EAA enforcement in France: DGCCRF fines and the first court cases

Which law applies

France transposed the Act with Law 2023-171 of 9 March 2023, completed by Ordinance 2023-859 and Decree 2023-931. The duty for e-commerce sits in the Code de la consommation: Article L.412-13 sets the obligation, Articles D.412-49 to D.412-62 the detail, and Article R.451-4-I the sanction (DGCCRF fact sheet, July 2025).

The Directive exempts microenterprises that provide services: fewer than 10 staff and an annual turnover or balance sheet total of EUR 2 million or less (Article 4(5)). Both conditions have to hold. Everyone above that line who sells to consumers online is in scope from 28 June 2025. The DGCCRF fact sheet confirms that microenterprise service providers have no accessibility obligation at all.

A second, older rule also exists: Article 47 of the 2005 disability law, which covers public bodies and companies with turnover above EUR 250 million and is policed by Arcom, with fines up to EUR 50,000 (Banque des Territoires). The two tracks are easy to mix up, and one court already has (see Auchan below).

The Act itself describes outcomes (perceivable, operable, understandable, robust) rather than naming WCAG. In practice authorities and courts measure websites against the harmonised European standard EN 301 549, whose web chapter in version 3.2.1 maps to WCAG 2.1 level AA. Working to WCAG 2.2 AA covers those criteria plus the six new level A and AA criteria WCAG 2.2 added. French practice also uses the national RGAA criteria, which are built on the same WCAG base.

Who enforces it for online shops

The DGCCRF (Direction générale de la concurrence, de la consommation et de la répression des fraudes) controls e-commerce accessibility, with sector regulators covering telecoms, media and finance (DGCCRF fact sheet). It works through planned inspection campaigns and consumer reports.

How a complaint reaches a shop

• SignalConso. Consumers report an inaccessible site through the DGCCRF's SignalConso platform, which added a dedicated accessibility route covering companies with 10 or more staff and over EUR 2 million turnover (economie.gouv.fr).
• Associations in court. Disability associations can go straight to a judge for an urgent order, without waiting for the DGCCRF. That is what happened to Auchan, Carrefour, E.Leclerc and Picard.

Fines and other sanctions

Under Article R.451-4-I of the Code de la consommation a breach is a fifth class offence: up to EUR 7,500 for a company, EUR 15,000 on a repeat, and EUR 1,500 or 3,000 for an individual. The fine applies per service and per obligation breached, so a site, an app and a customer portal are three exposures (DGCCRF fact sheet).

Higher figures you may see online, such as EUR 50,000 per service or EUR 25,000 for a missing accessibility statement, belong to the separate Article 47 track for very large companies and public bodies (Banque des Territoires), not to ordinary shops under the EAA.

The bigger cost in practice has come from judges: an order to make the service fully accessible, enforced by a daily penalty payment (astreinte).

What has actually happened so far

• 7 July 2025, formal notices. The associations apiDV and Droit Pluriel, with the legal collective Intérêt à Agir, put Auchan, Carrefour, E.Leclerc and Picard Surgelés on notice to make their grocery sites accessible by 1 September 2025 (informations.handicap.fr).
• 12 November 2025, urgent proceedings. The associations filed for urgent court orders against all four (Intérêt à Agir).
• 5 May 2026, Auchan wins in Lille. The Lille court dismissed the claim because Auchan's e-commerce company, with about EUR 144 million turnover in 2024, sat below the EUR 250 million threshold of the older 2005 law, which the court treated as decisive (informations.handicap.fr, 7 May 2026). The associations call this a misreading of the EAA and announced an appeal to the Douai court of appeal (Le Journal des Entreprises). No appeal ruling had been reported by 1 October 2026.
• 4 June 2026, Carrefour loses in Caen. The Caen court ordered Carrefour France to make its website and app fully accessible within six months, under a daily penalty. Carrefour argued it met 71% of the criteria; the court answered that the site "cannot be only a little accessible, it must be fully accessible" (Intérêt à Agir, informations.handicap.fr). A specialist site reports the penalty at EUR 500 a day and EUR 10,000 in provisional damages (auditsu); we could not confirm those amounts in the press coverage we checked.
• E.Leclerc and Picard. The E.Leclerc hearing in Créteil was postponed to 22 September 2026 (Faire Face); no ruling had been reported by 1 October 2026. Picard said it had opened talks with the associations and planned a corrective action plan (France 3); no ruling found.
• No published DGCCRF fine against a named shop was found as of 1 October 2026.

What to do if you sell into France

If you sell to consumers in France and you are above the microenterprise line, the defensible position is the same as everywhere else in the EU: fix the barriers in your own code, keep dated evidence of what you tested and changed, and publish the accessibility information the law asks for.

1. Scan your key templates (home, category, product, cart, checkout, account) for the failures a script can verify. Our free scan does this for up to 10 pages.
2. Test the purchase journey with a keyboard only and with a screen reader. A script cannot judge whether alt text makes sense or a checkout error is announced.
3. Fix the issues in the theme or codebase, not with an overlay widget. Overlays vs code fixes explains why.
4. Publish the service information the Act requires, in an accessible format. See what an EAA accessibility statement must contain.
5. Re-test after every redesign, theme update or new app, and keep the reports.

A Fix Sprint covers steps 1, 2, 3 and 5 for a fixed price. None of this is legal advice, and no audit can promise that a regulator or court will agree with it. It is the work that makes a complaint easy to answer.