The EAA directive is shared across the whole Union, but its transposition and enforcement are national — and the gaps are already clear. For an e-commerce site selling in several countries, it's the harshest link that determines the real risk. An overview of France / Germany / Spain.

Germany — the fastest to strike

The Barrierefreiheitsstärkungsgesetz (BFSG) transposes the EAA. The Länder are responsible for enforcement, and some (Bavaria, North Rhine-Westphalia) opened proceedings as early as the summer of 2025. The fine is capped at around €100,000, but it's cumulative per non-conformity, which can push the bill up on a site riddled with errors.

Spain — procedural but slower

Real Decreto 193/2023 transposes the EAA, with coordination on the digital-accessibility side. The sanctions scale is wide — from a few tens of thousands of euros up to a million depending on severity — but the first effective sanctions are slow to come: many complaints recorded, few decisions so far.

France — enforcement gets going

The law of 9 March 2023 transposes the EAA, the DGCCRF investigates. The strong signal: the formal complaints filed by the CFPSAA against Auchan, Carrefour, E. Leclerc and Picard in July 2025. Proceedings are under way, the first sanctions expected around the end of 2026. France sits between German aggressiveness and Spanish slowness.

What to take away

  • →The earliest and most mechanical risk is German (cumulative by default)
  • →The Spanish risk is potentially the heaviest in amount, but slower
  • →The French risk is now real and high-profile
  • →The same technical defect is visible — and sanctionable — in all three countries at once

// For a cross-European e-commerce site

A non-conformity visible in France is also visible in Germany and Spain: the risk is cumulative, not shared out. The fix: an audit that covers both RGAA 4.1 (France) and WCAG 2.1 AA (the common European base). That's what ComplAudit does by default, so you don't reason country by country.

Frequently asked questions

I sell in France and Germany: which standard should I follow?

Aim for WCAG 2.1 AA, the base common to both transpositions, and apply RGAA 4.1 for the French part (the official assessment method in France). Complying with the stricter one covers the other.

Does a complaint in one country count for the others?

Legally, each national authority acts on its own territory. But the technical defect itself is identical everywhere: a complaint in Germany reveals an immediate risk in France on the same site. Fix at the source, not country by country.

Does Germany really sanction faster?

The first proceedings started there early, and the cumulative-per-non-conformity mechanism makes the bill quickly off-putting. It's the market where inaction costs the most, the fastest.

Cover the RGAA (France) and WCAG (Europe) in a single audit:

→ Run an audit