shops and the websites of major telecom and energy providers: someone using assistive technology could not complete an order at 61% of them — order buttons that could not be operated, inaccessible CAPTCHAs and similar. ACM said it is giving the worst-performing large companies improvement points, and that companies which do not improve sufficiently risk enforcement action.

The Netherlands transposed the EAA through the Implementatiewet toegankelijkheidsvoorschriften producten en diensten (Staatsblad 2024, 87), an omnibus amendment rather than a single new code. The accessibility obligations took effect on 28 June 2025. There is no single designating article and no single supervisor: each authority draws its competence from an amendment to its OWN sectoral statute, and the Rijksoverheid names six of them — the RDI for every product the directive covers (ATMs, televisions, computers, e-readers), the ILT for elements of passenger transport by air, bus, rail and water, the AFM for consumer banking services and financial e-commerce, the Commissariaat voor de Media for e-books and services giving access to audiovisual media services, the ACM for e-commerce and electronic communication services, and the Inspectie JenV for the 112 emergency number. The ACM's own competence is the one pinned verbatim in statute — article 8a.1 Wet handhaving consumentenbescherming reads "De Autoriteit Consument en Markt is belast met het toezicht op de naleving van de artikelen 8a.2 en 8a.3." A statement that escalates every complaint to the ACM sends a bank's or a broadcaster's reader to a regulator with no competence over it.

The MLBF — the joint market-surveillance body of Germany's 16 states, based in Magdeburg — became operational after its state treaty took effect on 26 September 2025 and adopted a risk-based surveillance strategy on 29 January 2026, mixing active and automated checks with reactive complaint handling. Worth stating plainly: the MLBF has published no activity numbers — no counts of checks, complaints or actions — so any figure you read about German EAA enforcement volume did not come from the authority doing it. Also worth stating plainly, because every summary gets it wrong: the BFSG never names the MLBF. §2 no. 22 defines the Marktüberwachungsbehörde as "jede Behörde, die nach Landesrecht für die Durchführung der Marktüberwachung zuständig ist", and §20 addresses "die Marktüberwachungsbehörden der Länder". Competence is therefore held at Land level and pooled by treaty; the MLBF is the body to contact, not the body the statute designates. §28 applies the same defined term to services, so there is no separate services authority.

Germany transposed the EAA as the Barrierefreiheitsstärkungsgesetz (BFSG), with the BFSGV ordinance following in June 2022; both have since been amended and should be cited from the consolidated text rather than the original promulgation. The penalty schedule sits in BFSG §37, and it is not a single number — the widely-quoted maximum applies only to the most serious categories.

Germany's distinctive exposure is not only the regulator. From around August 2025 a wave of Abmahnungen — private warning letters — went out to small e-commerce operators over claimed BFSG breaches, sent by a law firm acting for a claimed competitor and demanding roughly €600 each; a regional trade association publicly flagged the wave on 20 August 2025. The legal basis is genuinely unsettled: no German court has yet ruled on whether the BFSG is a Marktverhaltensregel under UWG §3a, which is what the practice depends on.

Secondary source only — we could not reach a primary document for this row.

The Commission decided to send Germany an additional reasoned opinion (case INFR(2022)0295) for incomplete transposition of the EAA, following a July 2022 letter of formal notice and a July 2024 reasoned opinion on the same file; Germany was given two months to respond. This is the second reasoned opinion on this file, which is the stage before a referral to the Court of Justice.

PTS opened a staged supervision programme of e-commerce services on 15 October 2025 and had 28 cases open by 3 March 2026, among them several of the largest Swedish retailers. Its published method for that cohort is worth knowing because it is concrete: it checks three parts of each site — the home page, one product page and the search function. The cases are in the review and request-to-remedy phase; PTS has published no sanction decision under the accessibility act.

Sweden's transposition — lag (2023:254) om vissa produkters och tjänsters tillgänglighet — has applied since 28 June 2025 and gives the supervisory authority two distinct instruments: a compliance order (föreläggande) that may carry a conditional fine, and an administrative sanction fee for breaches of specific substantive obligations. The two cannot both be applied to the same violation.

Austria transposed the EAA as the Barrierefreiheitsgesetz (BaFG), BGBl. I Nr. 76/2023, applying since 28 June 2025. Unlike most Member States it did not split supervision across sector regulators: the Sozialministeriumservice is the single authority for both products and services, and §36 BaFG names it in the statute as the body that imposes the fine. The ceilings are tiered and halve for SMEs as defined in §3 Z 20 — up to €80,000 (€50,000 for an SME) for placing a non-conforming product on the market, €40,000 (€25,000) for conformity-assessment and marking defects, and €16,000 (€10,000) for documentation failures and non-cooperation. The "€100,000 EAA fine in Austria" that circulates on aggregator sites is Germany's number, from §37 BFSG; it has no counterpart in Austrian law, and the two acts are easy to confuse because the abbreviations differ by one letter.

Belgium transposed the EAA in two pieces rather than one act: the loi du 5 novembre 2023 amends several books of the Code de droit économique for SERVICES, and a separate arrêté royal du 1er octobre 2023 covers PRODUCTS. Article 38 of the loi puts it in force on 28 June 2025, and article 39 lets service contracts agreed before that date run unchanged until expiry, capped at five years. What is unusual is the grading: article 32 inserts XV.99/1 into book XV, punishing breach with a niveau 2 sanction and breach committed "de mauvaise foi" with a niveau 3 one — so Belgian exposure turns on good faith, which few other transpositions make explicit. The euro bands attached to those levels are set in book XV's general scale, not in the accessibility text, so a figure quoted as "the Belgian EAA fine" is really the Code's level tariff and applies far beyond accessibility.

Bulgaria transposed the EAA only in April 2025 — the Закон за изискванията за достъпност на продукти и услуги was published in Държавен вестник 31 on 11 April 2025, nearly three years after the transposition deadline, and applies from 28 June 2025. DAMTN supervises products; services are split across the consumer-protection commission, the central bank, the financial-supervision commission and the culture ministry by sector. The penalties are two-track and modest: a глоба of 1,000–5,000 лв for an individual, or an имуществена санкция of 5,000–25,000 лв for a company, doubling on repeat to 2,000–10,000 лв and 10,000–50,000 лв. The ceiling is therefore 50,000 лв, about €25,600 at the lev's fixed rate — an order of magnitude below what "EAA fines" headlines imply.

Czechia transposed the EAA as zákon č. 424/2023 Sb., effective 28 June 2025 (§29). §19(1) makes the Česká obchodní inspekce the supervisory body for products, with the Český telekomunikační úřad, the RRTV, the Drážní úřad, the Úřad pro civilní letectví, the Státní plavební správa and regional authorities each taking their own service. Unlike most transpositions the fine ceiling is written into the act and it is tiered by offence, not by company size: §25(8) sets four bands — up to 10,000,000 Kč, 5,000,000 Kč, 2,000,000 Kč and 1,000,000 Kč. A figure of "50,000,000 Kč for legal persons" circulates in automated summaries of this act; it appears nowhere in the text.

Denmark transposed the EAA as lov nr. 801 af 7. juni 2022 om tilgængelighedskrav for produkter og tjenester, in force from 28 June 2025. §45 splits supervision four ways and names each body in the act itself: Sikkerhedsstyrelsen for products, Energistyrelsen for electronic communications, Trafikstyrelsen for air, bus and rail transport, and Søfartsstyrelsen for waterborne transport. The enforcement instrument is a påbud under §49 — an order to bring things into conformity within a stated period — and §57 makes breach punishable "med bøde", with NO figure written into the act at all: no ceiling, no floor, no administrative penalty. Any specific euro amount quoted as a Danish EAA fine is therefore not from this law. One further correction: the act does not mention Digitaliseringsstyrelsen, which is frequently named as the supervisor for digital services — the text assigns electronic communications to Energistyrelsen, and we could not verify a delegation moving it.

Traficom has been Finland's accessibility supervisor since 1 January 2025, covering products under act 102/2023 and, from 28 June 2025, private-sector digital services under chapter 3a of act 306/2019. Two details are routinely reported wrongly. The enforcement instrument is a conditional fine (uhkasakko) compelling compliance, with no euro ceiling written into the accessibility legislation at all — the €150,000 "Finnish accessibility fine" that circulates online has no statutory basis we could find, and appears only on unsourced aggregator sites. And the "independent audit paid for by the infringer" is really reimbursement of the authority's own testing costs, owed only after a finding of significant non-compliance, and for products only — there is no equivalent clause for services.

Croatia transposed the EAA fifteen days before it applied: the Zakon o zahtjevima za pristupačnost proizvoda i usluga appeared in Narodne novine 89/2025 on 13 June 2025, three years after the 28 June 2022 transposition deadline. Supervision is split between the Državni inspektorat for most products, HAKOM for radio and communications equipment, the Agencija za elektroničke medije for audiovisual media, and the transport and financial regulators for their own sectors. Article 32(1) fines a manufacturer that is a legal person €6,630 to €132,720, with lower bands for importers and distributors — the highest ordinary ceiling of any Member State transposition read for this tracker apart from Luxembourg's criminal limb. Aggregators quoting "€2,000 to €50,000" for Croatia are out by a factor of two and a half at the top.

Hungary transposed the EAA as 2022. évi XVII. törvény, with the authorities and the penalty scale set by the implementing decree 605/2022. (XII. 28.) Korm. rendelet; the substantive obligations apply from 28 June 2025. The NMHH supervises electronic products, e-readers and communications and audiovisual access services, while the consumer-protection authority takes payment and self-service terminals, retail banking, e-commerce and e-books, and each transport regulator its own mode. §9(1) of the decree sets the közigazgatási bírság from 15,000 HUF up to 5% of annual net turnover, capped at 500 million HUF, for operators turning over more than 100 million HUF; §9(4) caps it at 500,000 HUF where there is no net turnover at all. Aggregators quote 30 million HUF, 2 billion HUF and €1.26 million for Hungary — none of the three is in the decree.

Ireland transposed the EAA by S.I. No. 636 of 2023, published in Iris Oifigiúil on 15 December 2023 and in operation since 28 June 2025. Regulation 4(1) makes the CCPC the market-surveillance authority for PRODUCTS; Regulation 4(2) splits services across six more bodies — ComReg, Coimisiún na Meán, the Irish Aviation Authority, the National Transport Authority, the Central Bank of Ireland and the CCPC again — so which regulator writes to you depends on the service, not on the company. The detail most summaries get wrong is the enforcement route: Ireland did not create an administrative fine. Breach is a criminal OFFENCE, prosecuted, carrying a class A fine or up to 6 months on summary conviction, and up to €60,000 or 18 months on indictment (Regulation 32(6); the summary limb's class A fine is capped at €5,000 by section 3 of the Fines Act 2010). A "€60,000 EAA fine" quoted as something a regulator can impose is therefore wrong twice over — it is a court's ceiling on indictment, and no such conviction is on the public record.

Lithuania transposed the EAA as the Gaminių ir paslaugų prieinamumo reikalavimų įstatymas, Nr. XIV-1633, adopted by the Seimas on 8 December 2022; article 30(1) sets entry into force at 28 June 2025. Article 30(3) then grandfathers service contracts concluded before that date, and products already lawfully in use, until 28 June 2030. Like Romania, Lithuania does not appoint a single regulator: article 6(4)-(7) divides market surveillance between the consumer authority VVTAT for most products and services, the Transport Safety Administration for transport and rail-interoperable products, the Communications Regulatory Authority for electronic communications, and the Radio and Television Commission for audiovisual media. Widely repeated secondary sources date the law to 22 December 2022; that is the register publication date, not the 8 December adoption date printed in the act itself.

Luxembourg created a regulator for this specifically: article 3 of the loi du 8 mars 2023 establishes the OSAPS, which covers products and services alike, and article 36 applies the act from 28 June 2025. It also carries the highest exposure of any transposition read for this tracker, and it is CRIMINAL rather than administrative. Article 32 lets the OSAPS itself impose €250–€15,000 for procedural failures. Article 33 is the courts': €251 to €500,000 for a substantive breach, and €500 to €1,000,000 on a repeat conviction, with confiscation and destruction of goods available on top. Unlike most figures quoted for the EAA, the million is real — it is just a court's ceiling for a second offence, not a regulator's opening move.

Latvia transposed the EAA as the Preču un pakalpojumu piekļūstamības likums, adopted 16 March 2023 and applying from 28 June 2025, with implementing rules in MK noteikumi Nr. 128. Article 18(1) makes the Patērētāju tiesību aizsardzības centrs the market-surveillance authority, with sector regulators taking their own services under article 22. The striking part is what the act does not contain: reading the full text, the words "sods" and "soda" — fine, penalty — do not appear once, and the only euro figures in it are the EAA's own microenterprise thresholds (fewer than 10 staff, €2,000,000 turnover or balance sheet). The act gives corrective powers instead — rectification, restriction, withdrawal from the market — and no monetary penalty of its own. A law firm figure of "up to €10,000 for legal persons" is quoted for Latvia without an article; it is not in this act.

Malta transposed the EAA as the Accessibility Measures (European Accessibility Act) Regulations, made as Legal Notice 214 of 2022, published in the Government Gazette on 29 July 2022 and consolidated as S.L. 627.03 under the UN Convention on the Rights of Persons with Disabilities Act (Cap. 627). Regulation 1(3) holds the obligations to 28 June 2025, with regulation 4(8) held to 28 June 2027 and grandfathering that runs to 28 June 2030 for service contracts and up to twenty years for self-service terminals already in use. Regulation 2 names the Commission for the Rights of Persons with Disability as market-surveillance authority, designated under article 22(1)(v) of the Equal Opportunities (Persons with Disability) Act. The part worth knowing is that no euro figure exists to quote: regulation 27 prescribes no amount at all, it directs that penalties "shall be prescribed" by the authority under article 32 of Cap. 413 — and article 32C of that Act delegates again, requiring the Minister to set administrative fines "by means of regulations made under this Act". We could not locate those regulations in force. The enforcement machinery is real and detailed in Cap. 413 (an Enforcement Unit, cessation orders, remedial action), but the fine schedule for EAA non-compliance is a two-level delegation whose last step we could not confirm, so this row carries no penalty figure rather than one inferred from what other Maltese regulators charge.

Poland transposed the EAA late, by the ustawa of 26 April 2024 (Dz.U. 2024 poz. 731), in force from 28 June 2025. Supervision is coordinated by the Prezes Zarządu PFRON — the disability rehabilitation fund, not a market-surveillance body — with sector regulators (UKE, UTK, ULC, the Rzecznik Finansowy and the voivodeship transport inspectorates) supervising their own domains. The penalty is the part no aggregator states correctly, because it is not a number: article 73 sets the kara pieniężna "w wysokości do dziesięciokrotności przeciętnego wynagrodzenia miesięcznego w gospodarce narodowej za rok poprzedzający" — up to TEN TIMES the previous year's average monthly national wage, as published by the head of GUS in Monitor Polski — and then caps that at "nie większej niż 10% obrotu osiągniętego w roku obrotowym poprzedzającym rok nałożenia kary", 10% of the preceding financial year's turnover, whichever bites first. The ceiling therefore moves every year, depends on the operator, and cannot be quoted as a fixed złoty figure. The "up to PLN 100,000" attributed to UKE belongs to its telecoms and EMC regime, not to this act.

Portugal transposed the EAA early, by Decreto-Lei n.º 82/2022 of 6 December 2022, but article 39.º defers its effects to 28 June 2025. Article 28.º splits supervision by product and service type rather than naming one regulator — ANACOM for radio and electronic-communications equipment and services, ASAE for the remaining equipment, self-service terminals and e-readers, with further bodies for audiovisual media, transport and financial services. The penalty structure is the part worth reading carefully: article 29.º sets FLOORS, not a ceiling. A serious contraordenação runs €650–€1,500 for an individual and €12,000–€24,000 for a company; a very serious one starts at €2,000 and €24,000 respectively and runs "até ao limiar máximo previsto no Decreto-Lei n.º 433/82" — the general administrative-offence regime. So no maximum figure exists in the EAA decree itself, and any specific Portuguese ceiling quoted as coming from Decreto-Lei n.º 82/2022 is not in it.

Romania transposed the EAA as Legea nr. 232/2022, adopted 19 July 2022 and published in Monitorul Oficial nr. 743 of 25 July 2022 — three years before it bound anyone. Article 30 holds the whole act back to 28 June 2025, with the real-time text provision for 112 emergency calls (article 4(8)) held back further to 28 June 2027. The other unusual feature is that there is no single regulator: article 19(1) names seven, splitting market surveillance by product and service category between ANPC, the Ministry of Economy, ANCOM, the Digitalisation Authority, the audiovisual council CNA, the Ministry of Transport and the Competition Council. ANPC is listed first and covers the broadest category — consumer hardware and software, e-readers and consumer banking — so it is the closest thing to a lead authority, but a compliance question here may belong to any of the seven.

Secondary source only — we could not reach a primary document for this row.

Slovenia transposed the EAA as the Zakon o dostopnosti do proizvodov in storitev za invalide (ZDPSI), Uradni list RS 14/2023, with the substantive obligations applying from 28 June 2025. The Tržni inšpektorat supervises products, e-commerce and parts of banking and waterborne transport; AKOS takes electronic communications, audiovisual media and e-books. Article 34(1) fines a legal person between €3,000 and €40,000 for a product accessibility breach, and article 35 runs €500–€10,000 for electronic-communications services. €40,000 is the ceiling — the "€100,000 Slovenian EAA fine" repeated across aggregator sites is two and a half times it.

Slovakia transposed the EAA as zákon č. 351/2022 Z. z., applying from 28 June 2025, and kept supervision in one place: the Slovenská obchodná inšpekcia covers both products and services. §10(2) sets the fine at 200 € up to 3 % of the previous accounting period's turnover, capped by offence type at €6,000, €20,000 or €30,000 — so €30,000 is the statutory ceiling for the whole act, and the turnover percentage bites only below it. An aggregator figure of "up to €200,000" for Slovakia is nearly seven times the real maximum and has no basis in the text.

Cyprus transposed the EAA as Ν. 57(Ι)/2024, published in the Επίσημη Εφημερίδα, Παράρτημα Πρώτο, Αρ. 4996 on 2 May 2024 and in force from that publication under Article 52 of the Constitution; article 4 holds the substantive obligations to 28 June 2025. Two things stand out. Article 3(1) names the Υφυπουργός Κοινωνικής Πρόνοιας — the Deputy Minister of Social Welfare personally — as the competent authority, not a department, with power to delegate to officers of the Deputy Ministry and with separate accessibility-surveillance bodies to be designated by the Council of Ministers under article 3(3). And enforcement is dual-track: the administrative fine of article 36 is imposed independently of the criminal offences in article 38, so one episode of non-compliance can in principle draw both.

Greece transposed the EAA as Ν. 4994/2022, published in ΦΕΚ Α' 215 on 18 November 2022; article 46(1) brings the act into force on publication and article 46(2) holds Part B — the accessibility obligations themselves — to 28 June 2025. Article 19(2) splits market surveillance four ways by product category: the Industrial Products Safety and Compliance Directorate of the Ministry of Development for most consumer products and for payment terminals and ATMs, the telecoms regulator EETT for its category, the Transport Secretariat jointly with the Directorate, and the broadcasting council ESR jointly with the Directorate. Two things a compliance reader should know. Article 26, the sanctions article, carries no euro figure at all. And in March 2025 the Commission issued a reasoned opinion against Greece over remaining transposition gaps, notwithstanding the "complete" transposition declaration Greece filed on EUR-Lex; the Commission did not publish which gaps. On the penalties: article 26 states the principle of proportionality and the factors to weigh, then lists what the surveillance authority may do — recommend corrective action, seize temporarily, ban the product from the market — and stops. For telecoms it defers to article 113 of Ν. 4727/2020 and for media to article 36(3) of Ν. 4779/2021 or article 4 of Ν. 2328/1995, so any monetary fine for those two sectors lives in another statute entirely; for the built environment it borrows from town-planning law. This makes Greece the second EAA transposition in this tracker, after Latvia, with no self-contained monetary penalty — and unlike Latvia the absence is partial, because two sectors do have fines, just not in this act.

Estonia transposed the EAA as the Toodete ja teenuste ligipääsetavuse seadus (RT I, 15.06.2022, 1), passed on 30 May 2022, and section 27 brought it into force on 28 June 2022 — three years before the Directive's own application date, which is why this row is dated to the Estonian event rather than to 28 June 2025. Section 22(1) then holds the substantive requirements back to 28 June 2025 anyway, with transitional cover for existing service contracts to 28 June 2030 and for self-service terminals up to twenty years after commissioning. Section 16 puts state supervision with the Consumer Protection and Technical Regulatory Authority, and section 21 makes the same body the out-of-court prosecutor for misdemeanours under the act, so supervision and sanction sit in one place.

AgID put its supervisory machinery in place in the first half of 2026: determinazione n. 38/2026 (4 March 2026) approved new accessibility guidelines for services implementing article 21 of legislative decree 82/2022, and determinazione n. 84/2026 (15 May 2026) approved the regulation on how breaches are established and the sanctioning power exercised — unifying the procedure across the older "Legge Stanca" (law 4/2004) and the EAA transposition.

Italy transposed the EAA as decreto legislativo 27 maggio 2022, n. 82, in force since 16 July 2022 and operating alongside — not in place of — the older law 4/2004. AgID supervises services under article 21; the products side sits with the Ministry of Enterprises. Italy's own EAA infringement case was closed by the Commission on 11 December 2025.

Real Decreto 143/2026, de 25 de febrero, created the technical unit that supports and coordinates Spain's accessibility market-surveillance authorities, as article 28 of Ley 11/2023 required. It entered into force on 28 February 2026 and acts both as the EU and citizen contact point and as the surveillance authority of last resort where no other authority has been designated — which matters in Spain, because designation itself is regional.

Spain transposed the EAA in Título I of Ley 11/2023, and assigns the surveillance authorities to the autonomous communities and the cities of Ceuta and Melilla, each within its own competence. Its article 30 does not set an accessibility penalty schedule of its own: it defers to sector-specific law and, residually, to Título III of Real Decreto Legislativo 1/2013. That distinction is where most published figures go wrong — the €30,000 / €150,000 / €600,000 schedule widely attributed to Ley 11/2023 belongs to a different title of the same omnibus law, unrelated to accessibility.

A €90,000 fine on an airline for an inaccessible website is the figure most often quoted as "the EAA fine". The fine is real and was upheld on appeal, but it is not an EAA fine and cannot be one: the administrative sanction dates from 20 October 2020, under article 95.3.e) of Real Decreto Legislativo 1/2013 — years before Ley 11/2023 existed and years before the EAA applied. We include it because a tracker that only lists what happened is less useful than one that also names the number everyone else is misattributing.

Secondary source only — we could not reach a primary document for this row.