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July 27, 2026 · 3 min read

The European Accessibility Act turns one: what enforcement actually looked like

The European Accessibility Act passed its first birthday on June 28. A year earlier, a lot of teams had been told the deadline would arrive with fines attached. It didn't. What arrived instead was slower, stranger, and — if you publish content for a living — more useful to know about.

Two French rulings, pointing opposite ways

In July 2025, two French disability associations, apiDV and Droit Pluriel, put four of the country's largest retailers on formal notice: Auchan, Carrefour, E.Leclerc, and Picard. When their deadline passed, they filed emergency injunction proceedings.

The first ruling landed on May 5, 2026, and the retailer won — which is the part that got quoted. Read the reasoning and it's narrower than it sounds. The Lille court dismissed the case over which French revenue threshold applied to the entity being sued, not over whether the site worked. In the same decision it described the site's accessibility as "fairly low," with strong or major failures across 13 of the 19 sections the associations had audited. The associations filed an appeal two days later.

The second ruling, on June 4, went the other way. A court in Caen ordered Carrefour to make its website and mobile app accessible within six months, with a €500-per-day penalty for every day it runs late. Carrefour's defense had been its own published conformance rate — around 71% against the RGAA, France's accessibility standard. The court treated accessibility as an obligation of result. Under that standard there is no passing grade below 100%.

A conformance percentage on your accessibility statement is a claim, not a defense.

Everywhere else, it got quieter and more organized

Sweden's regulator widened its e-commerce supervision programme from 28 sites to 39 in March 2026. Germany's federal market surveillance body for accessibility has been running since September 2025. In Norway, a public health portal drew a daily penalty of roughly €4,500 that accumulated until the problems were fixed. In the Netherlands, the consumer authority found that most of the country's largest online retailers still fell short as of March 2026, with active enforcement expected in the second half of this year.

That isn't a wave of fines. It's the same shape as the first year of GDPR: inventory, guidance, and observation first, consequences after.

Where this actually lands on a marketing team

Here's the detail worth carrying out of the French cases. The audits that ended up in front of a judge weren't automated scans. The associations assembled a committee of blind and partially sighted testers and walked the journeys that matter — finding a product, adding it to a cart, paying for it.

Undescribed images are one of the most ordinary things those walkthroughs turn up, and they're different from most accessibility defects in one important way: they aren't created once in a redesign and then fixed. They're created every day, by publishing. A site can ship a perfect component library and still accumulate hundreds of silent images in a year of campaigns.

What a screen reader says todaybanner underscore summer sale v3 dot j-p-g
What it could saySummer sale banner: up to 40% off outdoor furniture, ends August 9

Nobody in engineering is going to write that second line for the graphic you posted this morning. It belongs to whoever pressed publish.

What to take from year one

Not legal advice, and the open questions are genuinely open — the French appeal will decide which companies the national rules reach. But the practical read is steady: "mostly accessible" isn't a category anyone is being graded on, self-declared scores haven't held up when tested, and regulators are building records rather than issuing headlines. The teams that come out of this well won't be the ones who audited once. They will be the ones who made describing an image part of publishing it.

Describe it as you publish it

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