⚠ Why now

The EAA is in force. And it costs.

Everything you should know before receiving a notice: the timeline, the penalties, the companies already sued, and the legal framework country by country.

€250,000

Maximum fine per confirmed non-compliance

French law of 9 March 2023, art. L. 412-1 — transposing EU Directive 2019/882

§ 01 // — Timeline

From directive to penalty.

Six years between the EU vote and the date your business becomes liable. The grace period is over.

  1. 01

    17 April 2019

    EU Directive 2019/882 adopted

    The European Parliament votes the European Accessibility Act. Member states have until 28 June 2022 to transpose it.

  2. 02

    9 March 2023

    French transposition law

    Law n° 2023-171 transposes the EAA into French law. It introduces fines up to €250,000 for legal entities.

  3. 03

    28 June 2025

    Application — new sites

    Any new e-commerce site launched after this date must be compliant immediately. No grace period.

  4. 04

    July 2025

    First formal complaints filed

    Disability rights associations file the first formal complaints against Auchan, Carrefour, E. Leclerc and Picard.

  5. 05

    28 June 2030

    End of grace for legacy sites

    Sites created before June 2025 must be compliant — unless they can demonstrate an active remediation effort.

§ 02 // — Complaints already filed

Four major retailers, hit in the first month.

French disability-rights associations like Valentin Haüy and APF France handicap are not waiting. Here are the first formal actions filed after the EAA took effect.

Auchan

⚠ Formal notice

// July 2025

Checkout flow unusable with screen readers

Carrefour

⚠ Formal notice

// July 2025

Form fields without labels, insufficient contrast on promo banners

E. Leclerc

⚠ Formal notice

// July 2025

Customer area not navigable by keyboard

Picard

⚠ Formal notice

// July 2025

Product images without alternative text

The sources and case numbers are public. If you run a store with fewer than 250 employees, you're the next target: large retailers can afford to defend themselves; you cannot.

§ 03 // — The legal text

What's actually required.

«
"Products and services subject to the accessibility requirements set out in this Directive shall be designed and produced in such a way as to maximise their foreseeable use by persons with disabilities and shall be accompanied where possible in or on the product by accessible information on their functioning and on their accessibility features."

// Directive (EU) 2019/882, article 4 §1

Plain English: your store must be usable by a person who is blind, low-vision, deaf or has a motor disability. Not on the surface — actually.

§ 04 // — Who is covered

You, most likely.

The EAA applies to every economic operator offering goods or services in the EU — including online stores. A few concrete cases:

// scénario 01

You sell to consumers (B2C)

→ You're covered.

All B2C e-commerce sites fall within the EAA's scope, regardless of size.

// scénario 02

You have under 10 employees AND under €2M revenue

→ Possible exemption (micro-enterprise).

But only if you declare it explicitly. And the exemption doesn't apply to sites created after 28 June 2025.

// scénario 03

You sell only B2B

→ Partially covered.

B2B services are less covered, but the EAA does apply to payment interfaces and online customer support.

// scénario 04

You're an agency managing 10 client stores

→ Covered × 10.

Each client store is individually liable. But the technical fault will land on you contractually.

§ 05 // — Country by country

Where you can be sued.

The EAA is an EU directive, but each member state has transposed it with its own authorities and its own penalty ceilings.

PaysLoiAutoritéAmende max.
FranceLaw n° 2023-171 of 9 March 2023DGCCRF€250,000
GermanyBarrierefreiheitsstärkungsgesetz (BFSG)Federal market surveillance authorities€100,000
SpainReal Decreto 193/2023Ministry of Social Rights€600,000
ItalyLegislative Decree 82/2022 (updated Stanca Act)AgID€40,000
Rest of EUNational transpositions of Directive 2019/882VariesDepends on country

You need an audit. Now.

A ComplAudit audit costs €225 and takes 5 to 20 minutes. A formal notice costs a lawyer. A court ruling costs €250 000. Do the math.

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