7 min read
The European Accessibility Act became enforceable on 28 June 2025. In the months since, enforcement has moved from guidance documents and press releases to regulatory inspections, court filings, and a landmark ruling that explicitly rejected partial compliance as a defence.
If you sell digital products or services to customers in the EU, this guide covers what the EAA actually requires, what enforcement looks like in practice, and what the early cases tell us about the risk of doing nothing.
Who the EAA applies to
This is where many businesses make their first error. The EAA is not limited to companies based in the EU. It applies to any business selling digital products or services into the EU market, regardless of where that business is headquartered.
That means a UK retailer with EU customers, a US SaaS company with European subscribers, or an Australian e-commerce brand shipping to Germany. If your service is accessible to EU consumers, the EAA has a view on how accessible that service needs to be.
There are some exemptions. Micro-enterprises (fewer than 10 employees and annual turnover under €2 million) selling services are excluded, though not those selling products. But for most businesses of any meaningful scale, the EAA applies.
What the EAA actually covers
The EAA is broader in scope than many UK and US accessibility frameworks. It covers not just websites but e-commerce platforms, mobile apps, banking and financial services, transport booking systems, e-readers, and digital television services. The technical standard it maps to is WCAG 2.1 Level AA, the same benchmark used across the US, UK, and wider Europe.
In practical terms, this means your checkout flow, your mobile app, your customer account portal, and your product search are all in scope — not just your homepage. Accessibility is required across the entire user journey, not just the front door.
What enforcement looks like in practice
The four countries generating the most enforcement activity right now are Sweden, the Netherlands, France, and Germany. Each has taken a slightly different approach, and together they give a clear picture of what the enforcement machine looks like in motion.
Sweden
Sweden's Post and Telecom Agency (PTS) completed its first wave of formal inspections in Q4 2025 and issued 23 formal notices to e-commerce operators. Companies receive a 60-day remediation window, after which follow-up inspections are carried out. PTS has published a list of 200 e-commerce platforms it intends to audit by Q3 2026.
Alongside regulatory action, PTS has received 124 public complaints from consumers — a figure that matters, because it shows the public is aware of their rights and prepared to use them. The maximum penalty in Sweden is SEK 10 million, approximately €900,000.
The Netherlands
The Dutch Authority for Consumers and Markets (ACM) has prioritised companies that failed to submit compliance reports or submitted incomplete ones. It has sent information requests to e-commerce operators worldwide — including those headquartered outside the EU — and formal enforcement is expected in the second half of 2026.
The Netherlands has positioned itself as one of the toughest enforcers in the bloc. Maximum fines are €900,000 or 10% of annual revenue, whichever is higher. For a mid-sized business, the revenue-based calculation is the one to watch.
France and the Carrefour ruling
France has produced the most significant development in EAA enforcement to date, and it came not from a regulator but from a court.
In July 2025, two disability advocacy organisations sent formal legal notices to four major grocery retailers: Auchan, Carrefour, E. Leclerc, and Picard Surgelés. When the retailers did not comply, emergency injunctions were filed in November 2025. On 4 June 2026, the Caen Judicial Court issued the first court ruling under the EAA, finding Carrefour liable for the inaccessibility of its online grocery service.
The ruling is worth reading carefully. Carrefour presented evidence that its site met 71% of France's official accessibility criteria. The court's response was direct: 71% accessible is a strange way of saying inaccessible. The court held that the standard is total accessibility, not partial progress toward it.
The case was brought by disability advocacy organisations, not a regulator. This matters because it confirms that civil action under the EAA is not limited to public authorities. Any disability organisation or consumer body can bring a case.
Germany
Germany deserves separate attention because its enforcement model is structurally different. The German implementation of the EAA includes a mechanism called Abmahnung, which allows private parties — including competitors and consumer organisations — to issue cease-and-desist notices without going through a regulator. This private-sector enforcement mechanism has already produced more EAA enforcement actions than any other EU country. The formal fine ceiling is €100,000, but the private route moves faster and at scale.
What the Carrefour ruling changes for compliance strategy
Before the Carrefour ruling, a common approach to EAA compliance was to demonstrate measurable progress. Run an automated scan, fix the obvious issues, document the work, and present that as a good-faith effort.
The ruling makes that approach significantly riskier. A court has now stated explicitly that partial compliance is not a defence. The question is not whether you have made progress. It is whether a disabled user can actually use your service.
This brings the EAA in line with how accessibility has always worked in practice. Automated scanning tools typically catch around 30% of accessibility issues. A site that scores well on automated checks can still be largely unusable for a blind user relying on a screen reader, or a motor-impaired user navigating by keyboard only. The Carrefour case is a reminder that a percentage score is not the same as an accessible service.
What your actual compliance risk looks like
The risk varies by country, by the nature of your service, and by how visible your non-compliance is. But some things are consistent across the enforcement landscape so far.
Regulators are starting with the most obvious targets: companies that have not submitted compliance reports, businesses that received complaints and did not respond, and large-scale e-commerce operators with significant disabled user bases. If your business fits any of those descriptions, the probability of being contacted is higher than it was a year ago.
The soft-landing window — where regulators issue a notice and allow time to remediate before imposing a penalty — is real, but it is narrowing. Sweden's first wave of notices did not result in immediate fines. The second wave, following up on those 23 cases, will be a different conversation for organisations that have not acted.
For UK businesses specifically: the EAA does not require you to be based in the EU. If you have EU customers, the EAA applies to those transactions. The UK Equality Act remains separately in force for UK customers. You may be operating under both frameworks simultaneously.
What to do about it
The starting point is an accurate picture of where your service actually stands. Not an automated scan score. Not a developer's assessment. An honest evaluation of whether a disabled user — someone using a screen reader, navigating by keyboard, relying on captions — can complete the core tasks your service is built around.
A manual accessibility audit mapped against WCAG 2.1 AA will tell you what is broken, how severe each issue is, and what to fix first. From there, you need a remediation plan that is realistic for your team to execute and a way to test that the fixes actually work for real users.
The Carrefour case is not a reason to panic. It is a reason to understand your position before someone else defines it for you.
Where to start
If you are unsure whether the EAA applies to your business, or you know it does and want to understand what your current exposure looks like, get in touch. We carry out manual accessibility audits for businesses across the UK and Europe, and we will give you a straight answer on where you stand.
Sources
- Deque: Early Signs of EAA Enforcement Across Europe
- Snellman Digital Compliance Tracker: Swedish PTS First Market Surveillance
- Eye-Able: First EAA Lawsuits Hit French Grocery Retailers (2025)
- LI Solutions: First European Accessibility Act Court Ruling (June 2026)
- BarrierBreak: Carrefour EAA Ruling — What It Teaches Businesses
- BarrierBreak: Netherlands ACM Accessibility Reporting Rules
- Web Accessibility Checker: EAA Fines by Country (2026)
- Level Access: EAA Compliance in 2026 — How Enforcement Has Evolved
- Taylor Wessing: The EAA Takes Shape
