The European Accessibility Act (EAA, Directive (EU) 2019/882) became enforceable on June 28, 2025. One year on, the first enforcement actions have arrived — though confirmed monetary fines under national EAA-implementing laws remained rare. Early enforcement has centered on complaints, inspections, formal notices, market surveillance, and corrective-action deadlines rather than immediate penalties. The pattern so far is notice, then investigation, then required fixes, with fines as a later step. Two developments stand out: a French court order against Carrefour, and daily penalties in Norway.
What the EAA requires
The EAA sets accessibility requirements for a range of products and services sold in the EU, including e-commerce, banking, transport, and e-books. Its technical baseline is the harmonized standard EN 301 549, which incorporates WCAG 2.1 Level AA. There is a limited exemption for microenterprises providing services, but the reach is broad — and it is not confined to companies headquartered in Europe.
France: formal notices, then a court order
In November 2025, France’s DGCCRF — the consumer and competition authority — sent formal enforcement notices to four major retailers: Auchan, Carrefour, E.Leclerc, and Picard. Inspections had found systematic problems: keyboard-navigation failures, missing alternative text, and non-compliant checkout flows.
In June 2026, the Carrefour matter was heard, and a French court ordered Carrefour France to make both its e-commerce website and its mobile application fully accessible to people with disabilities within six months — under penalty of a fine for each day of delay. It has been described as an early EAA-era court ruling, and it underlines a key point: accessibility obligations extend beyond the website to the mobile app.
Norway: daily penalties
Norway’s equality and anti-discrimination authority imposed a daily penalty of NOK 50,000 — about EUR 4,500 per day — on the HelsaMi health portal operated by Norsk Helsenett, over persistent keyboard-accessibility failures. The case illustrates how the enforcement escalates: authorities generally issue a notice, investigate, and demand corrective action, with recurring daily penalties applied when problems persist.
The typical enforcement pattern is notice, then investigation, then corrective action — with fines as a later step, not a first resort.
A recurring theme: keyboard access
Across the French inspections and the Norwegian penalty, keyboard-navigation failures appear again and again — alongside missing alternative text and broken checkout flows. These are foundational, well-understood barriers, and they map directly to WCAG success criteria. A structured WCAG checklist helps teams catch exactly these issues before an inspector does.
What this means for you
If you sell to consumers in the EU, the EAA can apply to you — even if your company is based in the United States or elsewhere outside Europe. That is the single most important takeaway for non-EU businesses. E-commerce is squarely in scope, and the early enforcement has landed heavily on online retail.
- Confirm your exposure. If EU consumers can buy your products or use your services, assume the EAA is relevant and check whether the microenterprise exemption applies to you.
- Test the whole journey. The Carrefour order covered both website and mobile app. Cover your full purchase flow — browsing, search, cart, and checkout — on both surfaces.
- Fix keyboard access first. It is the most commonly cited failure and among the most straightforward to verify. Ensure every interactive element is reachable and operable by keyboard alone.
- Measure against EN 301 549 / WCAG 2.1 AA. That is the standard authorities are applying, so it is the standard to build and test toward.
For deeper background, see our overview of the European Accessibility Act and our reference on accessibility laws worldwide.
The bottom line
A year in, EAA enforcement is real but still ramping. Big fines under national implementing laws remain uncommon, yet the machinery — inspections, formal notices, court orders, and daily penalties — is clearly in motion, and it is reaching household-name retailers. Organizations that treat WCAG 2.1 AA as the working standard, test both web and mobile, and start with keyboard access will be well ahead of the enforcement curve.
This article is general information, not legal advice.