EAA compliance in France — what businesses need to know

The European Accessibility Act became enforceable in France on 28 June 2025 under LOI n° 2023-171, France’s transposition of Directive 2019/882. France is not a new entrant to digital accessibility regulation — RGAA had applied to the public sector since 2012 — but the EAA extended binding obligations to a wide range of private-sector organisations for the first time. Any organisation providing covered digital products or services to consumers in France is in scope, regardless of where the organisation is headquartered.

The French legal framework

The transposition of the EAA into French law was completed through three instruments: LOI n° 2023-171 (9 March 2023), Ordonnance n° 2023-859 (6 September 2023), and Décret n° 2023-931 (9 October 2023). Together these define the technical requirements, the scope of covered services, and the enforcement mechanisms.

France’s technical standard is the RGAA 4.1 (Référentiel Général d’Amélioration de l’Accessibilité), which operationalises WCAG 2.1 Level AA into 106 verifiable criteria. Meeting WCAG 2.1 AA via RGAA 4.1 is the path to French EAA compliance. EN 301 549, the harmonised European standard referenced by the EAA, and RGAA 4.1 are closely aligned.

The scope of covered services in France includes e-commerce, banking and financial services, electronic communications, audiovisual media services, and transport. Microenterprises (fewer than 10 employees and annual turnover or balance sheet total not exceeding €2 million) may be exempt for services, but should verify this before assuming the exemption applies to their specific situation.

Regulatory bodies and complaint handling

France does not have a single EAA enforcement authority. Enforcement responsibility is distributed across several bodies depending on the sector:

• DGCCRF (Direction Générale de la Concurrence, de la Consommation et de la Répression des Fraudes) — consumer protection enforcement for most private-sector organisations
• ARCOM (Autorité de Régulation de la Communication Audiovisuelle et Numérique) — audiovisual media services
• Défenseur des droits — the independent rights body that handles accessibility complaints escalated from users

The complaint process follows a specific sequence. A user who encounters an accessibility barrier must first contact the organisation directly through a mandatory accessibility feedback link (labelled “Accessibilité”) that organisations are required to publish on every page. The organisation must acknowledge the feedback within 10 days and propose a correction or alternative access route. If the response is inadequate or absent, the user can escalate to the Défenseur des droits.

Civil society organisations with legal standing can bypass this user-by-user process entirely and bring proceedings directly before the courts.

The Déclaration d’accessibilité

French law requires every in-scope organisation to publish a Déclaration d’accessibilité (accessibility declaration) on their website. This is the French equivalent of the EAA accessibility statement and must be accessible from every page of the site or application.

The declaration must include: the current level of conformance with RGAA 4.1 criteria, a list of content or functions that are not yet accessible and the reason for each gap, and information on how to contact the organisation about accessibility problems. Claiming conformance without a substantiated assessment, or publishing a declaration that does not reflect the actual state of the product, is itself a compliance failure.

Penalties

France operates a per-offence penalty model, not a single ceiling. The structure is:

Violation type	First offence	Repeat offence
Individual	€1,500	€3,000
Legal entity (organisation)	€7,500	€15,000
Systemic non-compliance	Aggregate penalties up to €250,000

The per-offence structure means that an organisation with multiple inaccessible products, multiple failing user journeys, or multiple applications could face separate penalty assessments for each identified failure. As of June 2026, no administrative EAA fines have been published in France. The civil society enforcement track has produced a court order rather than a regulatory fine.

Two court rulings — what has happened so far

France has produced two EAA court rulings, and both matter.

5 May 2026 — Auchan wins at Tribunal judiciaire de Lille. This is the first EAA court ruling in the EU, and the defendant won — but not on accessibility grounds. The court dismissed the case against Auchan E-Commerce because of a conflict between France’s 2005 domestic accessibility law (which has a €250 million revenue threshold) and the EAA transposition. Auchan E-Commerce reported €144 million revenue in 2024 and fell below the domestic threshold. Critically, the court explicitly found the site had “strong or major failures across 13 of 19 audited sections.” The ruling is being appealed. The threshold argument has no application to larger organisations: Carrefour reports roughly €90 billion globally; E.Leclerc roughly €60 billion.

4 June 2026 — Carrefour ordered to comply at Tribunal judiciaire de Caen. This is the first EAA ruling ordering an organisation to make its digital services accessible. Carrefour France has six months to comply. Fines accrue for each day of non-compliance after that deadline. Carrefour did not dispute being subject to the obligation and estimated it had met 71% of accessibility criteria. The court found that was not sufficient.

E.Leclerc has a hearing scheduled for 22 September 2026 at the Tribunal judiciaire de Créteil. Picard has no confirmed hearing date. The Auchan appeal is pending before the Court of Appeal of Douai.

Together, the two rulings demonstrate that civil society organisations with legal backing can bring EAA proceedings, that French courts will engage on the merits, and that compliance is the expected outcome for organisations that cannot invoke a narrow procedural threshold.

What compliance requires

For organisations with French consumer exposure, EAA compliance requires four things, all of which are mandatory:

• Technical conformance. WCAG 2.1 Level AA across all consumer-facing digital products and services, validated against RGAA 4.1 criteria.
• A published Déclaration d’accessibilité. Accessible from every page, describing your current conformance level, identified gaps, and how to contact you about accessibility.
• An accessibility feedback mechanism. A mandatory “Accessibilité” link or contact route on every page, with a 10-day response obligation when users raise accessibility problems.
• Active governance. A named owner for accessibility, a regular testing rhythm, and documentary evidence of ongoing management. Evidence of genuine compliance activity is what distinguishes an organisation that has engaged with the obligation from one that has not.

Which organisations are covered

Any organisation providing covered products or services to consumers in France is in scope — regardless of where the organisation is headquartered. An Irish SaaS company with French customers, a Dutch e-commerce retailer shipping to France, and a Swedish FinTech with French users are all subject to the same obligations as a French organisation. If your product is available to French consumers, French law applies.