Calculator
Risk calculator: conformance gap and complaint exposure
Set the sliders to your situation. The calculator returns two numbers: the conformance gap, meaning the share of assessed criteria that are violated, and the complaint exposure as a band with a traffic light. Both formulas are in the open, so you can recompute the number and argue with it.
Result
Conformance gap
30 %
Measured, not modelled: the share of assessed criteria that are violated. Even one percent means „not conformant“ for the criteria concerned.
Complaint exposure
52 to 68 %
Rating: high
Modelled from the four terms above. Published as a band, because a point value would suggest a precision the model does not have.
A model calculation on a disclosed formula, not a legal forecast and not legal advice. The conformance gap is measured; the complaint exposure is a setting whose weights are stated above.
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.
There are no publicly documented individual fines yet (as of July 2026). Without a base rate any probability of a fine would be guesswork. The real near-term risk is a complaint, a warning letter and pressure to remediate.
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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