European Accessibility Act: inspections, penalties and e-commerce checklist

The European Accessibility Act has applied since 28 June 2025, and the DGCCRF (the French consumer protection and fraud control authority) now checks online retail sites. Who is affected, which authorities check what, what the penalties are, which standard to follow: this guide takes stock as of 19 September 2026 and gives you a practical checklist to make your purchase journey accessible.

European Accessibility Act: what has applied since 28 June 2025

Directive (EU) 2019/882, known as the European Accessibility Act (EAA), sets accessibility requirements for a list of products and services intended for consumers, applicable since 28 June 2025 [1].

One directive, several French texts

The products and services covered

According to the DGCCRF [2]:

• products: computers and operating systems, payment terminals, cash machines and interactive kiosks, smartphones and telecommunications equipment, television equipment, e-readers;
• services: telephony, access to audiovisual media, elements of transport services (websites, apps, e-tickets, information), consumer banking services, e-books, e-commerce, emergency communications to 112.

An “e-commerce service” covers any website or app that allows a consumer to conclude a distance contract [1], for the sale of any product or service.

Who is affected? Thresholds and exemptions

The scope is B2C: a portal reserved for professionals is not covered.

The microenterprise exemption

The directive defines a microenterprise as a business that employs fewer than ten people and whose annual turnover or annual balance sheet total does not exceed €2 million [1]. Microenterprises that provide services are exempt from the accessibility requirements (article 4(5)). For products, the DGCCRF specifies that they may derogate without having to justify themselves [2].

Disproportionate burden and fundamental alteration

Two derogations exist for other businesses: where accessibility would entail a fundamental alteration of the service, or impose a disproportionate burden, assessed against the criteria in the annex to article D. 412-60 of the Consumer Code [2][4]. In both cases, you must document the assessment and inform the DGCCRF through the online procedure “Declaration of non-compliance or invocation of an exemption”. France Num warns that this derogation is hard to obtain for a service launched after 28 June 2025, which must build in accessibility from the design stage [4].

Transitional period: why your website does not benefit from it

Article 32 of the directive provides for transitions, which France has taken over [1][2]:

• providers may, until 28 June 2030, continue to provide their services using products that they lawfully used before that date;
• B2C service contracts concluded before 28 June 2025 may run unchanged until their term, at the latest 28 June 2030;
• self-service terminals in use before 28 June 2025 may be used until the end of their economic life, within a limit of fifteen years in France (the directive allowed up to twenty).

The DGCCRF is explicit: a website or a mobile app is not a product within the meaning of the directive [2]. An online shop that existed before June 2025 therefore had to be accessible from 28 June 2025.

Who checks what: DGCCRF, Arcom and the others

The first inspections

The review published by the DGCCRF on 25 June 2026 shows the scale of the action taken [3]:

• from April 2025 to March 2026, a survey of rail transport covered 38 establishments. Among the defects found were websites that were not fully compliant, followed by corrective and educational measures;
• since January 2026, three surveys are under way, including one on the accessibility of online retail websites and apps and on the fairness of accessibility audit providers;
• in total, around a hundred establishments will be inspected in 2026;
• since December 2025, consumers can report an accessibility defect on SignalConso, which is used to target inspections.

On the Arcom side, a decision of 24 June 2026 served formal notice on the ministry in charge of public accounts to bring impots.gouv.fr into compliance [6].

Penalties: what you risk

On a purchase journey, several obligations may be at issue at the same time: it is the accumulation that drives up the bill.

RGAA, EN 301 549, WCAG: which standard to follow?

DINUM is preparing RGAA 5, announced for the end of 2026, which will incorporate WCAG 2.2; its criteria “will clarify or supplement those of RGAA 4.1.2, without contradicting them”, and statements drawn up before its publication will remain valid for 18 months [8]. Conclusion: don’t suspend anything, audit against RGAA 4.1.2 today.

Accessibility information and accessibility statement

Two obligations coexist:

• for every provider subject to the EAA: publish information on the accessibility of the service, in the terms and conditions or an equivalent document (Annex V of the directive): description of the service in an accessible format, explanations of how it works, how the requirements are met [1]. France Num recommends an “Accessibility information” page stating the standard used, any derogations and at least two means of contact [4];
• for bodies covered by article 47 (public sector, delegates, companies with turnover above €250 million): the accessibility statement and the display notices checked by Arcom [5].

E-commerce operational checklist

The purchase journey from end to end

Annex I of the directive explicitly covers identification, security and payment functions [1]. Test the whole journey, not the home page:

• [ ] Search and filters usable by keyboard and announced to screen readers
• [ ] Product page: informative images with a text alternative, variants (size, colour) selectable without a mouse
• [ ] Accessibility information for the products sold displayed when the manufacturer provides it
• [ ] Basket: quantities can be changed, total updated and announced
• [ ] Choice of delivery method and point is accessible, including the pick-up point map (with a list alternative)
• [ ] Payment: the provider’s module tested (iframe, 3-D Secure), not just your page
• [ ] Account creation, login and captcha with an accessible alternative
• [ ] Order confirmation and emails properly structured

Forms

• [ ] Every field has a visible, associated label
• [ ] Required fields and expected formats indicated before input
• [ ] Errors identified in text, with a suggested correction (WCAG 3.3.1 and 3.3.3)
• [ ] Autocomplete enabled on identity and address fields
• [ ] No session timeout that loses the user’s input without warning

Contrast, zoom and layout

• [ ] Text contrast of at least 4.5:1 (3:1 for large text) and 3:1 for interface components
• [ ] Content readable at 200% zoom and with no horizontal scrolling at 320 px wide
• [ ] Information never conveyed by colour alone (stock, error, promotion)

These choices are made at the UX/UI design stage, which is far cheaper than fixing later.

Keyboard and focus

• [ ] The whole journey can be completed by keyboard, in a logical order
• [ ] Focus always visible, never hidden by a sticky banner
• [ ] Modals (side basket, cookies): focus trapped inside and restored on closing
• [ ] Skip link to the main content

Screen readers

• [ ] Unique page titles and a consistent heading hierarchy
• [ ] Buttons and links with an explicit name (no “click here” or silent icon)
• [ ] Status messages announced (“product added to basket”)
• [ ] Real test with NVDA or JAWS on Windows and VoiceOver on iOS
• [ ] Help chatbot that is accessible, and that announces it is an AI if it is one (see our article on the AI Act and Article 50)

Automated or manual audit?

The two are complementary: automated testing prevents regressions, manual auditing establishes compliance. Example of a guardrail in a CI, with Playwright and axe-core:

import { test, expect } from '@playwright/test';
import AxeBuilder from '@axe-core/playwright';

const etapes = ['/panier', '/commande/livraison', '/commande/paiement'];

for (const url of etapes) {
  test(`accessibilité automatique ${url}`, async ({ page }) => {
    await page.goto(url);
    const resultat = await new AxeBuilder({ page })
      .withTags(['wcag2a', 'wcag2aa', 'wcag21a', 'wcag21aa'])
      .analyze();
    expect(resultat.violations).toEqual([]);
  });
}

A green test does not prove compliance, only the absence of a detectable regression: it fits into a quality assurance and testing approach.

Frequently asked questions

Making your purchase journey accessible, step by step

The European Accessibility Act is an enforced obligation, with targeted surveys on online retail in 2026. The sequence: check whether you are affected, audit the purchase journey against RGAA, publish your accessibility information, fix things step by step, then lock them in with automated tests.

At iones, we work on every link in the chain: audit, fixes in web development on PrestaShop, WooCommerce or React and Next.js front ends, then long-term follow-up with application maintenance, on a white-label basis for agencies. Want to know where your checkout funnel stands? Contact us: reply within 48 to 72 hours, no-commitment discussion, under NDA.