Europe’s accessibility law at one year: a French court orders Carrefour to reach 100%

The European Accessibility Act (EAA) took effect in June 2025. It requires many digital products and services sold to consumers in the EU, including e-commerce, to be accessible to people with disabilities. Early on, many wondered how seriously it would be enforced. In its second year, the answer is getting clearer.

On 4 June 2026, the Tribunal judiciaire de Caen issued an urgent-procedure order requiring Carrefour France to make carrefour.fr and its mobile app fully accessible within six months, with a daily penalty if it misses the deadline. The case was brought by the associations apiDV and Droit Pluriel, supported by the Intérêt à Agir collective.

Deque, an accessibility firm that followed the case, notes that Carrefour did not dispute being subject to accessibility duties under the French Consumer Code. The question was whether it had done enough.

Carrefour argued that its site already met 71% of the accessibility criteria. The court rejected this. Handicap.fr reports that the court treated accessibility as an obligation of result, not of effort, so the site must meet 100% of the applicable criteria of RGAA, France’s accessibility standard.

This matters beyond the case itself. Many businesses treat accessibility as a score where higher is better. But for a user, if the one payment button cannot be reached with a keyboard, passing every other criterion does not help them buy anything.

Not every case ends the same way. A few weeks earlier, a court in Lille dismissed a similar action against Auchan’s e-commerce subsidiary, finding its turnover fell below the €250 million threshold in a 2005 French law. The associations dispute that reading. Outcomes depend on the legal details of each case.

AccessiWay, an accessibility audit provider, summarised first-year activity across several countries. Each is moving at a different speed, and publicly known fines actually paid remain rare.

The clearest case outside France is in Norway, which is in the European Economic Area but not the EU. The regulator inspected the HelsaMi patient portal, found 119 errors across 12 of 14 requirements, and ordered fixes by 19 December 2025 or a penalty of NOK 50,000 per day.

• Sweden: the regulator PTS opened its first cases against large e-commerce operators in October 2025
• Netherlands: ACM set a 15 October 2025 deadline for non-conformance reports and flagged incomplete filers for priority audits in early 2026
• Germany: the MLBF market surveillance body began work on 26 September 2025, with penalties up to €100,000 per violation
• Italy: AgID published guidelines on 4 March 2026, opened a complaints platform on 11 March, and set fines of up to €40,000

The EAA does not apply to ordinary Thai websites. But Thai businesses that sell in-scope products or digital services to consumers in the EU, such as online shops shipping to Europe, may need to check whether they are covered. The law exempts very small businesses providing services, and details vary by member state, so seek legal advice before drawing conclusions.

In our view, the lesson applies to every business regardless of market: “partly accessible” does not mean customers can use it. Key journeys such as product search, adding to cart, entering an address and paying must work at every step. If one step breaks, the customer cannot buy.

Documentation also matters. The French plaintiffs began by testing sites and sending formal notices before going to court. A business with audit results and a clear remediation plan is in a much better position when questions arrive.

Most European standards tie back to WCAG through the EN 301 549 standard. Targeting WCAG 2.1 Level AA is a sensible starting point for any site with international customers.

Even for businesses that do not sell to Europe, the same standard makes sites easier to use for Thai customers, especially older people and those with low vision. One investment pays off both ways.

• Check whether your business sells to consumers in the EU, and consult a legal adviser
• Test core purchase journeys end to end with a keyboard and a screen reader
• Audit both website and app, since the Carrefour order covered both
• Document audit findings and a dated remediation plan
• Publish a way for users to report accessibility problems and respond systematically