On 4 June 2026, a French court ordered Carrefour to make its entire ecommerce platform accessible to disabled users within six months — with daily fines for every day of delay. Carrefour had argued in its defense that its website was already 71% compliant. The judge's response was unambiguous: "The e-commerce site in question cannot just be somewhat accessible; it must be totally accessible."

With the EAA's first anniversary on 28 June 2026, that ruling tells you everything you need to know about where this law is heading.

Some businesses have treated the EAA as something to think about eventually, or something only relevant to their EU competitors. The events of the past twelve months show that view is costly. Here's what has actually happened since the deadline, what the first legal cases mean in practice, and exactly what you need to do now.

What the EAA is and who it covers

The European Accessibility Act (EU Directive 2019/882) came into force on 28 June 2025 across all 27 EU member states. It requires that a broad range of digital products and services be accessible to people with disabilities — including those with visual, hearing, motor, and cognitive impairments.

The covered categories are wider than most businesses realize: ecommerce platforms, online banking and financial services, travel booking, telecommunications, streaming and audiovisual media, e-books, and mobile apps all fall within scope. If you operate in any of these categories and serve EU consumers, the EAA applies to you.

The technical benchmark is EN 301 549 — Europe's digital accessibility standard. Its current version incorporates WCAG 2.1 Level AA in full, and extends requirements to mobile apps, software, and hardware. Conforming with EN 301 549 creates a legal "presumption of conformity," meaning regulators will presume your products meet the law's requirements.

Two scope points every business needs to understand:

Micro-enterprise exemption. Businesses with fewer than 10 employees and annual turnover under €2 million have limited exemptions on the services side of the directive. Most businesses don't qualify, and product accessibility requirements apply regardless of company size.

Extraterritorial reach. This is the point most often overlooked by UK and US businesses. The EAA applies to any business selling covered products or services to consumers in the EU — regardless of where your business is based. If your Shopify store accepts orders from Germany, your SaaS product has French subscribers, or your streaming service has Spanish users, you're in scope. Where your company is incorporated doesn't matter. Where your customers are does.

What has happened since the deadline: a country-by-country briefing

France — the most active jurisdiction

France has moved faster than any other member state, driven largely by disability rights organizations that haven't waited for regulators to act.

July 2025: Within days of the EAA deadline passing, two French disability organizations — ApiDV and Droit Pluriel, supported by the legal collective Intérêt à Agir — sent formal legal notices to four of France's largest grocery retailers: Auchan, Carrefour, E. Leclerc, and Picard Surgelés. Their websites and apps were inaccessible to approximately 2 million visually impaired people in France. The notices gave each retailer until 1 September 2025 to fix that.

The scale of the underlying problem was stark: according to the Observatoire de l'accessibilité numérique, only 3.4% of major French company websites were accessible in 2025, and fewer than 1% fully met legal requirements.

November 2025: When the September deadline passed without meaningful remediation, the organizations filed emergency injunctions ("référé") before the Commercial Court — the first EAA-linked legal filings anywhere in Europe.

May 2026: The Tribunal judiciaire de Lille dismissed the case against Auchan on procedural grounds — but notably acknowledged the site doesn't comply with digital accessibility standards. The non-compliance itself wasn't disputed. The ruling is already under appeal.

4 June 2026: The landmark ruling. The Tribunal judiciaire de Caen ordered Carrefour to achieve full accessibility within six months, with daily fines accruing until it does. Carrefour's 71% compliance figure was legally irrelevant — courts apply a binary test.

2 June 2026: A class action was filed against France's national tax authority over the inaccessibility of impots.gouv.fr. Civil action is now moving beyond retail into the public sector.

The Netherlands

The Dutch Authority for Consumers and Markets (ACM) set an October 2025 deadline for businesses to self-report their non-conformance. Many did — but with gaps. The ACM has since confirmed that businesses that didn't report at all, or submitted incomplete reports, will be prioritized for audits in spring 2026.

The ACM's own project leader has been clear: "There is a very big gap between the status of the industry and the compliance with EAA." Fines aren't the immediate goal — remediation is — but formal enforcement measures follow if businesses don't engage.

Sweden

The Swedish Post and Telecom Authority (PTS) launched its first regulatory cases specifically targeting ecommerce accessibility in late 2025, with inspections running through 2026. If you sell to Swedish customers, assume you're on their radar.

Ireland

ComReg, Ireland's communications regulator, has begun processing consumer complaints under the EAA — including a formal complaint against Three, Ireland's largest mobile telecom operator.

Czech Republic

The Czech supervisory authority plans to publish public lists of non-compliant products and services. Beyond fines, that's a reputational mechanism — and one that will matter regardless of the financial penalty attached.

What the rulings actually mean

The Carrefour decision is the most significant development of the EAA's first year. Several principles emerge that apply to every business in scope.

Partial compliance is not a legal defense. Carrefour's 71% figure wasn't contested by the court. It was simply irrelevant. The EAA doesn't grade on a curve. If 29% of disabled users can't access your service, your service is not accessible.

Civil society doesn't wait for regulators. Both waves of French litigation were brought by disability organizations, not government agencies. The EAA's transposition model means any EU consumer or consumer group can bring a claim independently of slow-moving regulatory timelines. In jurisdictions with active disability rights communities — much of Western Europe — this is a parallel legal risk that doesn't depend on how quickly the national regulator moves.

Interim injunctions are fast. The French plaintiffs chose "référé" proceedings deliberately — designed to produce rulings in weeks, not years. This law has mechanisms for rapid court orders, not just eventual fines.

One country's ruling sets the template for others. The EAA is the same directive across all 27 member states. The principles established in Caen are available to courts in Berlin, Dublin, Warsaw, or Amsterdam. France is an early indicator, not an outlier.

Even dismissed cases matter. The Auchan dismissal is under appeal. The Lille court acknowledged the site was non-compliant — it just ruled procedurally. The direction of legal travel is clearly toward stronger enforcement, not weaker.

What are the penalties?

The EAA doesn't set a single EU-wide fine. Each member state sets its own penalty regime. Financial penalties aren't the only exposure. The EAA also enables market access restrictions — non-compliant products can be barred from sale entirely. And the Czech Republic's planned publication of non-compliance lists introduces a public-facing reputational risk.

For businesses outside the EU, the worst-case outcome is losing EU market access entirely.

What this means for your business

If you're EU-based

Regulatory patience in year one has been real — but it isn't unlimited. The Dutch and Swedish approach of starting with letters and inspections before escalating to fines reflects how most regulators have operated so far. But France has demonstrated that disability organizations won't wait, and that courts will act.

The Carrefour ruling's most practical lesson: document your accessibility work, but don't rely on partial compliance as a legal defense. A remediation roadmap with clear milestones is far more valuable in an enforcement conversation than a percentage figure.

And the commercial case is just as strong as the legal one. 1 in 4 people need some form of accessibility support, and 71% of disabled users admit to leaving inaccessible sites. Those are lost customers and lost revenue — right now, before any regulator gets involved.

If you're based outside the EU (UK, US, or anywhere else)

The EAA's extraterritorial reach is written directly into the directive. Any business whose website, app, or digital service can be purchased by EU consumers is in scope — full stop.

For UK businesses post-Brexit, EAA compliance is a live requirement for any commercial relationship with EU customers, separate from UK accessibility obligations. For US-based Shopify merchants, SaaS businesses, and subscription services with EU traffic, the question isn't whether the EAA applies. It's how exposed you currently are.

Five things to act on now:

Run an accessibility audit against WCAG 2.1 AA. Automated tools catch roughly 30–40% of issues; a manual or expert audit covers the rest. You need both for a defensible compliance position — and to understand the actual gap between where you are and where the law requires you to be.

Publish an accessibility statement. France, Germany, and other member states impose separate penalties for missing or inadequate accessibility statements, regardless of your actual compliance level. It's a quick win — and an expensive omission.

Build a documented remediation roadmap. Regulators consistently say they want evidence of active, structured progress. A plan with milestones and owners reduces your enforcement risk substantially, even before remediation is complete.

Don't assume micro-enterprise exemptions apply to you. They cover specific service provisions, not all obligations. Verify your position against your specific products and the member states where your customers are.

Know where your EU traffic comes from. France, the Netherlands, Sweden, and Ireland are the most active enforcement jurisdictions right now. Knowing your EU customer geography tells you which accessibility statement requirements apply and where your civil litigation risk is highest.

Looking ahead

As the EAA enters year two, the trajectory is clear. More lawsuits will follow in France as appeals continue and the Carrefour ruling sets a template. The Netherlands will begin its spring audit cycle. Sweden's ecommerce inspections continue. The Czech Republic's non-compliance lists will go public. And more member states will follow France's lead as disability organizations across Europe watch the precedents being set.

The question is no longer whether the EAA has teeth. The Caen court just used them. The real question is whether your store is ready for what comes next — or whether you're waiting to find out the hard way.

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