Have any EAA fines already been imposed?

We have found no administrative fine under the EAA that has been made public in an EU Member State (as at 4 August 2026). That is not the same as an absence of action. The authorities are active: the DGCCRF has been conducting on-site inspections since January 2026. Civil proceedings have also already resulted in an injunction subject to a daily penalty of 500 euros (Caen, interim proceedings, 4 June 2026, RG 25/00691), with the six-month deadline expiring at the beginning of December 2026.

Do I need to publish a multi-year plan?

Only if you are subject to Article 47 of Law No. 2005-102: the public sector, or turnover in France of at least 250 million euros (Decree No. 2019-768). Below this threshold, this obligation does not apply to you; the EAA is what concerns you.

Does the law also apply to my small business?

The microenterprise exemption applies to service providers with fewer than 10 people, provided that annual turnover **or** the annual balance sheet total does not exceed 2 million euros. From 10 people onwards, the law applies in all cases. With fewer than 10 people and turnover of more than 2 million euros, you can remain a microenterprise if your balance sheet total remains below 2 million (Directive (EU) 2019/882, Article 3, point 23).

What does “accessible” mean in practical terms?

In practice, the European standard EN 301 549 is used, which refers to WCAG 2.1, Level AA, for websites. In France, the RGAA sets out these same criteria using its own testing method; our reports are aligned with these criteria.

Is an accessibility statement enough?

No. A statement describes the actual state of your service. A statement without an underlying assessment is itself a risk: it publicly asserts something that you have not verified.

31 July 2026

Digital accessibility in France: where do things stand in July 2026?

This article describes the situation in France. The rules are European, the enforcement is national, so both the deadlines and the amounts differ per country.

This article was translated from French. Where the two differ, the original is the one to go by. Read the authoritative version

Since 28 June 2025, the European Accessibility Act (EAA) has applied to a range of digital services intended for consumers, including e-commerce. In France, it overlaps with an older obligation arising from the 2005 law, and the two are regularly presented as one and the same. This is not a minor detail: the 2005 obligation applies only to companies generating at least 250 million euros in revenue in France. As of 4 August 2026, we have not found any administrative fine under the EAA that has been made public in an EU Member State. However, a court ruling obtained by two associations, rather than by a supervisory authority, gives Carrefour until early December 2026 to achieve conformity, subject to an astreinte of 500 euros per day.

Here is the current state of play, with one source for each statement.

Two regimes, often confused

France regulated digital accessibility well before the EAA. This has resulted in two distinct obligations today, which should not be confused:

Article 47 of loi n° 2005-102 requires a multi-year accessibility plan (no more than three years), annual action plans and a published accessibility statement. It applies to the public sector and companies whose turnover in France reaches at least €250 million (décret n° 2019-768). The penalty is administrative: a maximum of €25,000, renewable each year for as long as the breach continues.
The EAA, transposed by ordinance, has applied to the products and services concerned since 28 June 2025, with no turnover threshold of this kind. This is the regime that affects French SMEs.

The practical consequence should be stated plainly: if you are an SME, the multi-year plan does not apply to you. A provider that sells you an annual action plan on the basis of the 2005 law is referring to the wrong obligation. What applies to you is the EAA, and the EAA does not require a plan, it requires a usable service.

Who does the EAA apply to?

The EAA covers digital services intended for consumers in the EU. In practical terms:

online shops and other e-commerce services
banking and payment services
ticketing and travel information
e-books and associated reading applications

An exception exists for microenterprises providing services, and it does not work in the way that is often claimed. You are a microenterprise if you employ fewer than 10 people and if your annual turnover or annual balance sheet total does not exceed €2 million. The headcount is a strict threshold: from 10 people onwards, the exception no longer applies, regardless of your financial figures. On the financial side, meeting either criterion is sufficient: with fewer than 10 people and turnover exceeding €2 million, you can remain a microenterprise if your balance sheet total remains below €2 million (Directive (EU) 2019/882, Article 3, point 23, and Article 4, paragraph 5).

The Carrefour decision, and who obtained it

On 4 June 2026, the tribunal judiciaire de Caen, ruling in summary proceedings, ordered Carrefour France to bring its online commerce services into conformance with accessibility requirements, subject to an astreinte of 500 euros per day. This astreinte only begins after a period of six months from the date of the decision, around 4 December 2026: Carrefour therefore first has six months to make the necessary corrections. This is an order in summary proceedings, provisionally enforceable, and not a judgment on the merits (tribunal judiciaire de Caen, summary proceedings, 4 June 2026, RG 25/00691).

One point is essential to understanding what is happening in France: this decision was not obtained by a supervisory authority. It was obtained through civil proceedings by disability rights organisations (ApiDV and Droit Pluriel). It was preceded, on 7 July 2025, by formal notices sent to four major retail chains by the same organisations.

The court did not grant all the claims. Suspending the website and app was considered disproportionate because it would also have deprived other consumers of the service, and the request to publish the decision on Carrefour’s homepage was rejected. Of the 50,000 euros in damages sought, 10,000 euros were awarded. One month earlier, by contrast, the tribunal de Lille had dismissed a comparable action against Auchan.

In other words: you do not need to wait for a regulator to take an interest in you. In France, the risk arrived through civil proceedings before it arrived through administrative enforcement.

What the case says about your accessibility statement

The figure on which the case turned came from the accessibility statement published by Carrefour itself: a 71.21% conformance level. The court’s reasoning was as follows: anyone who departs from European standard EN 301 549 is presumed not to meet the legal accessibility requirements. This presumption can be rebutted, but evidence to the contrary must be provided, and Carrefour did not provide it.

An accessibility statement is therefore not a blank cheque. What you publish about the accessibility of your service may subsequently be read as evidence. This is not a reason not to publish one, it is a reason to ensure that its content is accurate and backed by an assessment and a plan.

What the DGCCRF is doing

The DGCCRF is the French market surveillance authority for this area. It is conducting its own inspection programme, with on-site checks since January 2026. These checks are separate from the organisations’ action: do not confuse the two, as the actions of one are often attributed to the other.

“There is no fine yet” is a statement that should be treated with caution: we found no administrative fine that had been made public, which is not the same as there being no fine. And this is only the beginning: the authorities are moving from implementation to active enforcement, while civil proceedings have already produced a result.

Why this is not only a legal issue

Nearly one in four people in the EU aged 16 or over reports having a disability (Eurostat, 2024 data). A website they cannot use is a website they leave. The loss in revenue is already there before any sanction. The law is the floor, not the reason.

What can you do now?

Start by finding out where you stand. With one honest caveat: automated testing covers only part of the standard. Our analysis robot machine-tests 30 of the 50 WCAG 2.1 AA criteria, either fully or in part; the others require human judgement. Automated checks reliably identify approximately 30 to 50% of genuine issues. It is a solid starting point, not a declaration of conformance.

Getting an initial idea of your own site takes 60 seconds.

Start the free analysis

Frequently asked questions

Have any EAA fines already been imposed?: We have found no administrative fine under the EAA that has been made public in an EU Member State (as at 4 August 2026). That is not the same as an absence of action. The authorities are active: the DGCCRF has been conducting on-site inspections since January 2026. Civil proceedings have also already resulted in an injunction subject to a daily penalty of 500 euros (Caen, interim proceedings, 4 June 2026, RG 25/00691), with the six-month deadline expiring at the beginning of December 2026.
Do I need to publish a multi-year plan?: Only if you are subject to Article 47 of Law No. 2005-102: the public sector, or turnover in France of at least 250 million euros (Decree No. 2019-768). Below this threshold, this obligation does not apply to you; the EAA is what concerns you.
Does the law also apply to my small business?: The microenterprise exemption applies to service providers with fewer than 10 people, provided that annual turnover **or** the annual balance sheet total does not exceed 2 million euros. From 10 people onwards, the law applies in all cases. With fewer than 10 people and turnover of more than 2 million euros, you can remain a microenterprise if your balance sheet total remains below 2 million (Directive (EU) 2019/882, Article 3, point 23).
What does “accessible” mean in practical terms?: In practice, the European standard EN 301 549 is used, which refers to WCAG 2.1, Level AA, for websites. In France, the RGAA sets out these same criteria using its own testing method; our reports are aligned with these criteria.
Is an accessibility statement enough?: No. A statement describes the actual state of your service. A statement without an underlying assessment is itself a risk: it publicly asserts something that you have not verified.

Sources

Wexlo analyses website accessibility and states openly what automated testing can and cannot detect. This article provides information, not legal advice.