The European Accessibility Act got its first court ruling. 71% accessible didn't count.

Key takeaways
No partial credit
Carrefour argued that meeting 71% of France's accessibility criteria was enough. The court said an e-commerce site must be totally accessible, and gave it six months at 500 euros per day of delay.
The law follows the customer
If you sell to EU consumers, the EAA covers you regardless of where you're incorporated. The Dutch regulator has already sent information requests to companies with no EU office. The only broad exemption is microenterprises: under 10 employees and under 2 million euros in turnover.
Don't build your plan on the 2030 window
Services that predate June 2025 have a transition period on paper. Carrefour's site predates it by decades and still got six months, not four years.
Audit the money path first
The French ruling came down to customers who couldn't finish buying groceries, not a stray alt tag. Running a screen reader through your own checkout is free and tells you more than any scan report.
Carrefour showed up to court with a number it thought was good: carrefour.fr met 71 percent of the criteria in France's official accessibility framework. On June 4, the judicial court in Caen replied that 71 percent accessible is a strange way of saying inaccessible. The site and the mobile app were unusable for blind customers, the court found. Carrefour has six months to fix both, with a 500 euro penalty for every day past the deadline.
That's the first court ruling tied to the European Accessibility Act, the EU law that quietly took effect in June 2025 while everyone was busy arguing about the AI Act. If your product sells anything to EU consumers, this is the moment the EAA stopped being a paragraph in a compliance newsletter.
How a grocery cart ended up in court
The case didn't come from a regulator. In July 2025, days after the EAA took effect, French disability organizations sent formal legal notices to four supermarket chains: Auchan, Carrefour, E.Leclerc and Picard. The responses apparently weren't convincing, because in November the organizations filed emergency injunctions, the first EAA-related lawsuits in Europe. Carrefour's case was the first to be decided.
Carrefour's defense is the interesting part. The company didn't claim the site was accessible. It argued that meeting 71 percent of the RGAA criteria, the French framework that implements the EU rules, was sufficient. The judge disagreed in unusually plain language: an e-commerce site cannot just be somewhat accessible, it must be totally accessible. There's no percentage that counts as a passing grade, because a blind customer doesn't experience 71 percent compliance. They experience a checkout they can't finish.
Carrefour has since announced a compliance plan targeting full accessibility by the end of 2026, plus an accessibility observatory that tests fixes with real users. Which is roughly what it would have needed to do anyway, minus the court order and the daily fine.
The law you may have skimmed
The EAA has applied since June 28, 2025 to products and services placed on the EU market after that date. For digital products the covered list is broad: online stores, banking, transport and event ticketing, telecoms, e-books, streaming. The common thread is consumer-facing. Internal tools and pure B2B products are out of scope.
Where you're incorporated doesn't matter. The law follows the customer, so a US or UK company selling to EU consumers is covered the same way a French one is. The one real exemption is for microenterprises: if you have fewer than ten employees and under 2 million euros in turnover, the service rules don't apply to you.
The technical benchmark, in practice, is WCAG 2.1 Level AA, wired into EU law through the EN 301 549 standard. If you've dealt with accessibility in a US context, through Section 508 or the ADA lawsuit wave, the criteria will look familiar.
There's also a transition rule that reads like an escape hatch: services already on the market before June 2025 have until June 28, 2030, and pre-existing contracts can run out their term, capped at five years. Before you build a plan on that, consider that carrefour.fr is much older than 2025 and the court gave it six months anyway. The 2030 window exists on paper. I wouldn't lean a roadmap against it.
The regulators are warming up too
France got its ruling through advocacy groups suing directly, which is a feature of the EAA worth noticing: nobody has to wait for a regulator. But the regulators are moving as well. The Dutch consumer authority, ACM, has sent information requests to e-commerce operators around the world, including companies with no EU office, and has been auditing since spring. Active Dutch enforcement is expected in the second half of 2026, which is the half we're in now. Sweden's telecom regulator runs a formal enforcement program of its own, and penalty decisions are expected across member states through the year.
Penalties are set per country and the spread is wide: maximum fines run from around 60,000 euros in Ireland to roughly 900,000 in Sweden. Authorities can also order a non-compliant service off the market entirely. And because this is a directive implemented 27 times, compliance is checked country by country, not once for the whole bloc.
What this looks like in an actual codebase
WCAG 2.1 AA is not exotic. For a typical store or booking flow it means labels on every form field, everything operable by keyboard, visible focus states, enough color contrast, alt text that says something useful, and no traps where a screen reader user can enter a flow but not leave it. None of this is hard on its own. What's hard is that it has to hold across the entire purchase path, including the embedded widgets everyone forgot about.
Note what the Carrefour case was actually about: not a missing alt tag on a blog image, but customers who could not shop. If you audit anything, audit the money path first. Open a screen reader and try to complete a purchase on your own site. That single test tells you more than most scan reports.
Automated scanners are worth running, and they catch the mechanical failures cheaply. What they can't tell you is whether a person can actually finish checkout without sight. That takes manual testing, ideally by people who use assistive tech daily. It's what Carrefour's new observatory does, and what it could have started two years earlier for a lot less money.
The other structural decision: fix things in the component library, not per page. If your button, input and modal components are accessible, every page that uses them inherits the fix. If you patch pages one by one, the next sprint quietly breaks them again.
If you're covered, this quarter
- Run a screen reader through your checkout or booking flow yourself. It costs nothing, and it's effectively the test the Caen court applied.
- Get a WCAG 2.1 AA audit and triage by funnel impact, not by issue count. A hundred minor contrast issues matter less than one unlabeled payment field.
- Move the fixes into shared components so they persist past the next redesign.
- Document how the service meets the requirements. The EAA expects providers to explain this publicly, and an accessibility statement is the usual form.
- If a rebuild is on your roadmap anyway, make WCAG AA an acceptance criterion from the first ticket. Retrofitting is the expensive way to buy the same thing.
GDPR looked ignorable for about a year too, and then it wasn't. The EAA is at the same point on that curve, with one difference: the first court order already exists, it names a household brand, and it puts the acceptable level of accessibility at exactly 100 percent.
Frequently asked questions
Does the EAA apply to companies outside the EU?
Yes, if you sell products or services to consumers in the EU. The law follows the customer, not your registered address. The Dutch consumer authority ACM has already sent information requests to e-commerce operators headquartered outside the EU, so this is being enforced in practice, not just in theory.
What technical standard do I actually have to meet?
In practice, WCAG 2.1 Level AA, which enters EU law through the EN 301 549 standard. Member states implement it through their own frameworks, like the RGAA in France. Note that the first court ruling rejected percentage compliance as a defense: 71% of the RGAA criteria was treated as non-compliance, not as a passing grade.
Our service launched before June 2025. Don't we have until 2030?
There is a transition rule: services already on the market before June 28, 2025 have until June 28, 2030, and contracts signed before that date can run to their end, five years at most. But the Carrefour ruling gave a decades-old site six months to reach full accessibility, and a major redesign is widely read as placing a new service on the market, which restarts the clock. Treat 2030 as fragile.
What are the penalties for non-compliance?
They're set per country and the spread is wide: maximum fines range from around 60,000 euros in Ireland to roughly 900,000 in Sweden, and courts can add daily penalties, like Carrefour's 500 euros per day. Authorities can also order a non-compliant product or service off the market. Separately, disability organizations can sue directly, which is how the French cases started.
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