What the Carrefour ruling actually decided

On 4 June 2026 the Tribunal judiciaire de Caen ordered Carrefour France to make carrefour.fr and its mobile app accessible within six months, under a penalty of 500 euros for each day it runs late. The part worth reading twice is not the penalty. It is what the court did with Carrefour's defence.

A conformance score is not a defence

Carrefour argued that its site was 71% conformant with the RGAA, the French accessibility reference framework. The court rejected that. Accessibility, it held, is an obligation of result: a shop cannot be partly accessible any more than a staircase can have most of a handrail. The applicable criteria have to be met.

If you sell a percentage as proof of compliance, or buy one, this is the sentence that matters. A score tells you where you stand and whether you are improving. On this reasoning it will not stand in for conformance.

What the decision does not say

Three things are worth being straight about, because the opposite is being written elsewhere.

The law is not settled. A similar claim against Auchan's e-commerce arm was rejected by the Lille tribunal in early May 2026, a month earlier. It did not fail on accessibility: the court read the EAA transposition through the 2005 law rather than as an autonomous regime, which put the EUR 250 million turnover threshold in the way, and the claimants have appealed. Two courts, two outcomes, one of them unfinished. Anyone presenting Caen as the settled position is overstating it.
No regulator issued a fine. This came from disability associations, apiDV and Droit Pluriel with the support of Intérêt à Agir, going to court. The realistic trigger is a claim from people who cannot use your service, not an inspection.
It is a French decision. It applies the RGAA and the French transposition. The European Accessibility Act has applied across the EU since 28 June 2025 and each member state enforces its own version, so the direction of travel is shared while the mechanics are not.

What enforcement actually looks like in 2026

The maximum penalties written into the national transpositions are being quoted everywhere as though they were being handed out. They are not. As of September 2026, no fine has been issued under any EAA transposition anywhere in the EU. Three things are happening instead.

Court claims

Disability associations, not regulators, brought the case that produced the only order so far. Carrefour, Caen, June 2026.

Regulator reviews

Sweden's PTS published the names of 28 e-commerce services it is checking, and says it tests the homepage, one product page and the search function.

Complaint queues

Germany's MLBF, operational in Magdeburg since September 2025, reported close to 700 filed reports by June 2026. No penalty has followed.

None of the three gives notice. All three are answered the same way: with a dated record showing you knew what was wrong and were fixing it. That is also why this page will keep saying no fine has been issued for exactly as long as that stays true.

What this means if you run a site

The uncomfortable part is that most of what got Carrefour here is not machine-detectable. Whether a blind customer can complete a purchase is a question about a journey, and no scanner answers it. Automated testing covers about a third of the WCAG success criteria: contrast, missing text alternatives, unlabelled controls, structure. Useful, and not the whole picture.

What automation is genuinely good for is finding the machine-checkable failures quickly, and leaving a dated record that you found them and fixed them. If a claim ever arrives, the argument you want to be able to make is not that you scored well. It is that you knew what was wrong and were demonstrably fixing it.

Start with what is findable

Conforma scans against WCAG 2.2 AA, gives a fix for every issue it finds, and keeps a dated record of the ones you close. It does not issue certificates, and it will tell you what it did not test.

Common questions

Does a conformance percentage protect me?

Not on the reasoning in this decision. Carrefour put forward a 71% RGAA conformance rate and the court rejected it, holding that accessibility is an obligation of result: an online shop cannot be somewhat accessible, it has to meet the applicable criteria. A score is useful for knowing where you stand and for showing progress. It is not a defence.

Have regulators started fining companies under the EAA?

No. As of September 2026 no fine has been issued under any EAA transposition anywhere in the EU. The pressure so far has come from disability associations bringing cases and from complaints reaching market surveillance bodies, not from penalties. That matters for planning, because it means the trigger is a claim rather than an inspection, and claims tend to follow the sites people actually cannot use.

What are regulators doing instead of fining?

Reviewing and collecting complaints. Sweden's PTS published a list of 28 named e-commerce services it is checking, and said when it opened the review in October 2025 that it checks the homepage, one product page and the search function. Germany's market surveillance body for the BFSG, the MLBF in Magdeburg, has been operational since September 2025 and said in June 2026 that it was working through close to 700 reports. Neither has issued a penalty. Both arrive without notice.

Is the case law settled?

No. A similar claim against Auchan's e-commerce arm was rejected by the Lille tribunal in early May 2026, a month before the Caen decision, and that dismissal is under appeal. It turned on scope rather than accessibility: the court treated the EAA transposition as subordinate to the 2005 law, which brought a EUR 250 million turnover threshold into play. One ruling in one direction, one in the other, and one appeal pending is not a settled position, and anyone telling you the law is now clear is selling something.

What does an automated scan actually cover?

About a third of the WCAG success criteria: the machine-checkable ones such as contrast, missing text alternatives, unlabelled controls and page structure. Keyboard operation, whether a screen-reader user can actually complete a purchase, and whether the flow makes sense are not things a scanner can judge. Any tool claiming otherwise is overselling.

So what is worth doing?

Fix what is findable, keep a dated record of having done it, and get a human to walk the critical journeys. The record is the part people skip, and it is the part that demonstrates good faith if a claim ever arrives.

Sources

This page describes a public court decision and is not legal advice. Figures are limited to those the sources state.