European Accessibility Act (Directive (EU) 2019/882)
What the European Accessibility Act actually requires of you
A plain reading for people who have to make a decision this quarter. This is context, not legal advice.
Who it applies to
Directive (EU) 2019/882 has applied to services placed on the EU market since 28 June 2025. It is transposed into national law in each Member State, so the penalties and the enforcing body differ, but the technical requirement does not.
Services in scope include:
- E-commerce — Any business selling goods or services to consumers online
- Consumer banking — Consumer banking services, and the interfaces used to access them
- E-books — E-books and the dedicated software used to read them
- Telecoms — Electronic communications services
- Passenger transport — Passenger transport information, ticketing and booking
- Media access — Access to audiovisual media services
The exemption people reach for first is the microenterprise one, and it is narrower than expected: Fewer than 10 employees AND annual turnover or balance sheet total not exceeding €2 million. Both limbs must be satisfied, and it applies to services — not to products.
What "accessible" means in practice
The Act sets functional requirements rather than a technical specification. Conformity is presumed where you meet the harmonised standard, EN 301 549 v3.2.1, whose clause 9 adopts WCAG 2.1 level AA for web content. In practice, if a tester runs WCAG 2.1 AA against your site, that is the assessment.
There is no partial credit. A success criterion is met or it is not, on the page in question, for the task in question. This is the point on which the Carrefour defence failed.
What enforcement looked like in 2026
| Where | Who | What is happening |
|---|---|---|
| Sweden | PTS (Post- och telestyrelsen) | Running systematic e-commerce inspections throughout 2026. |
| Netherlands | Market surveillance authorities | Prioritised businesses that failed to report for audit in spring 2026. |
| France | Courts / DGCCRF | Private enforcement now proven viable after the Carrefour ruling. |
Typical sequence for a non-large company: an inspection or a complaint, a finding, then a remediation notice with roughly 90 days to comply. Fines in the €5,000 – €40,000 range follow non-compliance with the notice rather than the original failure. The expensive part is rarely the fine — it is rebuilding a checkout under a deadline you did not choose.
The Carrefour ruling, and why it matters more than the fines
On 4 June 2026, the Caen Judicial Court (Tribunal judiciaire de Caen), France held that Carrefour was liable for an inaccessible online grocery service. Carrefour was found liable for an inaccessible online grocery service. The court ordered carrefour.fr and the mobile app made fully accessible within six months, under a €500 per-day penalty, plus €10,000 in damages.
Carrefour argued it already met 71% of the French RGAA criteria. The court rejected that outright. Partial accessibility is not a defence.
Two things changed that day. First, a private claimant obtained an injunction with a daily penalty — no regulator required, no waiting for an inspection cycle. Second, the "we are substantially compliant and improving" position was tested in court and lost. If you are holding a conformance percentage from an agency, that is now a document that describes your exposure rather than limits it.
What a defensible position looks like
- A dated record of testing. What was tested, against which standard, on which date, by whom.
- A prioritised remediation plan with owners and dates — evidence of a programme, not an intention.
- An accessibility statement that is accurate, current, and honest about known gaps.
- A feedback mechanism users can actually reach, and a record of how you responded.
- Regression control. Fixes that survive the next deploy. This is the part almost everyone skips, and it is why compliance is a state rather than an event.
A free scan gets you the first item in about five minutes. The rest is work — some of which you can do yourself with the report in hand.
EU Conformance Hub provides technical conformance testing and remediation services. Nothing on this site or in our reports constitutes legal advice. Enforcement, penalties and exemptions vary by Member State — consult qualified counsel in your jurisdiction.