The European Accessibility Act has applied to new products and services since 28 June 2025. One year later, the question we hear most from app and web teams is simple: has anyone actually been enforced against? The honest answer is that no fine under an EAA-transposing law has been reported anywhere in the EU, but the machinery has started to move, and the first court decisions tell you a lot about how the rules will be read.

France: the courts move first

The most consequential enforcement so far has come from disability associations rather than regulators. Droit Pluriel and ApiDV, supported by the lawyers’ collective Intérêt à agir, brought proceedings against four French grocery retailers over the accessibility of their online shopping services.

On 5 May 2026 the Lille court dismissed the case against Auchan’s e-commerce subsidiary on scope. The French decree implementing the 2005 disability law applies its web accessibility duty to companies with average turnover above 250 million euros, and the subsidiary’s 2024 turnover was 144 million euros. The associations have appealed to the Douai court of appeal.

On 4 June 2026 the Caen court reached the opposite result against Carrefour France. It ordered the company to make carrefour.fr and its mobile app fully accessible within six months, with a penalty of 500 euros for every day of delay after that. Carrefour’s site had been assessed as 71 per cent accessible. The judge’s reasoning, in translation, was that an e-commerce site “cannot be just a little accessible, it must be totally accessible”. The order relied on article L.412-13 of the French consumer code, which is where France transposed the EAA’s e-commerce obligations and which applies to online retailers above a 2 million euro turnover threshold, alongside the older 2005 law.

Two points stand out. First, the court treated the mobile app as squarely in scope. Second, a partial conformity score was not a defence. Coverage in Faire Face and Handicap.fr has the detail. Both decisions are first-instance and open to appeal.

Regulators: investigations, not yet penalties

  • Sweden. In October 2025 the telecoms regulator PTS opened 28 investigations into e-commerce websites on its own initiative, with no complaint needed. No decisions have been published.
  • Netherlands. The consumer and markets authority ACM required in-scope businesses to self-report by 15 October 2025 and has been auditing companies that did not. Again, no published decisions.
  • Germany. The federal market surveillance body for accessibility in Magdeburg has been operating since 26 September 2025 and has taken no public action. The warning letters that circulated in 2025 came from private law firms.
  • Ireland. ComReg is processing complaints, including a publicised one against a mobile operator in December 2025. Irish law provides for criminal penalties but none has been used.
  • Italy. AgID published private-sector compliance guidelines on 4 March 2026.

The one monetary penalty in the wider European Economic Area, a daily fine against a Norwegian health portal in December 2025, was issued under Norway’s older domestic law rather than the EAA, and the portal fixed the problem within days. A running tally by Auditsu tracks these cases. It is a vendor source and worth cross-checking, but it cites the court and regulator documents.

What this tells you

  1. Scope thresholds are being litigated. Which law applies, and which turnover test, decided the Lille case. Know which national transposition covers you and keep the evidence for your microenterprise or disproportionate burden position if you rely on one. The lesson Exemptions and disproportionate burden covers how.
  2. “Mostly accessible” is not the standard. The EAA’s requirements are functional and binary. A 71 per cent score sounds like progress to a product team and reads as non-compliance to a judge.
  3. Apps are in. If your service has an app, the app is part of the service.
  4. Enforcement is complaint-driven and association-driven. The feedback mechanism the EAA requires is not a formality. A complaint you answer well is one that does not reach a regulator or a court.
  5. The standard is about to change. EN 301 549 V4.1.1, which moves the baseline to WCAG 2.2 and maps the standard to the EAA in a new annex, is in its final approval vote at ETSI, CEN and CENELEC and is expected to be published later this year. Audits against WCAG 2.1 will need topping up.

Try it this week

Use Accessibility Checker to generate a draft accessibility statement for one service and compare what you can honestly say against what the EAA’s Annex V asks you to disclose. Then work through EAA obligations and An EAA compliance workflow.

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