The European Accessibility Act has been enforceable since June 28, 2025, and its first year settled the core question: partial compliance counts as non-compliance. On June 4, 2026, the Tribunal judiciaire de Caen gave Carrefour six months to make carrefour.fr and its app fully accessible, and rejected the retailer's measured accessibility rate of 71% as a defense. That ruling now defines the website accessibility requirements any business selling to EU consumers faces in 2026.
Your site probably fails. A German survey at the one-year mark put average compliance at 49% of required criteria, and the complaints target basics: missing alt text, low contrast, forms you cannot complete with a keyboard.
You have likely heard of the EAA, maybe installed a widget, and moved on. This article covers year-one enforcement, who the law applies to, why the widget is the expensive option, and the retrofit-or-rebuild math, plus a 15-minute self-audit.
- Carrefour ruling, June 4, 2026: six months to reach full accessibility, daily penalties after the deadline, a 71% score dismissed as insufficient.
- Year-one enforcement ran on court orders and Abmahnungen, fines as the backstop. Germany's first Abmahnung landed in August 2025, six weeks after the deadline.
- Microenterprises are exempt on the services side: fewer than 10 employees and at most 2 million euros in annual turnover. Everyone else selling to EU consumers online is in scope.
- Overlay widgets already failed in the US: the FTC ordered accessiBe to pay $1 million in January 2025 over WCAG compliance claims.
- For template and plugin-heavy sites, a rebuild often beats a retrofit on cost once you price in re-auditing after every theme and plugin update.
What a year of EAA enforcement looks like
The Carrefour case is the loudest data point. Two French disability associations, apiDV and Droit Pluriel, took the retailer to court. The Caen ruling of June 4, 2026 ordered full accessibility of carrefour.fr and the app within six months, with daily penalties after that. Carrefour argued its site already measured 71% accessible; the court held the site must be totally accessible and gave partial scores no legal weight.
Germany moved through lawyers. The first BFSG Abmahnung, a formal cease-and-desist letter, went out in August 2025, six weeks after the deadline. Volume rose through Q1 2026 as market surveillance authorities opened their first proceedings. Reported costs run 3,500 to 20,000 euros per letter, with fines up to 100,000 euros for serious or repeated violations.
Sweden's telecom authority PTS started inspections in October 2025 and logged 124 complaints by mid-2026, 110 of them about services. That number matters more than any fine: complaints are free to file, and every one can start a proceeding.
| Country | What arrived in year one | Cost exposure |
|---|---|---|
| France | Court order against Carrefour: 6-month deadline, daily penalties after | Open-ended daily penalties plus forced remediation |
| Germany | Abmahnung wave from August 2025, authority proceedings from Q1 2026 | 3,500 to 20,000 euros per Abmahnung, fines up to 100,000 euros |
| Sweden | PTS inspections from October 2025, 124 complaints, first e-commerce cases | Fines defined per case, among the EU's highest ceilings |
If your site is in scope and runs on an aging WordPress or page-builder stack, webvise's migration service folds the accessibility baseline into the rebuild itself, so you pay for it once instead of buying it as a separate remediation project.
Does the law apply to your website?
The EAA covers consumer-facing services delivered through websites and apps: e-commerce, banking, transport booking, e-books, and telecom. For most businesses the trigger is simple: consumers can buy, book, or conclude a contract on your site. The obligation attaches to the whole purchase path, from product page through checkout confirmation.
- You sell or take bookings from EU consumers online (checkout, booking calendar, paid subscriptions): in scope, regardless of where your company sits.
- You are a microenterprise providing services: fewer than 10 employees and at most 2 million euros annual turnover means you are exempt under the EAA's services rules.
- Your site is purely B2B with no consumer checkout: outside the EAA's consumer scope, though public tenders and enterprise procurement increasingly require the same WCAG 2.1 AA standard anyway.
- You are in scope and have no accessibility statement: fix that first. A missing statement is the violation a complainant can spot in 10 seconds, and it headlined the early German Abmahnung wave.
The technical bar is EN 301 549, which maps to WCAG 2.1 level AA. Auditors and courts test against those criteria, so 'looks fine to me' has no evidentiary value. Carrefour's 71% was measured against exactly this standard and still lost.
The widget defense already failed
In January 2025 the FTC ordered accessiBe to pay $1 million over its claim that one line of code makes a website 30% compliant immediately and fully WCAG-compliant within 48 hours. The FTC found the claims unsubstantiated: the widget left menus, headings, tables, and images inaccessible on customer sites. The final order stands for 20 years.
The EU enforcement record points the same way. The violations driving German Abmahnungen are structural: alt text missing from the markup, contrast baked into the design, forms that break without a mouse, statements that were never written. An overlay script repaints the page on the client. It does none of the structural work an EN 301 549 audit measures, which is why Carrefour, widget or no widget, stood in court at 71%.
A widget subscription runs 490 to 1,500 euros a year and leaves the underlying markup untouched. You keep paying it forever, and when the complaint arrives you still pay for the real fix. That is the expensive option.
Retrofit or rebuild: the math for template sites
On a WordPress or page-builder site, the markup that fails the audit belongs to a theme and a dozen plugins you do not control. You can patch templates and override CSS, but the next theme update can silently reintroduce the violations, and each plugin swap restarts the audit clock. Remediation on that stack is a subscription, priced like one.
| Retrofit on theme/plugin stack | Rebuild with owned components | |
|---|---|---|
| Who controls the failing markup | Theme and plugin vendors | You, in your own component library |
| Regression risk | Every theme or plugin update can undo fixes | Fixes live in versioned code you review |
| Re-audit cadence | After every significant update | Once per feature you ship |
| Side effects | None. The stack stays slow | PageSpeed 90+ target and lower hosting costs come with it |
| Timeline | Open-ended fix cycle | 2-3 weeks for brochure sites, 4-6 for complex ones |
A rebuild bakes the baseline in. When webvise rebuilt the outdated website of a Brandenburg construction firm as a Next.js site, semantic markup, keyboard-reachable navigation, and contrast-checked components came from the component system itself. The project took 3 weeks, scored 95 on Lighthouse, and accessibility never appeared as a separate line item, because on an owned component stack it is a property of the build, priced at zero extra.
The two objections that stall this decision have their own write-ups: what a redesign actually costs is covered in the 2026 redesign cost guide, and the ranking-loss fear is covered in will I lose SEO rankings if I rebuild. Short version: with a redirect map and metadata preservation, the rankings carry over.
The 5 failures that trigger complaints first
The early German enforcement wave concentrated on the same handful of violations. Each one takes minutes to check. Run this on your own site today.
- Missing alt text. Run Lighthouse's accessibility audit or the free axe DevTools extension. Every content image needs a description; decorative images need an empty alt attribute.
- Contrast below 4.5:1 for body text. Open browser DevTools, inspect your body text and buttons, and read the contrast ratio shown next to the color value.
- Forms that need a mouse. Unplug your mouse and complete your contact form or checkout with Tab, Shift+Tab, and Enter alone. If you get stuck, so does a screen-reader user, and so does the auditor.
- No accessibility statement. In-scope services must publish one that names the standard and lists known gaps. Its absence is the first thing complaint-writers screenshot.
- Invisible focus. Tab through the page and watch for the outline showing where you are. Themes that ship `outline: none` for aesthetics fail this instantly.
The whole pass takes about 15 minutes. If 2 or more items fail and your site is in scope, you are carrying the exact exposure the year-one complaints targeted, and 124 Swedish complainants have already shown how cheap it is to pull the trigger.
Where to start before a complaint lands
Confirm scope first, because the microenterprise exemption resolves this in one sentence for some businesses. Then run the 5-point audit above and count the failures. With that count in hand, price both paths: a remediation quote against your current stack, and a rebuild quote with the baseline included. For sites already showing the other redesign symptoms, the second quote usually wins on 24-month cost.
webvise runs this scope check and 5-point audit on your site before a discovery call, and quotes the retrofit and the rebuild side by side so you can compare real numbers. Book the call here.