The European Accessibility Act, one year in: enforcement is real

The European Accessibility Act became enforceable on June 28, 2025, and one year in, enforcement is no longer theoretical. A French court has ordered Carrefour to make its website and app fully accessible under threat of daily fines, Norway's regulator is charging a health portal 50,000 kroner per day, and market-surveillance authorities in Germany, Sweden, the Netherlands, Ireland, and Poland have moved from setting up offices to opening cases.

Here's what has actually happened since the deadline, with sources you can check.

What the EAA covers, briefly

The EAA (Directive (EU) 2019/882) sets accessibility requirements for products and services the EU considers most important for people with disabilities: e-commerce, banking, e-books, telecoms, passenger transport, and hardware like smartphones, computers, and self-service terminals (European Commission).

The obligations have applied to new products and services since June 28, 2025. There are real carve-outs, but they're narrower than most teams assume: microenterprises (fewer than 10 staff and at most €2 million turnover) are exempt from the service requirements only, and pre-existing service contracts get a transition that runs out on June 28, 2030 (Taylor Wessing). If you run an online store, a banking product, or a booking flow for EU consumers, you should assume you're in scope.

France: from formal notices to a court order

France has produced the clearest enforcement story so far — driven by disability organizations using the courts.

In July 2025, two weeks after the deadline, the associations ApiDV and Droit Pluriel sent formal legal notices to four of France's largest grocery retailers — Auchan, Carrefour, E. Leclerc, and Picard — over the inaccessibility of their online shopping services (Law Office of Lainey Feingold). The failures cited were basic and testable: sites that couldn't be used with a screen reader, navigation that was impossible without a mouse, and click-and-collect flows blind users couldn't complete (Inclusive Web). When progress stalled, the organizations escalated to court filings for interim relief in November 2025 (Deque).

On June 4, 2026, the Tribunal judiciaire de Caen ruled against Carrefour, ordering it to make carrefour.fr and its mobile app fully accessible within six months, with daily fines accruing after that (Deque). The most important part of the ruling is what the judge rejected: Carrefour argued it already met 71% of the criteria in the RGAA, France's accessibility standard. The court's answer — the e-commerce site "cannot just be somewhat accessible; it must be totally accessible."

A parallel case against Auchan was dismissed in May 2026 on scope grounds and is under appeal (Deque), so French case law is still forming. But the Carrefour ruling stands as the first major court decision under the EAA era, and its message is blunt: partial conformance is not a defense.

Norway: daily fines, running now

Norway isn't an EU member, but it enforces equivalent accessibility rules through its ICT regulations, with WCAG as the technical baseline (Uutilsynet).

In late 2025, the Authority for Universal Design of ICT concluded an inspection of HelsaMi, a patient portal used by roughly 425,000 people in Mid-Norway, and found 119 accessibility errors across 12 of 14 legal requirements. When the remediation deadline passed with 64 issues still open, the authority ordered the remaining problems fixed by December 19, 2025 — or a penalty of NOK 50,000 per day until they are (UsableNet).

That's the enforcement shape to internalize: inspection, a concrete error list, a deadline, then an automatic daily meter. Not a negotiation.

Monitoring is ramping up across the rest of Europe

• Germany. The federal states' joint market-surveillance authority for accessibility (MLBF), based in Magdeburg, has operated since June 28, 2025. It inspects on a random basis and in response to complaints, and Germany's BFSG allows fines up to €100,000, with the ultimate option of prohibiting a non-compliant service (Härting Rechtsanwälte). Germany also has a second enforcement track: competitors' law firms began sending unfair-competition warning letters to e-commerce operators within weeks of the law taking effect (Level Access). And in December 2025, the German BIK audit methodology formally rejected overlay widgets as a path to conformance (Lainey Feingold) — consistent with what the broader record shows about overlays.
• Sweden. The Post and Telecom Authority (PTS) opened its first inspection cases in October 2025, covering both devices and e-commerce services, and reports 124 public complaints — 110 about services, mostly e-retail websites (Level Access).
• Netherlands. The consumer and markets authority (ACM) required companies to report their compliance status by October 15, 2025, and is prioritizing audits — starting with companies that didn't reply at all (Deque).
• Ireland. ComReg has begun processing consumer accessibility complaints, including a formal complaint against Three, Ireland's largest mobile operator (Deque).
• Poland. The transposition act has been in force since June 28, 2025, with the President of PFRON empowered to run inspections and take complaints, and monitoring activity beginning in 2026 (Quertum).

The pace differs by country, but the direction is the same everywhere: registration and guidance phases are over; casework has started.

What enforcement looks like in practice

Across every case above, enforcement started with something visible from the outside — a regulator reviewing your public pages, a user filing a complaint, an advocacy group testing your checkout with a screen reader, or a mandatory report you did or didn't file. Nobody needs your permission to evaluate your site, and the failures cited so far (keyboard traps, missing labels, inaccessible checkout) are exactly the kind that automated and semi-automated review finds quickly.

Then comes a notice with a deadline. Only after that deadline passes do fines start — which means the window between "regulator noticed" and "money is owed" is the window in which a documented, moving remediation program matters most. The Netherlands has been explicit that its approach targets companies that don't engage; Norway's daily fines kicked in only after a missed remediation deadline.

What to do now

1. Test what a regulator would test. Your public funnels first: home page, search, product or service pages, checkout or signup. Run an automated WCAG scan, then verify keyboard-only and screen-reader paths through the money flow. Our accessibility guides cover the most common failure patterns, including platform-specific issues for online stores.
2. Fix at the source, worst-first. The failures named in the French notices — screen-reader breakage, mouse-only navigation, inaccessible checkout — are the ones to clear before anything cosmetic.
3. Don't stop at a percentage. The Carrefour court rejected 71% conformance as a defense. Treat any open, applicable criterion as open risk.
4. Keep the record. Scan results, tickets, fixes, re-scans, and an accurate accessibility statement. In a notice-and-deadline system, demonstrated progress is the difference between a correction order and a daily fine.

This is the workflow BugPort is built for: automated scans that find real WCAG failures on your actual pages, findings that become tickets with element-level evidence your developers can act on, and a re-scan history that documents remediation over time. It won't make you "compliant" — no tool can promise that — but it makes the find-fix-verify loop fast and auditable. You can run a free WCAG audit on your site today.

This article is for general information only and is not legal advice. For decisions about your own compliance obligations, talk to a qualified lawyer in the relevant jurisdiction.

FAQ

Is the EAA actually being enforced?

Yes. The first year produced a French court order against Carrefour with daily fines attached (Deque), running daily penalties in Norway (UsableNet), and active inspections or complaint handling in Germany, Sweden, the Netherlands, and Ireland. Enforcement intensity varies by country, but "nobody is checking" stopped being true in 2025.

Does the EAA apply to companies outside the EU?

The EAA regulates products and services offered on the EU market, not where the provider is incorporated. If you sell covered services — e-commerce, banking, e-books, and the rest — to consumers in the EU, plan on being in scope, and confirm specifics with counsel.

What technical standard do regulators test against?

The harmonized European standard EN 301 549, which incorporates WCAG 2.1 Level AA for web content and extends similar requirements to apps, documents, and hardware (Deque). In practice, testing your site against WCAG 2.1/2.2 AA covers the web-facing core of what an inspector will look at.

Is "mostly accessible" good enough?

The one court that has ruled on this question said no: Carrefour's claim of 71% RGAA conformance was rejected, with the judge requiring the service to be "totally accessible" (Deque). Treat partial conformance as a milestone, not a destination.