EAA enforcement is real: the Carrefour ruling and what it means for sellers

On 4 June 2026, a French court ordered Carrefour to make its website and mobile app fully accessible within six months, with a €500-per-day penalty for every day it misses the deadline. The court rejected Carrefour's defence that meeting 71% of France's accessibility standard was good enough, ruling plainly that an ecommerce site "cannot be only somewhat accessible; it must be totally accessible." This is genuine, binding enforcement, not a warning letter or a guidance document. It followed a different ruling a month earlier where a similar case against Auchan was dismissed, not because Auchan's site was accessible (it wasn't; the court itself found only 41% compliance), but on a narrow domestic revenue-threshold technicality that doesn't apply to most retailers. As of mid-2026, no EAA fine has actually been paid anywhere in the EU. What exists is something arguably more significant for a seller: a court willing to order compliance and start the clock on daily penalties.

What actually happened

Two French disability rights organisations, apiDV and Droit Pluriel, had spent roughly ten months trying to get Carrefour to fix accessibility problems on its grocery website and app before taking the matter to court. The case was heard as a référé, a fast-track French civil procedure used to stop an ongoing harm quickly, rather than a full trial working through every detail of the claim.

On 4 June 2026, the Tribunal judiciaire de Caen sided with the claimants. It ordered Carrefour France to make both carrefour.fr and its mobile app fully accessible to disabled customers within six months, a deadline that runs to roughly 4 December 2026, with a penalty (an astreinte) of €500 for every day it runs late after that. The legal basis was Article L.412-13 of the French Consumer Code, the provision that transposes the EAA into French law.

Carrefour didn't argue its site was already accessible. Its defence was that the site already met 71% of the criteria in the RGAA, France's official accessibility framework, itself based on WCAG 2.1 AA. The court rejected that argument directly, finding strong or major failures across 13 of the 19 sections tested, and stated plainly that an ecommerce site cannot be only somewhat accessible; it must be totally accessible.

Why this matters more than a fine would

It's tempting to look at this and think "no actual money changed hands yet, so it's not that serious." That reading misses the point. As of mid-2026, no company has actually paid a fine under an EAA-transposing law anywhere in the EU, this is genuinely still true, and worth being accurate about rather than overstating. But the Carrefour order is arguably a stronger enforcement signal than a one-off fine would be, for a few reasons:

• It's a binding court order, not a warning. This isn't a regulator sending a letter asking a business to explain itself. It's a court that heard both sides and ordered specific, court-enforced remediation with a deadline attached.
• The daily penalty structure is designed to bite. €500 a day sounds modest as a single figure, but it accrues for every day past the deadline, a slow-moving compliance project becomes an actively worsening financial problem the longer it drags on.
• "Partial compliance" was explicitly rejected as a defence. A business that's made real, honest progress but hasn't finished the job doesn't have a middle-ground legal position here, at least on this court's reading. That's a meaningfully different standard from "we're working on it."
• It covers a mobile app as well as a website, treating both as one obligation with one deadline, a reminder that EAA scope isn't limited to your website if you also operate an app.

The Auchan contrast: why "one dismissed case" doesn't mean "nothing to worry about"

A month before the Carrefour ruling, the same two organisations brought a very similar case against Auchan's e-commerce subsidiary, and lost. It's worth understanding exactly why, because the honest reason is easy to misread as "the site was fine."

On 5 May 2026, the Tribunal judiciaire de Lille dismissed the case against Auchan, but not on accessibility grounds. The court's own finding was that Auchan's site was only 41% compliant with the RGAA, with the judge separately noting Auchan's apparent lack of real engagement with accessibility as a major online retailer. The case was dismissed because of a threshold conflict in how French domestic law interacts with the EAA: an older French law (from 2005) applies its own obligations only to companies with turnover above €250 million, and Auchan's e-commerce subsidiary reported around €144 million, below that domestic threshold, even though it's comfortably above the EAA's own, much lower, €2 million microenterprise exemption line.

In other words: Auchan won on a jurisdictional technicality specific to one part of French domestic law, not because its site met the standard. The court didn't rule the site was accessible, it ruled that one particular French law didn't reach that specific entity. apiDV and Droit Pluriel have appealed the decision to the Court of Appeal of Douai, arguing the reading conflicts with the EAA's own EU-wide scope. That appeal is still pending.

This threshold argument, even if it survives appeal, has no relevance for the vast majority of ecommerce businesses reading this. It's a narrow reading of one French domestic revenue threshold, not a general EAA size exemption, the EAA's own, genuine size exemption is for microenterprises under 10 employees and €2 million turnover, a completely different and much lower bar. If your business is above that threshold and sells into the EU, the Auchan outcome isn't a template you can rely on.

What this means in practice for an ecommerce seller

You don't sell in France specifically, and this was a French court applying French domestic procedure, so what does it actually change for you?

The direction of travel matters more than the jurisdiction. This is the clearest sign yet that EAA enforcement isn't staying theoretical. Civil society organisations, not just government regulators, can and will bring cases, and at least one French court has shown it's willing to engage seriously with the substance rather than accept partial compliance as good enough.

"We're mostly compliant" is not a safe position to rest on. Carrefour's 71% defence is the most directly transferable lesson here. A genuinely substantial compliance effort was explicitly found insufficient. If your own approach to accessibility has been "we've fixed the obvious stuff," this ruling is a concrete reason to treat that as a starting point, not a finish line.

More cases from the same claimants are already moving. The same organisations have further cases in progress against other major French retailers, with hearings scheduled through the rest of 2026. This isn't a single isolated case, it's an active, ongoing enforcement effort, and the pattern of outcomes will keep developing.

This is separate from, and doesn't replace, the UK's Equality Act. If you sell to UK customers, the Equality Act 2010's anticipatory reasonable-adjustments duty already applies to you regardless of size, and has done since 2010, see our guide on EAA vs UK Equality Act 2010 for how the two interact. The Carrefour ruling is EAA/EU-side evidence that enforcement is real; it isn't the whole picture of your legal exposure.

What to actually do with this

Don't read this guide and conclude you need a French lawyer. Read it as a concrete, current example of what "not compliant enough" can look like even for a business that's made real effort, and use it as a reason to find out, honestly, where your own site actually stands, rather than assuming a partial effort is sufficient.

It's automated, so, like any scanner, it will miss the majority of what genuinely blocks a disabled customer. For an honest, complete picture, our manual audit tests your actual site by keyboard and screen reader across your real purchase journey.

See what's included in our audits, from £350

Frequently asked questions

Has any business actually been fined under the EAA?

Not as of mid-2026, as far as public records show. The Carrefour order is a forward-looking remediation order with a daily penalty that starts accruing only if the deadline is missed, it isn't a sanction for past conduct, and no company has yet paid a fine under an EAA-transposing law anywhere in the EU. That said, the daily-penalty structure means this could change quickly if Carrefour doesn't meet its December 2026 deadline.

Does the Auchan case mean smaller retailers are safe?

No, and it's specifically not that kind of case. Auchan's dismissal turned on a narrow French domestic revenue threshold (€250 million) that's separate from and far higher than the EAA's own microenterprise exemption (10 employees and €2 million turnover). The court didn't find Auchan's site accessible, it found only 41% compliance, it simply ruled that one specific French law didn't apply to that entity. That reasoning is under appeal and has no bearing on the EAA's actual, much lower size exemption.

Does this ruling apply to my business directly?

Not as a direct legal precedent, it's a French court ruling under French procedure. Its relevance to a seller is as evidence of how EAA enforcement is actually playing out in practice: civil society groups bringing real cases, courts engaging with the substance, and partial compliance being explicitly rejected as a defence.

What if I've made real progress but I'm not fully WCAG compliant yet?

Genuine progress is meaningfully better than none, and most businesses are working toward compliance rather than arriving instantly. The Carrefour ruling's lesson isn't "don't bother unless you're perfect," it's that a self-assessed partial percentage isn't a legal safe harbour, so ongoing, honest work and a documented, dated position (see our guide on writing an accessibility statement) matters more than being able to cite a completion percentage.

Where can I read more about ongoing EAA enforcement cases?

Further cases from the same French organisations are scheduled through the rest of 2026, and other EU member states are at earlier stages of their own enforcement activity. This is a developing area, treat any single ruling, including this one, as a snapshot of where things stood at the time rather than a final, settled picture.