EAA Digital Accessibility Compliance: What the Carrefour Ruling Teaches Every Business

The European Accessibility Act (EAA) became enforceable across all 27 EU member states on 28 June 2025. Any business selling to EU consumers must comply, regardless of where they are based.

For years, the EAA was discussed as something coming in the future. Then June 2025 arrived. Within days, enforcement had already begun in France. Disability rights organizations filed formal legal notices against four of France's largest grocery retailers. When those retailers failed to act meaningfully, courts got involved. In June 2026, the Tribunal judiciaire de Caen delivered a landmark ruling against Carrefour France. The ruling sent a clear signal to businesses everywhere.

EAA digital accessibility compliance is not optional, not partial, and not future. It is a legal reality today.

The Carrefour Accessibility Case

The Carrefour case began with a public call for testimonies from visually impaired users across France. Two prominent French disability rights organizations led the action. These were the ApiDV (the French association for people with visual impairments) and Droit Pluriel (a law firm specializing in disability rights). They were supported by Intérêt à Agir, a legal collective focused on public interest rights.

After gathering real-world user experiences, the organizations identified four major French retailers whose digital platforms were failing people with visual impairments: Auchan, Carrefour, E. Leclerc, and Picard Surgelés.

The table below shows the timeline of events:

The court gave Carrefour six months to make its website and mobile application fully accessible to people with disabilities. Fines begin to accrue every day of delay after that deadline.

The legal basis was the French Consumer Code, as amended to transpose the EAA into national law. France had already required large private companies with turnover exceeding €250 million to comply with accessibility obligations under Article 47 of Law No. 2005-102 since 2016. The EAA strengthened these obligations further and extended them across the EU.

Carrefour's Own Position Made Things Worse

A critical detail emerged during the proceedings. Carrefour had never disputed that it was legally required to be accessible. The company acknowledged its obligations under the Consumer Code. What it argued was that it had already met 71% of the applicable Référentiel Général d’Amélioration de l’Accessibilité (RGAA) criteria.

The judge rejected this position directly. In the court's own words: "The e-commerce site in question cannot just be somewhat accessible; it must be totally accessible." Droit Pluriel captured the standard precisely in their statement on the ruling. When a company chooses to assess against the RGAA, 100% of applicable criteria must be met. No partial score qualifies as compliance.

What Accessibility Issues Were Identified on Carrefour's Platform

The organizations tested Carrefour's website and mobile application with real blind and low-vision users using assistive technologies. They found systematic barriers that prevented independent use of the platform for core shopping tasks.

• Missing alt text on informational images: Product images and other visually meaningful content had no descriptive text alternatives. A screen reader user received no information about what the image conveyed. This directly affected product discovery and decision-making.
• Decorative images read aloud by screen readers: Screen readers were announcing decorative images that carry no meaningful content. This created noise and confusion for blind users trying to navigate the page.
• Videos without text alternatives or descriptions: Video content on the platform had no captions, transcripts, or audio descriptions. Users who are deaf, hard of hearing, or blind had no way to access that content.
• Text readability breaks at 200% font size: When users scaled text to 200%, which is a standard accessibility requirement under WCAG 1.4.4, the layout broke down. Text overlapped, was clipped, or became unreadable. This directly affected users with low vision who rely on larger text.
• Navigation barriers blocking task completion: Specific pages required unnecessary vertical scrolling that created friction for users with motor disabilities. More critically, users with disabilities were blocked from completing essential tasks, including checking out. The inability to complete a purchase is a violation under EAA.

1. Browsing the eCommerce store.
2. Selecting products
3. Adding to products to basket
4. Completing a purchase.

Visually impaired users could not shop independently on the platform. That is not partial inaccessibility, but a complete exclusion.

Critical Lessons Every Organization Must Take from This Case

Lesson 1: Partial Compliance Is Not Compliance

This is the single most important legal principle the Carrefour ruling confirmed. Carrefour claimed 71% RGAA compliance. The court said that was not enough. The RGAA framework contains 106 technical criteria. Compliance means meeting all 106. There is no passing score below 100%.

The court used a precise analogy. 100% of the steps on a staircase must be covered by a handrail. Covering 71% of steps leaves some users unable to climb safely. The same logic applies to digital accessibility.

This has direct implications for how organizations must approach EAA digital accessibility compliance. An accessibility score is not a compliance certificate. An audit report is not proof of conformance unless every applicable criterion is met.

Lesson 2: Financial Penalties Are Real and Accumulating

The Carrefour ruling imposed daily fines that begin accruing if the company fails to meet the six-month remediation deadline. This is not a one-time fine. The cost grows every day the site remains non-compliant.

Across the EU, penalty frameworks vary but are significant:

Lesson 3: Real Users Matter More Than Automated Scans

Carrefour almost certainly used automated accessibility scanners as part of its 71% compliance claim. Automated tools are valuable because they catch real issues. But they cannot catch everything.

W3C guidance confirms that automated tools reliably detect only 30 to 40% of WCAG-defined accessibility barriers. The most critical barriers, such as screen reader incompatibility on dynamic interfaces, broken keyboard navigation flows, and inaccessible checkout sequences, require manual testing with real assistive technology and real users.

The ApiDV and Droit Pluriel organizations tested Carrefour's platform with actual blind users. That testing revealed barriers that no automated scanner would have reported. Courts and regulators apply the same standard: how does a disabled user actually experience this platform? Automated tools are the starting point, but human expertise is still needed.

Lesson 4: The EAA Has Global Reach

• Germany: E-commerce operators started receiving private warning letters from law firms within weeks of the BFSG (Germany's EAA transposition) taking effect
• Netherlands: The ACM (Consumer and Market Authority) began mandatory self-reporting requirements in October 2025 and is now conducting active monitoring
• Sweden and Denmark: Both countries began contacting businesses about compliance status in October 2025
• Italy: Active enforcement with 90-day remediation notices before fines apply

The rules for enforcing the EAA are now in place across the EU. France's actions in June 2026 show what other EU countries are likely to do next.

What E-Commerce Businesses Must Do Right Now

Know Your Regulatory Exposure First

• Do you sell products or services to customers in any EU member state?
• Does your company generate more than €2 million in annual turnover? (Micro-enterprises below 10 employees and €2 million turnover have limited exemptions. But most businesses are covered)
• Do you operate an e-commerce website, mobile application, or digital self-service platform accessible to consumers?

If you answered yes to any of these, the EAA applies to you. The technical standard you must meet is EN 301 549. It incorporates WCAG 2.1 Level AA as its baseline for web and mobile accessibility. In France specifically, compliance is assessed against the RGAA, which maps to WCAG 2.1 AA. However, it includes additional documentation and audit requirements.

Achieve Total, Not Partial, Compliance

The Carrefour ruling made it clear that partial scores do not protect you. Only full conformance does.

• All user-facing pages: Do not test just the homepage. Product pages, search, cart, checkout, account management, and help sections all need to be tested.
• Both website and mobile app: The Carrefour court order covered both carrefour.fr and the Carrefour mobile application.
• All transactional flows end-to-end: The ability to browse and select a product is not enough. The complete purchase journey must be accessible.
• Third-party embedded content: If you embed third-party payment processors, chat widgets, or promotional content, their accessibility is your legal responsibility too.

Go Beyond Automated Scanners

Automated scanners catch foundational issues quickly and at scale. But they cannot detect all barriers.

• Manual testing with assistive technologies: Test keyboard-only navigation through every core workflow. Test with screen readers including JAWS, NVDA, and VoiceOver on both desktop and mobile.
• Expert auditing against EN 301 549 or RGAA: An accessibility expert reviews not just what tools flag, but contextual issues that require judgment.
• User testing with people who have disabilities: This is what the disability organizations did to build their case against Carrefour. Blind users testing the platform found barriers no scanner would catch.

Maintain Continuous Monitoring

Accessibility is not a one-time fix. Every code deployment can introduce new barriers. Every content update can break what was previously correct. Compliance requires continuous vigilance.

This is where enterprise-grade platforms can help. A11yNow from BarrierBreak is designed for exactly this challenge. It is a continuous digital accessibility platform built to help enterprises monitor, improve, and sustain accessibility at scale.

• Automated scans with robust, regularly updated rulesets that reduce false positives and maintain coverage as standards evolve.
• Scheduled scans across websites and web applications, with comparison tools that track progress across multiple scan cycles.
• Issue tracking with severity ratings, code snippets, and step-by-step validation guidance, so developers can act on findings without specialist interpretation.
• Data-driven dashboards that give compliance managers a live view of their accessibility status across digital assets.
• Humans in the loop, including access to BarrierBreak's accessibility experts for contextual issue validation and manual testing.
• AI for efficiency, helping teams implement fixes faster and prioritize high-impact remediation work.
• Jira and GitHub integrations in the Enterprise plan, so accessibility issues flow directly into existing development workflows.

A11yNow makes EAA compliance an ongoing operational practice. This is critical when fines accrue daily for non-compliance.

Prioritize Core Accessibility Elements

When planning remediation, start with the barriers that directly prevent task completion. These are the issues most likely to form the basis of a legal complaint.

Prioritize issues based on the impact on users with disabilities.

Prepare to Respond to Formal Complaints

The Carrefour case began with formal legal notices. Organizations that responded to early notices with little meaningful progress ended up in court. Those that take complaints seriously and act quickly are in a far stronger position.

• Treat it as a legal document, not a customer service request. Route it immediately to legal, compliance, and your accessibility team.
• Do not dismiss partial progress as sufficient. The Carrefour ruling showed that a 71% score is legally indefensible.
• Engage directly with the complainant. Courts look at whether companies made genuine, good-faith efforts to address barriers.
• Document every remediation action with dates, scope, and outcomes. Evidence of systematic effort can influence the court's assessment of urgency and penalties.
• Set and publish a realistic remediation timeline. Vague promises without timelines did not help the French retailers.

Publish an Honest Accessibility Statement

Every organization subject to EAA digital accessibility compliance must publish an accessibility statement. In France, this is the Déclaration d'accessibilité, required in French, and must include a user feedback mechanism.

• Your current conformance level: Fully conformant, partially conformant, or non-conformant with EN 301 549 / WCAG 2.1 AA.
• Known barriers: A clear description of areas that are not yet accessible, with plans and timelines to fix them.
• A contact mechanism: A way for users to report accessibility barriers and request accessible alternatives.
• Date of last assessment: When the statement was last reviewed and updated.

Conclusion

The Carrefour ruling is the outcome of a company that received warnings and did not act. The formal notices came in July 2025 and the court order in June 2026. Nearly a full year passed, and the result was a court mandate with accumulating daily fines.

For every e-commerce business that sells to EU customers, that timeline is a lesson. The enforcement machinery is in place. Courts are interpreting EAA digital accessibility compliance strictly and without tolerance for partial scores. A lawsuit arrives without warning. But accessibility is a problem that can be identified and fixed before it becomes legal liability.

Do not wait for legal notice. Start improving accessibility now.