RGAA, the EAA, and the obligation of result — what the Carrefour ruling established

What RGAA is

RGAA 4.1 is the French technical standard that operationalises WCAG 2.1 Level AA into 106 verifiable criteria. Where WCAG states the principle, RGAA provides the specific test. It is how French courts, regulators, and civil society organisations measure whether a digital product is accessible in practice.

RGAA 4.1 and EN 301 549 are closely aligned: they share the same underlying WCAG 2.1 AA requirements, translated into different testing frameworks. Meeting one substantially achieves the other. Any organisation with French consumer exposure is assessed against RGAA criteria when French courts or civil society organisations evaluate compliance.

The distinction matters for one practical reason: RGAA is a named standard in the French EAA transposition. When a French court asks whether an organisation's site is accessible, it asks whether RGAA criteria are met. "We conform to WCAG 2.1 AA" and "we conform to RGAA 4.1" are not the same claim, though they largely overlap. A French court will assess RGAA compliance specifically.

What the Carrefour ruling established

On 4 June 2026, the Tribunal judiciaire de Caen issued the first EAA court order in Europe requiring an organisation to make its digital services accessible. A month earlier, Auchan had been the subject of the first EAA ruling overall, but that case was dismissed on a procedural threshold rather than decided on accessibility merits. The Carrefour ruling was the first to reach the substance of the obligation. The case was brought by civil society organisations, not a regulator. Carrefour did not dispute being in scope of the EAA. Its defence was that it had already done substantial accessibility work.

Specifically, Carrefour argued that it had already met 71% of RGAA criteria. The court considered this argument and rejected it explicitly.

The court ordered Carrefour to make its online commerce services fully accessible within six months, which puts the deadline at 4 December 2026. French press reporting puts the penalty at €500 per day of delay after that date. The figure does not appear in the associations’ own communiqués, so it is reported rather than confirmed. Carrefour did not dispute being subject to the obligation. It disputed only whether partial conformance was sufficient. The court answered that question plainly: it is not.

What "obligation of result" means in practice

The key phrase from the Carrefour ruling is "obligation of result." This is a specific legal standard. It does not mean best efforts. It does not mean substantial compliance. It does not mean "we are working on it." It means the outcome required by law is full accessibility, and partial progress toward that outcome is not a compliance position.

Most organisations that have done some accessibility work assume partial conformance is better than none, and that genuine effort provides some legal protection. The Carrefour ruling establishes that this assumption is wrong. 71% conformance is not compliance. The organisation that has addressed most of its accessibility issues is still non-compliant. The obligation is the result, not the effort.

This is a higher standard than most organisations have been applying. The common framing in accessibility work, phrases such as "we're making progress," "we've addressed the critical issues," and "we're committed to accessibility," reflects a reasonable-efforts understanding of the obligation. The Carrefour ruling replaces that framing with an outcome-based one. Progress is not compliance. The completed outcome is compliance.

What this means for organisations outside France

The Carrefour ruling was issued by a French court, applying the French transposition of the EAA, and as a precedent it binds only France. The principle underneath it is not confined to France. The EAA requires products and services to be accessible as a matter of outcome, not of effort. Article 4 requires them to meet the accessibility requirements in Annex I, not merely to work towards them. That outcome requirement applies in Ireland, the Netherlands, Sweden, Italy, and every other member state. “Obligation de résultat” is the French court’s own term for it; the requirement it names is EU-wide.

What the Carrefour ruling does is establish, in a published court decision, exactly what this standard means when tested. Courts in any EU member state can reach the same conclusion. The standard the Caen court applied is available to courts in Dublin, Amsterdam, Stockholm, and Rome.

The civil society enforcement model that produced the Carrefour ruling is also replicable. Disability organisations in Ireland, the Netherlands, and Sweden have the same legal standing to bring proceedings that French organisations exercised here. The Carrefour case demonstrates that the model works: organisations can be ordered to comply, with accruing daily fines, through a process that does not require a regulator to act first.

Two further cases remain pending in France: E.Leclerc, with a hearing at the Tribunal judiciaire de Créteil on 22 September 2026, and Picard Surgélés, with no confirmed hearing date. The Auchan case, decided a month before Carrefour's, was dismissed on a narrow procedural threshold rather than on accessibility grounds: the court found the site met only 41% of RGAA criteria, with strong or major failures across 13 of the 19 sections audited, and explicitly noted Auchan's "lack of interest" in accessibility despite its scale. The case turned entirely on whether Auchan's e-commerce subsidiary cleared France's separate €250 million domestic revenue threshold; it did not. That dismissal is under appeal to the Cour d'appel de Douai. The threshold argument does not extend to larger organisations: Carrefour and E.Leclerc both clear it by a wide margin, which is why their cases are being tested on the merits rather than on this technicality.

The practical implication for compliance work

Organisations that have done accessibility work but not completed it are in a specific position: they have demonstrated that they understood the obligation, began addressing it, and stopped before achieving compliance. In enforcement terms, this is potentially a more exposed position than having done nothing, because it removes the argument that the organisation was unaware of the requirement.

The due diligence defence available under the EAA requires documented evidence of active management. An organisation that has completed and documented its accessibility work has a stronger position than one that has done partial work without documentation. The Carrefour ruling clarifies that partial completion, without documentation of an active remediation programme, does not constitute a defence.

The starting point is the assessment that answers the question: where are the remaining gaps, and what does full compliance require? Without it, an organisation cannot know whether it is close to compliance or further away than it believes.