The Stop-Sale Threat: How Germany & Sweden Can Pull Non-Compliant Products

## Operational Rigor: The Stop-Sale Threat Countries like Germany and Sweden emphasize "Market Surveillance" over simple fines. The primary threat here is not the monetary penalty, but the Market Ban—the forced withdrawal of a non-compliant digital product or the shutdown of an e-commerce interface.

• ### Germany: The "Nuclear Option"
• Germany’s Barrierefreiheitsstärkungsgesetz (BFSG) views accessibility as a mandatory product characteristic, akin to fire safety.
• Authority to Ban: Authorities can order the termination of the service or the withdrawal of the product from the market. If a website or app is non-compliant, the state authority can issue a binding order to shut it down.
• Administrative Fines: While fines are capped at €100,000, the operational cost of a forced shutdown far exceeds this. The focus is on removing "defective" products from circulation.

• ### Sweden: Sanction Fees and Injunctions
• Sweden uses a technocratic, process-driven approach via the Post and Telecom Authority (PTS).
• Sanction Fees: Fees range from 10,000 SEK to 10,000,000 SEK (approx. €900,000). These are administrative fees levied directly by the authority without a court trial.
• Conditional Fines (Vite): PTS often issues injunctions with a conditional fine (e.g., "Fix this by May 1st or pay 1 million SEK"). This puts the control in the hands of the company: fix it to avoid the penalty, or delay and pay automatically.