{"id":8596,"date":"2026-08-04T22:30:14","date_gmt":"2026-08-04T22:30:14","guid":{"rendered":"https:\/\/dextora.agency\/?post_type=insight&p=8596"},"modified":"2026-08-04T22:30:14","modified_gmt":"2026-08-04T22:30:14","slug":"european-accessibility-act-first-year-enforcement","status":"publish","type":"insight","link":"https:\/\/dextora.agency\/en\/insights\/european-accessibility-act-first-year-enforcement\/","title":{"rendered":"A Year of the European Accessibility Act: Carrefour Under a Daily Penalty, German Warning Letters, Swedish Audits"},"content":{"rendered":"

The obligations of the European Accessibility Act started applying on 28 June 2025. For the first eleven months the enforcement picture was mostly speculation, some of it sold by vendors with an overlay to license. It stopped being speculation on 4 June 2026, when a French court ordered one of Europe’s largest retailers to make its shopping site and app fully accessible within six months, under a coercive penalty running per day of delay.<\/p>\n

The decision is worth reading carefully, because the single most repeated sentence about it in trade coverage is wrong, and because the reasoning transfers directly to any online shop above the national turnover thresholds.<\/p>\n

What the Caen court actually ordered<\/h2>\n

The claimants were two disability organisations, apiDV and Droit Pluriel, supported by the lawyers’ collective Interet a Agir. The sequence, from their own published statements, runs like this.<\/p>\n\n\n\n\n\n\n\n\n\n
Date<\/th>\nStep<\/th>\n<\/tr>\n<\/thead>\n
28 June 2025<\/td>\nThe accessibility obligation for online commerce starts applying in France<\/td>\n<\/tr>\n
7 July 2025<\/td>\nFormal notices sent to four retailers: Auchan, Carrefour, E. Leclerc and Picard Surgeles<\/td>\n<\/tr>\n
November 2025<\/td>\nAll four summoned in urgent interim proceedings, announced on 12 November<\/td>\n<\/tr>\n
5 May 2026<\/td>\nLille dismisses the claim against Auchan’s e-commerce subsidiary on turnover grounds; appeal lodged in Douai<\/td>\n<\/tr>\n
4 June 2026<\/td>\nCaen orders Carrefour France to make carrefour.fr and the Carrefour app fully accessible within six months<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

The claimants’ account of the Caen decision<\/a> records that Carrefour never disputed being subject to the obligation. Its defence was that it already satisfied 71% of the criteria of the French RGAA reference framework. The judge’s answer is the line the case will be remembered for: the e-commerce site concerned cannot be only somewhat accessible, it has to be accessible entirely. Accessibility is treated as an obligation of result. If a company chooses to measure itself against the RGAA, then 100% of the applicable criteria have to be met, in the same way that 100% of the steps of a staircase have to be covered by a ramp.<\/p>\n

The daily amount is reported as EUR 500 per day of delay by the specialist disability press, in particular Faire Face’s report on the ruling<\/a>. The claimants’ own statement confirms the six-month deadline and the existence of the penalty without naming the figure, so treat the number as well-sourced journalism rather than as text you have read in the judgment.<\/p>\n

An astreinte is not a fine, and the difference matters commercially<\/h2>\n

Almost every English-language summary called this a fine. It is not one. An astreinte is a coercive measure in French civil procedure: an amount that accrues per day until the ordered act is performed. Three consequences follow, and they change how the risk should be modelled.<\/p>\n