European Directive 2019/882, known as the European Accessibility Act (EAA), has applied since 28 June 2025 to consumer-facing digital services provided by companies that do not qualify as micro-enterprises (source: Official Journal of the EU, 17 April 2019). You had four years of transposition lead time, then an application deadline. Those deadlines have passed. France's consumer protection authority (DGCCRF) and the Arcom began checks in January 2026. If you have not yet reviewed the accessibility of your digital services, now is the time to act.
What the directive covers
Directive 2019/882 targets products and services offered to the general public (B2C). On the services side, it applies to e-commerce websites and applications, online banking, transport booking platforms, on-demand audiovisual services, and electronic communications services (messaging, internet calls).
The exemption covers micro-enterprises, defined as entities with fewer than 10 employees and an annual turnover below 2 million euros (source: Article 4, paragraph 5 of Directive 2019/882). If your organisation exceeds either of these two thresholds, the exemption does not apply.
An important clarification for existing services: a service deployed before 28 June 2025 may, under certain conditions, benefit from a technical compliance deadline extended to 28 June 2030. This extension does not waive the obligation to publish an accessibility statement or produce a multi-year accessibility plan: both documents are required now.
The three minimum obligations
Three elements form the minimum documentary basis. Their absence is an immediately verifiable breach, independent of the actual technical state of your service.
The accessibility statement. It describes the compliance status (fully compliant, partially compliant, non-compliant), lists unsatisfied criteria and any applicable exemptions, provides users with a mechanism to report anomalies, and states the date of the last audit. It must be reachable from every page of the service, typically via the footer or a dedicated link.
The multi-year accessibility plan. This planning document describes remediation commitments over three years: resources allocated, scope of planned audits, correction schedule. Its absence constitutes a documentary breach distinct from technical non-compliance.
The RGAA 4.1.2 compliance audit. France's General Accessibility Improvement Reference Framework, published by DINUM, is aligned with the WCAG 2.1 Level AA success criteria. It covers 106 criteria across four principles: perceivable, operable, understandable, robust. A result below 75 percent of satisfied criteria generally corresponds to partial compliance; below 50 percent, the service is considered non-compliant.
What the controls examine in practice
The DGCCRF oversees B2C service providers; Arcom covers audiovisual operators. Checks focus primarily on four areas:
- The presence and content of the accessibility statement: is it published, up to date, and does it honestly list known non-conformities?
- Critical journey compliance with WCAG 2.1 AA criteria: keyboard navigation, colour contrast ratios (minimum 4.5:1 for body text), text alternatives for images, explicit form labels.
- Compatibility with assistive technologies (screen readers such as NVDA, JAWS or VoiceOver on the main platforms).
- The presence of a functioning reporting mechanism allowing users to flag an anomaly and receive a response within a reasonable time.
Penalties under consumer protection law vary by severity and recurrence of the breach. Failure to publish an accessibility statement is a documentary breach distinct from technical non-compliance: both can be identified simultaneously, each giving rise to a separate measure.
A concrete example
Consider an online fashion retailer. Its product catalogue is visually sound, but the sorting filters (size, colour, price) are not keyboard-navigable. The labels on basket fields are not programmatically associated with their form controls. The alt attribute on every product image contains only the word "Image", with no description of the garment.
In this case, at least three WCAG 2.1 AA criteria are unsatisfied: 1.1.1 (non-text content), 1.3.1 (information and relationships), 2.1.1 (keyboard). The service is partially compliant at best. Its accessibility statement must list these non-conformities. If it does not, or does not exist at all, the authorities have grounds to act.
This is not a hypothetical scenario. Automated checks using tools such as Axe DevTools, Lighthouse or the DINUM validator identify most of these anomalies in under an hour, without a full specialist audit.
What you must do now
If you have not yet taken action, three steps are required in order of priority.
Run an initial automated review. An automated checking tool (Axe DevTools, Lighthouse, WAVE) gives an initial picture in a few hours. It does not replace a full RGAA audit, but it identifies the most frequent and most easily verifiable anomalies: insufficient contrast ratios, images without text alternatives, forms without labels, absent keyboard focus.
Publish an accessibility statement. Even a partial or non-compliant statement that honestly lists known issues and commits to a correction schedule is far better than no statement at all. DINUM provides an official statement generator on the accessibilite.numerique.gouv.fr portal. Without any document, your service is immediately in documentary breach, regardless of its actual technical state.
Plan remediation by criticality. Purchase, registration and authentication journeys come first: these are what the authorities check first and where non-compliance excludes the largest number of users. Static content (legal pages, editorial copy) can be addressed in a second phase. The consistency between your multi-year plan and this schedule is what an inspector will read first.
For full remediation support or a formalised RGAA audit, our accessibility remediation service guides you from initial diagnosis through to a published statement.
What the EAA reveals about your digital obligations
Digital accessibility is not a comfort requirement. It determines access to digital services for roughly 15 percent of the European population affected by a permanent disability (source: World Health Organization, World Report on Disability, 2023). Excluding these users from a purchase journey or an online banking service is no longer a tolerable technical omission: it is a legal breach subject to active enforcement.
The logic mirrors what we describe for the GDPR in our article on the three silent pillars of GDPR compliance: in both cases, organisations that treated compliance as a box to tick rather than a state to demonstrate find themselves exposed once enforcement begins. The difference with the EAA is that the technical state of your pages can be verified in minutes by any inspector.
The EAA is not a future constraint. It has applied for sixteen months and is being actively enforced. The question is no longer whether your service will be audited, but when. Organisations that prepared have today a published statement, a multi-year plan and a documented first audit. The others are managing an emergency.