EAA Enforcement Tracker

The first private-sector accessibility condemnation of the EAA era. Disability associations apiDV and Droit Pluriel sued Carrefour in summary proceedings over its e-commerce site and app. Carrefour argued 71% RGAA conformance was enough; the court rejected that outright — accessibility is an "obligation of result," meaning full conformance, not a passing grade. Carrefour has six months to reach 100% RGAA or pay €500 per day (statutory ceiling €3,000/day, capped at €300,000).

Spain's National High Court confirmed a €90,000 fine plus a temporary ban on receiving public funds after Vueling's website failed 26 of 38 accessibility indicators — disabled customers could not independently complete bookings, check in online, or manage reservations. The public-funds ban often matters more than the headline figure for airlines that receive aviation subsidies.

* Pre-EAA legal basis; substance equivalent to EAA requirements.

The same associations sued Auchan, but Lille dismissed the case on a threshold technicality: the court applied the old 2005 law's €250M-revenue trigger rather than the €2M e-commerce threshold under the 2019 directive — even while noting Auchan was only 41% RGAA-compliant. The associations have appealed to the Cour d'appel de Douai. A procedural escape, not a finding that the site is acceptable — and the interpretation is contested.

Two of the four original association référés — against E.Leclerc and Picard — are still awaiting hearings. Separately, the DGCCRF (the consumer-protection regulator, a distinct track from the association lawsuits) began field controls in January 2026, currently pedagogical, with a first sector probe into rail-transport online booking. No regulatory fine published yet.

Specialist law firms have sent Abmahnungen to German e-commerce operators since the BFSG took effect, on the theory that an inaccessible competitor gains an unfair advantage (UWG). Settlements run €1,500–€4,000 plus a contractual penalty. The state market-surveillance authority (MLBF, Magdeburg) became operational and entered active control in Q1 2026 — statutory fine band €10k–€100k — but no operator has been publicly named under the BFSG yet. The private Abmahnung track remains the only live mechanism.

† Aggregate of private settlements; individual amounts not publicly recorded.

ACM can fine up to €900,000 or 1% of annual turnover per violation and runs the most mature reporting regime in the EU, coordinated across six sector enforcers (ACM, AFM, ILT, RDI, CvdM, NVWA). It has published that 61% of the largest Dutch webshops are not accessible and says it will name the worst performers — but no individual penalty decision has landed yet. ACM signals a supportive posture toward firms that demonstrably take steps. First fines expected later in 2026.

Often miscited as a live six-figure penalty — it never was. Norwegian authorities ruled on 8 December 2025 that HelsaMi must fix accessibility failures (form labeling, focus management, AT compatibility) by 19 December or face a coercive fine of NOK 50,000/day. HelsaMi fixed the issues in time; a follow-up test on 23 December confirmed compliance and the supervision was closed. The daily penalty was never triggered — the threat alone forced the fix. A clean example of how the daily-penalty mechanism is meant to work.