In short: since 28 June 2025, the European Accessibility Act (EAA) has required private companies that sell online or provide certain digital services to consumers to make their websites and apps accessible to people with disabilities. Service micro-enterprises (fewer than 10 people, with an annual turnover or balance sheet total not exceeding €2 million) are exempt; other companies can only derogate in limited, documented cases. In France, the working standard is the RGAA, aligned with WCAG 2.1 level AA. As a rough guide, expect €2,000 to €8,000 for an audit, and anywhere from a few thousand to several tens of thousands of euros for fixes, depending on the state of your product.
For a long time, accessibility remained a matter of goodwill for most private companies. That is no longer the case. On 4 June 2026, the Caen court ordered Carrefour France, in summary proceedings, to make its grocery website and app fully accessible within six months, with a penalty of €500 per day of delay. The company argued that it was 71% compliant; the judge held that an e-commerce site cannot be "only a little accessible".
This article is for founders, CTOs and SME leaders who want to know, in concrete terms, whether they are affected, what they risk and how to organise themselves without stalling their roadmap. It is not legal advice: for borderline cases, have your situation reviewed by a lawyer.
What does the European Accessibility Act change for private companies?
The EAA is Directive (EU) 2019/882. It harmonises accessibility requirements for certain products and services across the Union. France transposed it notably through Law No. 2023-171 of 9 March 2023 and Decree No. 2023-931 of 9 October 2023, with provisions added to the Consumer Code.
Before the EAA, the French requirement (Article 47 of the law of 11 February 2005) mainly targeted the public sector and companies with more than €250 million in turnover. Since 28 June 2025, the scope has widened considerably: it no longer depends only on your size, but mainly on what you offer.
In practice, a covered service must:
- be usable by people who are blind, partially sighted, deaf, or who have a motor or cognitive disability, in particular with a screen reader, with a keyboard only or with heavy zoom;
- provide information about its accessibility, usually as an accessibility statement indicating the level of compliance and how to report a problem;
- keep that accessibility over time, with every new feature.
Is your company affected?
Ask yourself two questions: do you offer one of the covered services, and are you larger than a micro-enterprise?
| Service | Examples | Covered by the EAA |
|---|---|---|
| E-commerce | Online shop, marketplace, ordering app, paid appointment booking | Yes |
| Consumer banking services | Neobank, payment app, online credit | Yes |
| Passenger transport | Booking website and app, e-tickets, travel information | Yes |
| Electronic communications | Telecoms operator, messaging, internet telephony | Yes |
| E-books | E-reader, reading platform, dedicated software | Yes |
| Access to audiovisual services | Streaming app, programme guide | Yes |
| B2B SaaS for businesses | Management software, internal business tool | In principle no, unless it includes a consumer purchase journey |
| Brochure site with no sales | SME presentation site, blog | In principle not under the EAA |
A few points to watch:
- The notion of e-commerce is broad. As soon as a consumer can enter into a contract with you online, whether a purchase, a subscription or a booking, you are probably covered.
- The micro-enterprise exemption is narrow. It only applies to services and requires fewer than 10 people, with an annual turnover or balance sheet total not exceeding €2 million. An eight-person startup whose turnover and balance sheet total both exceed €2 million is no longer exempt: check your situation every year.
- Other derogations are strictly framed. A company can invoke a disproportionate burden or a fundamental alteration of its service, but it must justify this with a written assessment and be able to present it to the supervisory authorities.
- Your B2B customers will ask for it. Even if your SaaS is not directly covered, a retailer subject to the EAA that embeds your payment, booking or chat widget in its journey will require it to be accessible. Accessibility is becoming a purchasing criterion.
- The public sector remains subject to the RGAA under Article 47, with a mandatory accessibility statement and multi-year plan.
What do you risk if you are not compliant?
Today, the risk takes three forms.
Administrative inspections
For online retail and consumer services, inspections are mainly carried out by the DGCCRF (the French consumer protection authority), alongside other regulators depending on the sector (Arcom, ARCEP, ACPR). The usual procedure starts with a formal notice, followed by administrative fines and possibly daily penalties if nothing is fixed. Within the scope of Article 47 (the public sector and very large companies), Arcom can impose penalties of up to €50,000 per service.
Lawsuits
This is the real development of 2026. Disability associations are now taking companies to court. The Caen order against Carrefour shows that a judge can impose a short deadline and a daily penalty. Conversely, on 5 May 2026, the Lille court dismissed a similar claim against Auchan's e-commerce subsidiary on the grounds of the turnover threshold; an appeal is under way before the Douai Court of Appeal. Case law is therefore not yet settled, but the direction of travel is clear.
Commercial risk
Someone who cannot complete a purchase with their screen reader does not come back. A large account that requires a compliance report in its tender rules out suppliers who cannot provide one. And some accessibility fixes (clean HTML structure, alternative text, a proper heading hierarchy) also benefit your technical SEO.
RGAA, WCAG, EN 301 549: which standard should you follow?
The acronyms overlap, but the logic is simple.
| Standard | What it is | When to use it |
|---|---|---|
| WCAG 2.1 / 2.2 | International W3C guidelines, levels A, AA and AAA | Common technical basis for all standards |
| EN 301 549 | Harmonised European standard, which includes WCAG 2.1 AA and adds requirements for software and apps | Reference for demonstrating EAA compliance |
| RGAA 4.1 | French methodology with 106 criteria and precise tests | Reference in France for auditing a website and writing the statement |
In practice, targeting WCAG 2.1 level AA, audited using the RGAA methodology for the web, covers most expectations. For a native or React Native mobile app, the audit relies on EN 301 549 and on iOS and Android best practice, since the RGAA is designed for the web.
Mobile apps: the most common mistakes
Apps are often the poor relation of accessibility, even though they account for a growing share of purchases. Here is what we most often find during an audit:
- Buttons with no accessible name: a basket or heart icon that the screen reader (VoiceOver, TalkBack) announces simply as "button".
- Touch targets that are too small: elements smaller than 44 points across, hard to activate with a motor disability.
- Insufficient contrast: light grey text on a white background, very common in "clean" interfaces.
- Fixed text sizes: the app ignores the phone's font size setting, or its layout breaks when text is enlarged.
- Blocking journeys: a modal that does not return focus, a carousel that cannot be paused, a third-party payment form that is not accessible.
- Visual-only error messages: a field that turns red with no explanatory text.
In React Native, most of these issues can be fixed with the native properties designed for the purpose (role, label, state, font scaling support), provided they are built into the base components rather than added screen by screen.
How much does compliance cost?
Prices published by providers converge on the following orders of magnitude. They depend mainly on the number of distinct templates (product page, basket, account, checkout) rather than the total number of pages.
| Service | Order of magnitude | Indicative timeframe |
|---|---|---|
| Pre-audit of a few key pages | €1,000 – €2,000 | A few days |
| RGAA audit of an e-commerce site or SaaS | €2,000 – €8,000 | 1 to 3 weeks |
| Mobile app audit (iOS and Android) | €4,000 – €10,000 | 2 to 4 weeks |
| Fixes on a recent, well-structured product | €5,000 – €20,000 | 2 to 6 weeks |
| Fixes on an older product or one with heavy technical debt | €20,000 – €60,000 and more | 2 to 6 months |
| Accessibility built in from the design stage of a new product | Limited extra cost, absorbed into the development budget | No significant extra time |
Three factors drive the bill up:
- No design system. If every screen reinvents its buttons and fields, every screen has to be fixed. With an accessible design system, one fix propagates everywhere.
- Third-party components. An inaccessible payment, chat or map module can block an entire journey, and you do not control its code.
- Technical debt. On an ageing front end, fixing accessibility sometimes means rewriting whole sections. It is a good moment to weigh fixes against an application redesign.
How do you go about it without stalling your roadmap?
- Check your scope: list your services, your consumer journeys and your size. Write down your analysis, even if you conclude that you are exempt.
- Pre-audit your critical journeys: sign-up, search, product page, basket, payment, contact. That is where the legal and commercial risk is concentrated.
- Prioritise blockers: a journey that cannot be completed with a keyboard or screen reader comes before a contrast issue on a secondary page.
- Fix at the source: base components, design system, templates. It pays off far more than fixing page by page.
- Publish your accessibility statement, honest, with a contact method for reporting problems and a dated improvement plan.
- Make accessibility part of everyday work: criteria in your definition of done, automated tests in continuous integration, and a manual screen reader test before every significant release.
Automated tools (Lighthouse, axe, WAVE) are useful for catching obvious errors, but they only detect some of the problems. A human audit remains essential to assess a complete journey.
If you bring in a provider for a new project, require accessibility to be written into the contract and the acceptance criteria. It is one of the points we recommend checking to choose the right development agency.
Frequently asked questions
Is my company required to make its website accessible in 2026?
Yes, if you offer a service covered by the European Accessibility Act, in particular online sales to consumers, banking services, passenger transport or electronic communications, and you are not a service micro-enterprise, meaning fewer than 10 people with an annual turnover or balance sheet total not exceeding €2 million. A simple brochure site with no sales is in principle not covered by the EAA.
Is a B2B SaaS covered by the European Accessibility Act?
In principle, software sold only to businesses does not fall directly within scope, as the EAA targets services aimed at consumers. However, if your SaaS provides a component used in a consumer journey, such as a payment, booking or chat module, your customers subject to the EAA will ask you to make it accessible.
What is the difference between the RGAA and WCAG?
WCAG are the international W3C guidelines. The RGAA is the French methodology that translates those guidelines into 106 verifiable criteria with precise tests. Targeting WCAG 2.1 level AA and auditing against the RGAA is the most common way to demonstrate compliance for a website in France.
How much does an RGAA accessibility audit cost?
For an e-commerce site or a SaaS, expect roughly €2,000 to €8,000 depending on the number of templates to audit, and a little more for a mobile app on iOS and Android. Fixes should be budgeted separately: from a few thousand euros on a recent product to several tens of thousands on an older one.
Is an automated tool or an overlay enough to be compliant?
No. Automated tools such as Lighthouse or axe only detect some of the errors, and overlays that promise compliance with a single line of code do not fix structural, keyboard navigation or screen reader issues. They have also been criticised by many disability associations. Only fixing the code, validated by a human audit, makes a service genuinely accessible.
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