EAA: what happened in year one?

Posted on Thursday, 12 November 2026 by Mayi Wilson in Standards

Tags: WCAG

The deadline has passed, so what's actually happened since the European Accessibility Act (EAA) came into enforcement? What do the developments mean for you?

What is the European Accessibility Act (EAA)?

The EAA was introduced to benefit both businesses and people with disabilities in the EU. In the European Commission's own words:

Businesses benefit from:

• common rules on accessibility in the EU leading to costs reduction
• easier cross-border trading
• more market opportunities for their accessible products and services

Persons with disabilities and older people benefit from:

• more accessible products and services in the market
• accessible products and services at more competitive prices
• fewer barriers when accessing transport, education and the open labour market
• more jobs available where accessibility expertise is needed

Remember that the EAA applies to where your customers are based, not where your company is headquartered. So, if you have customers in the EU, your digital services need to be accessible.

To learn more about the EAA and associated standards, you can read our Understanding the European Accessibility Act (EAA) and Understanding EN 17161 Design for All posts.

A timeline of enforcement

• 2019: the EAA is adopted, establishing accessibility requirements across the EU
• 2022: transposition of the EAA into national law is completed by all 27 member states
• June 2025: enforcement begins, as does national oversight
• July 2025: legal challenges in France are brought against major retailers
• October 2025: Sweden launches market surveillance
• November 2025: the first EAA-related lawsuits are filed in France against four major retailers
• July 2026: Carrefour is told 71% conformance isn't enough
• 2026 to 27: the Web Content Accessibility Guidelines (WCAG) required standard will change from 2.1 to 2.2
• June 2030: the 5-year transitional period for services in use before 2025 ends

What's changed in the EAA since June 2025?

In September 2026, the EAA changed the WCAG standard it references from 2.1 to 2.2. There are nine additional success criteria that you need to be aware of if you haven't already been using WCAG 2.2 as your benchmark.

Two notable cases and what they mean for you

Carrefour

This case is one that most people will bring up as it represents some major firsts for accessibility in the private sector, across the EU.

In July 2025, two associations for disabled people submitted complaints against four large French retailers, including Carrefour, stating that their websites were not accessible for people with seeing disabilities. Lawsuits were formally filed in November 2025.

In June 2026, French courts ruled that Carrefour had six months to become conformant with accessibility standards under the EAA, and that they would receive a penalty for each day over that deadline they weren't accessible. The court included both the website and app in this ruling, a notable first among EAA cases so far which had been focused on websites only.

The other notable part of this case was Carrefour's attempted defence, and the court's response to it. Carrefour argued that they had achieved 71% conformance with the Référentiel général d’amélioration de l’accessibilité (RGAA), France's national accessibility standard, and that not only was this enough, only three years earlier the company had been scoring around half of that. The court essentially responded that the ruling was about whether people could use the site, not whether the company had worked hard to make it 'better'.

The deadline for Carrefour is coming up in December 2026, and we wait to see whether they have succeeded.

The key takeaways

Carrefour experienced legal, reputational and financial risks that could have been avoided, but when the ruling came down they already had systems in place to fix things and a log of evidence. They just had to move faster. The ruling could have been much more painful if they hadn't reached 71% conformance already.

This is the first case that treated both a website and native app as equally important, rolling both platforms into one even though the app wasn't part of the original filing. If your app serves customers in the EU, the EAA is just as applicable for you.

Auchan

In what's believed to be the first legal case brought under the EAA, in the same set of complaints as Carrefour was fellow retailer Auchan.

Their case was dismissed, and many people saw that headline and assumed that it meant the EAA wasn't really something to worry about. But the details of that dismissal are important.

As part of the case, the Auchan website was audited by a number of people with disabilities and it failed 9 of the 13 sections they assessed. While dismissing the case, the court acknowledged that the site's accessibility was "fairly low". The dismissal doesn't negate or erase that finding, which is now permanently documented.

In real terms, the case was dismissed because of two overlapping revenue threshold criteria in French law. The existing 2005 domestic law requires a company to make 250 million euro in order for accessibility standards to be applied, whereas the EAA only allows exemptions for small enterprises making less than 2 million euro and with fewer than 10 staff. Auchan sits somewhere between 140 and 190 million euro, below the domestic threshold but significantly above the EAA's exemption. The court applied the 2005 threshold during this case, even though it was brough under the EAA, which the complainants immediately appealed, stating that the law has been misinterpreted. We have yet to see if the appeal will be granted or not.

The key takeaways

This case isn't yet over, and the dismissal was on a revenue technicality, not whether the site was accessible. We know, on paper, that it isn't. We also know that the EAA is fundamentally about people being able to access services.

So if that appeal wins, Auchan could have a painful journey to improve the 9 areas they failed during accessibility auditing, especially if they aren't preparing now and getting the right internal structures in place.

Practical steps you can take

These actions will help you get prepared and have a plan to prioritise accessibility:

• Know your technical compliance by conducting an assessment
• If you've been working towards WCAG 2.1, start mapping out how to meet WCAG 2.2
• Validate the usability with disabled people
• Based on these results, create a plan to close any gaps, focusing first on any severe issues that are blocking people from carrying out tasks
• For each country you serve, check on the national laws about how you need to evidence your compliance status and what enforcement looks like - this is the only aspect of your obligation that can differ substantially between countries
• Embed accessibility into your culture to make it more sustainable

Summary

It can feel overwhelming to need to cater your accessibility to 27 different national laws. Remember that the approach to building accessible products and services remains the same no matter what region you're in. It's just the documentation and enforcement that may differ from country to country.

Always come back to the fact that it's about people being able to use the service, not checkboxes and criteria. Carrefour's 71% conformance was an improvement on where they were a few years earlier, but it still had barriers for people who are blind or have low vision. And, as the European Commission itself states, if you can get it right, you'll not only be making things better for your customers, but you'll be benefiting your business too.

Next steps

If you're not sure where to start, our Consultancy service can help you get a handle on where you are and what you need to do.

Have a look at our European Accessibility Act (EAA) FAQ for more answers to common questions about the act itself and what's covered.