First European Accessibility Act Lawsuits Hit French Retailers: What E-Commerce Needs to Know
TABLE OF CONTENTS
- Key Takeaways
- What Happened? The Timeline of the First EAA Lawsuits
- Why These Specific Retailers Were Targeted
- What Makes This Lawsuit Different: Emergency Injunction Procedure
- The Legal Framework: European Accessibility Act and EN 301 549
- What This Means for E-Commerce Businesses Selling to the EU
- The Parallels to U.S. ADA Litigation
- What the French Retailers Should Have Done
- What E-Commerce Businesses Should Do Now
- The Business Case Beyond Compliance
- What Comes Next: Predictions for EAA Enforcement
- Frequently Asked Questions
- Related TestParty Resources
- Sources
Key Takeaways
- November 12, 2025: First EAA lawsuits filed β Disability rights organizations ApiDV and Droit Pluriel filed emergency injunctions against Auchan, Carrefour, E. Leclerc, and Picard SurgelΓ©s in French court
- This follows a July formal complaint with a September 1 deadline β the retailers showed "little meaningful progress and even some indifference"
- Emergency procedure (assignation en rΓ©fΓ©rΓ©) means courts can demand immediate fixes, not vague promises
- Only 3.4% of major French company websites are accessible despite accessibility being a legal requirement since 2016
- E.Leclerc's compliance improved from 32% to just 50% β still illegal under French law and EU directive
- This sets precedent for all EU member states β advocacy groups now have clear legal standing to sue under EAA
- E-commerce is in the crosshairs β if you sell to EU customers, you're subject to the European Accessibility Act regardless of where you're headquartered
On November 12, 2025, accessibility enforcement in Europe entered a new era.
Two French disability rights organizationsβApiDV and Droit Plurielβsupported by the legal collective IntΓ©rΓͺt Γ Agir, filed emergency injunctions (assignation en rΓ©fΓ©rΓ©) against four of France's largest grocery retailers: Auchan, Carrefour, E. Leclerc, and Picard SurgelΓ©s.
The charge: digital discrimination against the 2 million visually impaired people in France who cannot use these retailers' websites and mobile apps to shop independently.
This isn't a regulatory warning or a symbolic complaint. It's a lawsuit asking a French judge to order these companies to stop discriminatingβimmediately.
For e-commerce businesses operating in or selling to the European Union, this case represents a fundamental shift. The European Accessibility Act (EAA), which became enforceable on June 28, 2025, is no longer theoretical. It's being enforced through the courts. And France is just the beginning.
What Happened? The Timeline of the First EAA Lawsuits
The French lawsuits didn't come out of nowhere. The organizations followed a deliberate escalation process that mirrors how accessibility enforcement is likely to work across the EU.
βββββββββββββββββββββββββ¬ββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββ
β Date β Event β
βββββββββββββββββββββββββΌββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββ€
β June 28, 2025 β European Accessibility Act becomes enforceable across all EU member states β
βββββββββββββββββββββββββΌββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββ€
β July 7, 2025 β ApiDV, Droit Pluriel, and IntΓ©rΓͺt Γ Agir send formal legal notices to β
β β Auchan, Carrefour, E. Leclerc, and Picard SurgelΓ©s β
βββββββββββββββββββββββββΌββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββ€
β September 1, 2025 β Deadline given to retailers to achieve accessibility compliance β
βββββββββββββββββββββββββΌββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββ€
β September-Nov 2025 β Testing committee of blind and visually impaired technology experts β
β β audits retailer websites and apps β
βββββββββββββββββββββββββΌββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββ€
β November 12, 2025 β Emergency injunctions filed in French court after retailers show β
β β "little meaningful progress" β
βββββββββββββββββββββββββ΄ββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββββAccording to the official press release from IntΓ©rΓͺt Γ Agir, the organizations gave these retailers a formal complaint in July with a clear deadline. The retailers were offered time to fix their accessibility issues or at least demonstrate meaningful progress.
Instead, the testing committee found:
- Missing alternative text for images, making product identification impossible for screen reader users
- Insufficient color contrast, creating barriers for users with low vision
- Links and buttons inaccessible via keyboard, blocking users who cannot use a mouse
- Incoherent page structure, preventing screen readers from navigating logically
The result: visually impaired customers still cannot complete a grocery order independently on these platforms.
As we've documented extensively, these are not exotic technical failures. They're the same WCAG violations that trigger ADA lawsuits in the United States every day. The difference is that Europe now has unified enforcement mechanismsβand advocacy groups are using them.
Why These Specific Retailers Were Targeted
The four retailers weren't chosen randomly. They represent some of France's largest grocery chains, and their digital platforms serve millions of customers:
βββββββββββββββββββββ¬ββββββββββββββββββββββββββ¬βββββββββββββββββββββββββββββββββββββββ
β Retailer β Properties Targeted β France Market Position β
βββββββββββββββββββββΌββββββββββββββββββββββββββΌβββββββββββββββββββββββββββββββββββββββ€
β Auchan β Website + Mobile App β 4th largest retailer β
βββββββββββββββββββββΌββββββββββββββββββββββββββΌβββββββββββββββββββββββββββββββββββββββ€
β Carrefour β Website β 2nd largest retailer, global presenceβ
βββββββββββββββββββββΌββββββββββββββββββββββββββΌβββββββββββββββββββββββββββββββββββββββ€
β E. Leclerc β Website β Largest retailer by market share β
βββββββββββββββββββββΌββββββββββββββββββββββββββΌβββββββββββββββββββββββββββββββββββββββ€
β Picard SurgelΓ©s β Website + Mobile App β Leading frozen food specialist β
βββββββββββββββββββββ΄ββββββββββββββββββββββββββ΄βββββββββββββββββββββββββββββββββββββββThe advocacy groups specifically targeted online grocery services because grocery shopping represents an essential daily activity. For someone who is blind or has low vision, an inaccessible grocery website doesn't just create inconvenienceβit removes the ability to perform a basic life function independently.
The FΓ©dΓ©ration des Aveugles et Amblyopes de France (Federation of Blind and Partially Sighted People of France) reported in June 2025 that only 3.4% of major French company websites are accessible. These four retailers were identified through public testimony as particularly problematic.
E. Leclerc's compliance status tells the story: according to French audit data, the retailer's website went from 32% RGAA compliance in May 2023 to 50% compliance in August 2025. That's progress, technicallyβbut 50% compliance is still illegal under both French law and the EU directive. Half-accessible is not accessible.
What Makes This Lawsuit Different: Emergency Injunction Procedure
The organizations filed an "assignation en rΓ©fΓ©rΓ©"βan emergency injunction procedure under French civil law. This is significant for several reasons:
Speed. Unlike standard civil litigation that can take years, emergency injunctions are designed for urgent situations requiring immediate judicial intervention. The court can order immediate remediation measures.
Injunctive relief, not just damages. The goal isn't primarily to extract money from these retailers (though penalties may follow). It's to force them to stop discriminatingβto make their websites and apps accessible now.
Public accountability. The lawsuit names these companies publicly. Their brand reputation is now directly tied to their accessibility failures. Every news article, every social media discussion, every customer who learns about this case will associate these brands with discrimination against disabled people.
Precedent-setting. This is the first lawsuit of its kind in France under the EAA framework. The court's decision will establish how aggressively the EAA will be enforced and what "compliance" actually means in practice.
For e-commerce businesses watching from outside France, this matters enormously. The EAA is a directiveβeach EU member state implements it through national law. France is now demonstrating what enforcement looks like. Other countries will follow.
The Legal Framework: European Accessibility Act and EN 301 549
To understand what these retailers are accused of violating, you need to understand the EU's accessibility legal framework.
European Accessibility Act (Directive 2019/882)
The European Accessibility Act was adopted in 2019 and became enforceable on June 28, 2025. It requires that products and services sold in the EU be accessible to people with disabilities.
For e-commerce, the EAA covers:
- Websites and mobile applications used to sell products or services
- E-commerce platforms and marketplaces
- Online payment systems
- Customer service interfaces (chatbots, contact forms, help centers)
- Digital receipts and order confirmations
- Self-service terminals (kiosks, ATMs)
The scope is broad: any business selling to EU consumers is subject to the EAA, regardless of where that business is headquartered. If you're a U.S. e-commerce brand shipping to Germany or France, you're covered.
EN 301 549: The Technical Standard
The EAA doesn't define technical accessibility requirements itself. Instead, it references EN 301 549, the harmonized European standard for ICT accessibility.
EN 301 549 incorporates WCAG 2.1 Level AA as its foundation for web and mobile accessibility. This means:
βββββββββββββββββββ¬ββββββββββββββββββββββββββββββββββββββββββββββββββββ¬ββββββββββββββββββββββββββββββββββββββββββ
β WCAG Principle β EN 301 549 Requirement β Example β
βββββββββββββββββββΌββββββββββββββββββββββββββββββββββββββββββββββββββββΌββββββββββββββββββββββββββββββββββββββββββ€
β Perceivable β All content must be presentable to users β Images need alt text; videos need β
β β regardless of sensory abilities β captions β
βββββββββββββββββββΌββββββββββββββββββββββββββββββββββββββββββββββββββββΌββββββββββββββββββββββββββββββββββββββββββ€
β Operable β All functionality must be available to users β Everything must work with keyboard only β
β β regardless of how they interact β β
βββββββββββββββββββΌββββββββββββββββββββββββββββββββββββββββββββββββββββΌββββββββββββββββββββββββββββββββββββββββββ€
β Understandable β Content and interface must be comprehensible β Clear labels, consistent navigation β
βββββββββββββββββββΌββββββββββββββββββββββββββββββββββββββββββββββββββββΌββββββββββββββββββββββββββββββββββββββββββ€
β Robust β Content must work with assistive technologies β Compatible with screen readers β
βββββββββββββββββββ΄ββββββββββββββββββββββββββββββββββββββββββββββββββββ΄ββββββββββββββββββββββββββββββββββββββββββFor businesses already pursuing WCAG 2.2 AA compliance, the transition to EN 301 549 compliance is relatively straightforwardβWCAG 2.2 is backwards-compatible with 2.1, and meeting WCAG 2.2 AA exceeds the current EN 301 549 requirements.
France's RGAA Standard
France has its own national accessibility standard, the RGAA (RΓ©fΓ©rentiel GΓ©nΓ©ral d'AmΓ©lioration de l'AccessibilitΓ©), which implements the EU directive. The RGAA aligns with WCAG 2.1 and includes additional documentation requirements like accessibility statements and multi-year compliance plans.
French law has required large companies to make their websites accessible since 2016βnearly a decade before these lawsuits. The EAA didn't create new obligations; it strengthened existing ones and provided clearer enforcement mechanisms.
This is a critical point: these retailers had years to comply. The EAA gave them until June 2025. France's national law gave them until 2016. Their non-compliance isn't a failure to meet a new surprise requirementβit's a decade of ignoring legal obligations.
What This Means for E-Commerce Businesses Selling to the EU
If you're running e-commerce operations that serve EU customers, the French lawsuits should change your risk calculus immediately.
The EAA Applies to You
The European Accessibility Act has extraterritorial reach. If your business:
- Sells products or services to customers in any EU member state
- Has an EU subsidiary or establishment
- Markets to EU consumers through websites accessible in the EU
You're subject to the EAA. It doesn't matter if you're headquartered in New York, Los Angeles, or Singapore.
This is similar to how GDPR worksβand we've seen how seriously the EU takes enforcement of that regulation. The EAA should be treated with the same level of attention.
Advocacy Groups Have Standing to Sue
One of the most significant aspects of the EAA is that it explicitly grants disability advocacy organizations and, in many member states, individuals the right to file complaints and lawsuits.
In the United States, most ADA website lawsuits are filed by individual plaintiffs (often represented by a small number of specialized law firms). In Europe, the EAA empowers disability rights organizations with resources, legal expertise, and public platforms.
These organizations are watching. They're documenting accessibility barriers. They're giving formal notice. And when businesses don't respondβas these French retailers didn'tβthey're going to court.
Enforcement Will Vary by Member State
Each EU country implements the EAA through its own national law and enforcement mechanisms. This creates complexity:
ββββββββββββββββ¬ββββββββββββββββββββββββββββββββββββββ¬βββββββββββββββββββββββββββββββββββββββββββββββββββββ
β Member State β Enforcement Authority β Notable Approach β
ββββββββββββββββΌββββββββββββββββββββββββββββββββββββββΌβββββββββββββββββββββββββββββββββββββββββββββββββββββ€
β France β ARCOM + Civil Courts β First to see private lawsuit under EAA β
ββββββββββββββββΌββββββββββββββββββββββββββββββββββββββΌβββββββββββββββββββββββββββββββββββββββββββββββββββββ€
β Germany β Federal Office for Accessibility β Focus on product compliance β
ββββββββββββββββΌββββββββββββββββββββββββββββββββββββββΌβββββββββββββββββββββββββββββββββββββββββββββββββββββ€
β Netherlands β Authority for Digital Infrastructureβ Active monitoring β
ββββββββββββββββΌββββββββββββββββββββββββββββββββββββββΌβββββββββββββββββββββββββββββββββββββββββββββββββββββ€
β Spain β Ministry of Social Rights β Already fined Vueling β¬90,000 pre-EAA β
ββββββββββββββββΌββββββββββββββββββββββββββββββββββββββΌβββββββββββββββββββββββββββββββββββββββββββββββββββββ€
β Sweden β PTS (Post and Telecom Authority) β Market surveillance of devices β
ββββββββββββββββ΄ββββββββββββββββββββββββββββββββββββββ΄βββββββββββββββββββββββββββββββββββββββββββββββββββββThe French lawsuits set a precedent that advocacy groups in other member states will likely follow. Expect similar legal actions in Germany, the Netherlands, and Spain in the coming months.
The "Indifference" Problem
Perhaps the most damning detail from the French case: the advocacy groups noted that the retailers showed "little meaningful progress and even some indifference" to their accessibility obligations.
This indifference is now a legal liability.
In accessibility enforcement, demonstrated good faith matters. If you receive a formal complaint and respond with a concrete remediation plan, documented progress, and genuine engagementβyou're in a different position than if you ignore it.
The French retailers apparently chose indifference. Now they're in court.
The Parallels to U.S. ADA Litigation
For businesses familiar with ADA website accessibility lawsuits in the United States, the French case has familiar elementsβbut also critical differences.
Similarities
Same underlying violations. Missing alt text, poor contrast, keyboard inaccessibility, broken form labelsβthese are the same WCAG violations that trigger lawsuits in both jurisdictions. If your site fails WCAG 2.1 AA, it fails both ADA case law standards and EN 301 549.
Formal notice before litigation. The French organizations sent formal complaints in July before filing suit in November. This mirrors the demand letter process common in U.S. ADA litigationβthough the timeline and formality differ.
E-commerce as primary target. 77% of ADA website lawsuits target e-commerce sites. The French case targets online groceryβa subset of e-commerce. Retail and e-commerce are high-visibility, high-transaction-volume targets in both regions.
Advocacy groups driving enforcement. While most U.S. ADA lawsuits are filed by individual plaintiffs, the organizations behind those plaintiffs (and the law firms representing them) operate with coordination and strategy. The European model makes organizational enforcement more explicit.
Key Differences
Unified technical standard. The EU has EN 301 549 as a legally referenced technical standard. The U.S. still has no formally adopted federal standard for private sector websitesβWCAG is referenced in case law and DOJ guidance but isn't codified in ADA regulations for private businesses.
Emergency injunction focus. The French lawsuit seeks immediate injunctive relief through an emergency procedure. U.S. ADA Title III also only provides injunctive relief (not damages), but the procedural speed differs significantly.
Explicit organizational standing. The EAA explicitly grants advocacy organizations the right to bring enforcement actions. U.S. law focuses on individual standing, though advocacy groups often support individual plaintiffs.
Regulatory coordination. The EAA integrates with broader EU regulatory frameworks. Member state enforcement authorities work alongside private litigation. The U.S. relies primarily on private litigation with limited DOJ enforcement.
ββββββββββββββββββββββββββββββββββ¬ββββββββββββββββββββββββββββββββββ¬ββββββββββββββββββββββββββββββββββ
β Aspect β ADA (U.S.) β EAA (EU) β
ββββββββββββββββββββββββββββββββββΌββββββββββββββββββββββββββββββββββΌββββββββββββββββββββββββββββββββββ€
β Technical Standard β No codified standard; β EN 301 549 (incorporates β
β β WCAG referenced in case law β WCAG 2.1 AA) legally required β
ββββββββββββββββββββββββββββββββββΌββββββββββββββββββββββββββββββββββΌββββββββββββββββββββββββββββββββββ€
β Who Can Sue β Individuals (often with β Individuals AND advocacy β
β β specialized law firms) β organizations explicitly β
ββββββββββββββββββββββββββββββββββΌββββββββββββββββββββββββββββββββββΌββββββββββββββββββββββββββββββββββ€
β Regulatory Enforcement β Limited DOJ enforcement β Designated authorities in β
β β β each member state β
ββββββββββββββββββββββββββββββββββΌββββββββββββββββββββββββββββββββββΌββββββββββββββββββββββββββββββββββ€
β Damages Available β Title III: Injunctive only β Varies by member state; β
β β (State laws may add damages) β fines + injunctive relief β
ββββββββββββββββββββββββββββββββββΌββββββββββββββββββββββββββββββββββΌββββββββββββββββββββββββββββββββββ€
β Primary Targets β 77% e-commerce β E-commerce, banking, β
β β β transport, telecom β
ββββββββββββββββββββββββββββββββββ΄ββββββββββββββββββββββββββββββββββ΄ββββββββββββββββββββββββββββββββββWhat the French Retailers Should Have Done
The tragedy of this lawsuit is that it was entirely preventable. Here's what these retailers could have done differently:
1. Responded to the July Formal Notice
When ApiDV, Droit Pluriel, and IntΓ©rΓͺt Γ Agir sent formal legal notices in July 2025, these retailers had an opportunity. They could have:
- Acknowledged the complaint and committed to remediation
- Engaged with the organizations to understand specific barriers
- Developed and published a concrete remediation timeline
- Demonstrated progress before the September deadline
Instead, according to the plaintiffs, they showed "indifference."
2. Achieved More Than 50% Compliance After Years of Notice
E. Leclerc's progression from 32% to 50% RGAA compliance between 2023 and 2025 represents two years of workβand they're still only halfway there. For a company with E. Leclerc's resources (France's largest retailer by market share), this pace is indefensible.
Accessibility remediation doesn't have to take years. With the right approachβautomated remediation tools, expert guidance, and organizational commitmentβsignificant improvements can happen in weeks, not years.
3. Made Their Accessibility Statement Honest
French law requires companies to publish accessibility statements. These statements must honestly report compliance status. A 50% compliance rate isn't a technical detail to buryβit's a public admission that half of users with disabilities cannot use your service.
4. Prioritized Accessibility in Development
These retailers have had since 2016 to build accessibility into their development processes. The shift-left approach to accessibilityβintegrating accessibility testing into CI/CD pipelines, training developers, making accessibility a release criterionβwould have prevented this situation entirely.
What E-Commerce Businesses Should Do Now
Whether you're subject to the EAA, the ADA, or both, the French lawsuits offer a clear action plan:
1. Understand Your Regulatory Exposure
If you sell to EU customers, you're subject to the EAA. If you sell to U.S. customers, you're subject to ADA risk. Many businesses face both. Map your exposure:
- Which EU member states do you serve?
- What percentage of revenue comes from EU customers?
- What digital properties (websites, apps, customer portals) are customer-facing?
2. Conduct a Real Accessibility Audit
Not a checkbox exerciseβa genuine assessment against EN 301 549 / WCAG 2.1 AA standards. This means:
- Automated scanning to identify obvious violations
- Manual testing by accessibility experts
- User testing with people who use assistive technologies
- Documentation of all findings with remediation priorities
See our Website Accessibility Testing Checklist for a comprehensive approach.
3. Build a Remediation Plan with Real Timelines
An audit without remediation is just documentation of your liability. Create a concrete plan:
- Prioritize issues by severity (critical barriers first)
- Assign ownership to specific teams
- Set milestone deadlines
- Budget for external expertise if needed
For realistic expectations, see How Long Does Website Accessibility Take to Fix?
4. Don't Rely on Overlays
If you're tempted to install an accessibility widget or overlay as a quick fixβdon't.
The FTC fined accessiBe $1 million in January 2025 for false advertising about their overlay's ability to achieve compliance. Over 1,000 businesses were sued in 2024 despite having accessibility widgets installed.
Overlays don't fix underlying code issues. They create an illusion of accessibility while leaving actual barriers in place. European regulators, like U.S. courts, will see through this.
Real compliance requires source-code remediationβfixing the actual HTML, CSS, and JavaScript that creates barriers.
5. Prepare for Formal Complaints
If an advocacy group or individual sends a formal accessibility complaint, treat it seriously:
- Acknowledge receipt immediately
- Engage constructively (don't ignore or dismiss)
- Provide a concrete response timeline
- Document all communications
- Begin remediation immediately
The French retailers' "indifference" turned a solvable problem into a lawsuit. Don't make the same mistake.
6. Publish an Honest Accessibility Statement
The EAA requires accessibility statements. Make yours honest:
- State your current conformance level accurately
- List known accessibility issues
- Describe your remediation plan
- Provide contact information for accessibility feedback
An honest statement that acknowledges gaps and describes a remediation plan is better than a dishonest statement claiming full compliance.
The Business Case Beyond Compliance
Legal risk is a powerful motivatorβbut it's not the only reason to prioritize accessibility.
Market Size
According to the World Health Organization, approximately 1.3 billion people globallyβ16% of the world's populationβexperience significant disability. In France alone, 12 million people are affected by accessibility issues.
These aren't edge cases. They're a substantial market segment that inaccessible competitors cannot serve.
SEO Benefits
Many accessibility best practices align with SEO best practices. Proper heading structure, descriptive alt text, semantic HTML, fast page loadsβthese help both screen reader users and search engine crawlers understand your content.
We've documented this relationship in The Strategic Guide to Accessibility-First SEO Success.
Brand Reputation
The French retailers are now publicly associated with discrimination against disabled people. Every news article about these lawsuitsβincluding this oneβmentions their names.
Conversely, brands that lead on accessibility build reputation among disability communities and allies. Accessibility becomes a competitive differentiator.
Future-Proofing
Accessibility requirements are only expanding. The EAA, ADA enforcement, DOJ's Title II web accessibility rule for government entitiesβthe regulatory trend is clear. Building accessibility into your processes now avoids repeated remediation as requirements tighten.
What Comes Next: Predictions for EAA Enforcement
The French lawsuits are the beginning, not the end. Here's what to expect:
More Lawsuits in France
The organizations behind these lawsuits have demonstrated a successful model: formal notice, reasonable deadline, documentation of non-compliance, emergency injunction. Expect them to apply this model to other industries and companies.
Expansion to Other Member States
Disability rights organizations across the EU are watching the French case closely. Successful enforcement in France will encourage similar actions in Germany, the Netherlands, Spain, and other member states with active disability advocacy communities.
Regulatory Authority Actions
Beyond private litigation, EU member states have designated regulatory authorities to enforce the EAA. These authorities can conduct market surveillance, require accessibility demonstrations, and impose administrative penalties.
Sweden's PTS (Post and Telecom Authority) has already announced market surveillance of devices under the EAA. Similar regulatory actions for websites and apps will follow.
Cross-Border Enforcement Coordination
The EAA includes mechanisms for cross-border enforcement. A Spanish consumer with a complaint against a French company can work with Spanish enforcement authorities, who coordinate with French counterparts.
This creates complexity for businesses but also means you can't avoid enforcement by targeting certain markets.
Frequently Asked Questions
What is the European Accessibility Act?
The European Accessibility Act (Directive 2019/882) is an EU law that requires products and servicesβincluding websites, mobile apps, e-commerce platforms, and digital servicesβto be accessible to people with disabilities. It became enforceable on June 28, 2025, and applies to businesses selling to EU consumers regardless of where they're headquartered.
What happened in the French EAA lawsuits?
On November 12, 2025, disability rights organizations ApiDV and Droit Pluriel, supported by legal collective IntΓ©rΓͺt Γ Agir, filed emergency injunctions against French grocery retailers Auchan, Carrefour, E. Leclerc, and Picard SurgelΓ©s. The lawsuits allege the retailers' websites and apps discriminate against visually impaired users by failing to meet accessibility requirements under the EAA.
Does the EAA apply to U.S. companies?
Yes. The EAA applies to any business selling products or services to EU consumers, regardless of where the business is headquartered. If your U.S. e-commerce site accepts orders from EU customers, you're subject to EAA requirements.
What accessibility standard does the EAA require?
The EAA references EN 301 549, the harmonized European standard for ICT accessibility. EN 301 549 incorporates WCAG 2.1 Level AA as its foundation for web and mobile accessibility. Businesses that achieve WCAG 2.1 AA conformance are generally compliant with EN 301 549's digital accessibility requirements.
How is EAA enforcement different from ADA enforcement?
Key differences include: (1) the EAA explicitly grants advocacy organizations standing to file complaints and lawsuits; (2) EN 301 549 is a legally referenced technical standard, while the ADA has no codified web standard; (3) EU member states have designated regulatory authorities for enforcement alongside private litigation; (4) the French emergency injunction procedure emphasizes speed and injunctive relief.
Can an accessibility overlay make my site EAA compliant?
No. Accessibility overlays don't fix underlying code issues and don't provide genuine compliance with EN 301 549 or WCAG standards. The FTC fined accessiBe $1 million for false advertising about overlay capabilities. European regulators will evaluate actual accessibility, not the presence of a widget. Source-code remediation is required for genuine compliance.
What should I do if I receive an accessibility complaint about my EU-facing website?
Treat it seriously: acknowledge receipt immediately, engage constructively with the complainant, provide a concrete timeline for remediation, document all communications, and begin fixing identified issues immediately. The French retailers' "indifference" turned manageable complaints into litigationβdon't make the same mistake.
Related TestParty Resources
Understanding EAA and International Compliance
- Website Accessibility Remediation: What You Need to Know Now That EAA Enforcement Is Underway
- WCAG 2.2 Is Now ISO 40500:2025: What This Historic Milestone Means
- What Are the Legal Requirements for Website Accessibility?
- What's the Difference Between ADA and WCAG?
WCAG Compliance Guides
- WCAG 2.2 AA Compliance Guide
- What WCAG Conformance Level Do I Need?
- The Technical Hunting Ground: WCAG Violations That Trigger Lawsuits
- Technical Remediation Checklist: The 50-Point WCAG Compliance Audit
Testing and Remediation
- Website Accessibility Testing Checklist: Complete QA Guide
- Automated Accessibility Remediation: Everything You Need to Know
- How Long Does Website Accessibility Take to Fix?
- How to Actually Shift-Left Accessibility
Why Overlays Don't Work
- Can I Install an Accessibility Widget to Avoid Lawsuits?
- The Death of Accessibility Overlays: Why the Industry Is Moving to Source Code
E-Commerce Specific
- Retail E-Commerce Accessibility
- Is My Shopify Store ADA Compliant?
- The Business Case for Digital Accessibility
Sources
- IntΓ©rΓͺt Γ Agir: Assignation en rΓ©fΓ©rΓ© des entreprises Auchan, Carrefour, E. Leclerc et Picard SurgelΓ©s (Primary source, November 2025)
- EcommerceMag: Distribution - 4 gΓ©ants assignΓ©s en justice pour manquement Γ l'accessibilitΓ© (November 12, 2025)
- European Commission: European Accessibility Act Overview
- EUR-Lex: Directive (EU) 2019/882 - European Accessibility Act
- ETSI: EN 301 549 V3.2.1 - Accessibility requirements for ICT products and services
- W3C: Web Content Accessibility Guidelines (WCAG) 2.1
- Lainey Feingold: European Accessibility Act Enforcement and Implementation
- Lainey Feingold: France Digital Accessibility Law
- FTC: Order Requires accessiBe to Pay $1 Million for Deceptive Claims
- World Health Organization: Disability Overview
- W3C Web Accessibility Initiative: WCAG Overview
Last updated: December 9, 2025
The EAA is now being enforced through the courts. Don't wait for a formal complaint to land in your inbox. Get a free accessibility audit and see how TestParty's automated remediation can bring your e-commerce site into EN 301 549 / WCAG 2.2 AA complianceβbefore advocacy groups come knocking.
Stay informed
Accessibility insights delivered
straight to your inbox.


Automate the software work for accessibility compliance, end-to-end.
Empowering businesses with seamless digital accessibility solutionsβsimple, inclusive, effective.
Book a Demo