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French Supermarkets Hit With EAA Legal Notices: What UK Developers Need to Know

French retailers face legal action under the European Accessibility Act. Here's what UK web developers need to understand about EAA compliance.

French Supermarkets Hit With EAA Legal Notices: What UK Developers Need to Know

Two French disability advocacy groups have sent formal legal notices to four major grocery retailers—Auchan, Carrefour, E.Leclerc, and Picard Surgelés—alleging their online shopping platforms fail to meet European Accessibility Act (EAA) requirements. This happened just days after the EAA enforcement deadline of 28 June 2025.

This is the first significant enforcement action under the EAA, and it signals that the law has teeth. If you're building websites for clients who sell to EU customers, here's what you need to understand.

What the EAA Actually Requires

The European Accessibility Act applies to products and services sold within the EU, including:

  • E-commerce websites and apps
  • Banking services
  • E-books and e-readers
  • Transport ticketing services
  • Telecommunications

The technical standard referenced is EN 301 549, which maps closely to WCAG 2.1 Level AA. If your site meets WCAG 2.1 AA, you're most of the way there.

The key WCAG success criteria that typically cause problems for e-commerce sites include:

  • 1.4.3 Contrast (Minimum): Text needs a contrast ratio of at least 4.5:1. Many retail sites fail this on promotional banners and call-to-action buttons.
  • 2.4.7 Focus Visible: Users navigating by keyboard must see where they are on the page. CSS resets that remove focus outlines break this.
  • 1.3.1 Info and Relationships: Form labels must be programmatically associated with their inputs. Placeholder text alone doesn't count.
  • 4.1.2 Name, Role, Value: Custom components like quantity selectors, filters, and accordion menus need proper ARIA attributes.

Why This Matters for UK Developers

Post-Brexit, the UK isn't bound by the EAA. But that's not the point.

If your client sells to EU customers—even from a UK-based website—the EAA applies to them. The law covers services "made available to consumers in the Union," regardless of where the business is headquartered.

This means:

  • A UK e-commerce site shipping to France, Germany, or any EU country falls under EAA scope
  • A UK company offering digital services to EU residents needs to comply
  • UK agencies building sites for EU-based clients are creating products that must meet EAA requirements

The French legal notices specifically targeted online grocery platforms. These sites typically have complex product filtering, shopping basket functionality, and checkout flows—all areas where accessibility failures cluster.

What Enforcement Looks Like

Each EU member state implements the EAA through national law, which means enforcement varies. In France, disability organisations can issue formal legal notices requiring businesses to address accessibility barriers. If the business doesn't respond adequately, court action follows.

Penalties under the EAA can include:

  • Fines (amounts vary by country)
  • Orders to make services accessible within set timeframes
  • Prohibition from selling services until compliance is achieved

The French cases will be worth watching. If the retailers settle quickly and remediate their sites, it establishes a pattern of successful advocacy. If cases go to court, we'll see how judges interpret the technical requirements.

Practical Steps for Your Projects

1. Audit existing e-commerce builds

Run automated scans to catch the obvious issues—missing alt text, contrast failures, empty links. Then do manual testing: can you complete a purchase using only a keyboard? Does the site work with a screen reader?

2. Fix the checkout flow first

This is where legal risk concentrates. Form validation errors must be clearly announced. Payment forms need proper labelling. Progress indicators should be accessible.

3. Test product filtering and search

Custom filter components often lack keyboard support and screen reader announcements. When a user applies a filter, is the results update announced? Can they clear filters without a mouse?

4. Document your compliance efforts

The EAA requires businesses to provide accessibility statements. Help your clients create these. Include what standards you've tested against, known limitations, and contact details for accessibility feedback.

5. Build accessibility into your process

Retrofitting accessibility is expensive. Testing during development catches issues when they're cheap to fix. Add accessibility acceptance criteria to your tickets.

The Bigger Picture

The French legal notices are a preview of what's coming across the EU. Advocacy groups have been waiting for the EAA enforcement date, and they're now equipped with a legal framework to challenge inaccessible services.

For UK developers, this creates both risk and opportunity. Clients who ignore accessibility face potential legal action in EU markets. Agencies who can deliver compliant sites have a competitive advantage.

The technical requirements aren't mysterious—WCAG 2.1 AA has been the standard for years. What's changed is that there are now consequences for ignoring it.

WCAGCheck scans your website for WCAG compliance issues and tells you exactly what to fix. Try it free at wcagcheck.co.uk