Calculator
Risk calculator: conformance gap and complaint exposure
Three questions you can answer without preparation. Out come two numbers: the conformance gap, meaning the share of assessable criteria that are violated, and the complaint exposure as a band. Both formulas are in the open, so you can recompute them and argue with them.
Three questions about your website
Result
On these answers about 30 percent of the assessable criteria are violated, and your exposure sits between 59 and 75 percent: high.
Conformance gap
30 %
The share of assessable criteria that are violated. While you are estimating, this figure is an estimate too; an audit measures it. Even one percent means „not conformant“ for the criteria concerned.
Complaint exposure
59 to 75 %
Rating: high
How exposed that leaves you once someone looks: an authority acting on its own initiative, a competitor, or a customer who complains. Published as a band, because a single value would suggest a precision the model does not have.
What your answers mean in the formula
- 14 of 47 assessable success criteria violated
- 2 blockers in the core journeys (beyond five the message does not change)
- 60 percent of the violations would be found by a purely automated check: fixed as an assumption, because nobody can estimate it up front
These three numbers feed the formula below. In an audit each of them is replaced by a measurement on your actual site.
A model calculation on a disclosed formula, not a legal forecast and not legal advice. The complaint exposure is a reasoned setting whose weights are stated below.
Why there is no probability of a fine here
We could easily print a percentage for „this is how likely you are to pay a fine“. It would be invented. Three facts from the legal situation decide what the model may output instead:
There is no error threshold. Each success criterion is met or not met, and one violated criterion means „not conformant“. The law knows no score at which it flips.
A fine does not follow from a count of defects but from a procedure: market surveillance checks actively and on complaint, asks for remediation with a deadline, and only escalates if that is ignored.
In Germany the competent market-surveillance body has only been operating nationwide since September 2025, so published individual cases are still rare. Without a base rate any probability of a fine would be guesswork. Elsewhere in Europe enforcement is well under way, with deadlines and daily fines: the cases are on the page about the law.
The weights, disclosed
The complaint exposure is a model calculation from four terms. The weights are a reasoned setting derived from how enforcement works, not an empirical estimate, because there is no data set to estimate from. That is exactly why they are here rather than in a black box.
| Driver | Weight | Why it is in the model |
|---|---|---|
| Base term, as soon as anything is violated | 0.10 | An authority screening automatically does not need a complaint to find a site. |
| Blockers in core journeys | 0.35 | A barrier that stops checkout, login or contact outright produces the complaint that triggers a reactive check. |
| Share of machine-detectable violations | 0.30 | Exactly the class an authority can establish at scale without human effort. Our rules layer finds the same cases. |
| Missing or incomplete accessibility statement | 0.25 | Independently actionable under § 37 numbers 2 to 6 and provable in seconds, so it is the first thing a check looks for. |
The full formula including the bands is in docs/specs/risk.md in the source. If the legal situation changes or documented enforcement practice emerges, the recalibration is recorded there.
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