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The European Accessibility Act has applied since 28 June 2025. If you sell to consumers online and have ten or more staff, your website and app must be accessible. Automated tests find failures on 96 of every 100 home pages. A French court has already ordered one retailer to fix its site under a daily penalty.


The head of e-commerce at a sixty person online retailer has heard of the European Accessibility Act. There was a webinar last spring, a line in a board update, a plugin vendor's email promising compliance in one click. The site passed a quick scan once. The subject went back in the drawer.

In June 2026 a French court took it out of the drawer for the whole sector. Carrefour showed the court that its site met 71% of the accessibility criteria. The judge wrote that the site "cannot be only a little accessible". It has to be accessible, full stop.

A French court has shown what enforcement looks like

The first cases did not come from a regulator. They came from associations representing people who use assistive technology.

In July 2025, two French disability associations, apiDV and Droit Pluriel, sent formal notices to Carrefour and other large retailers. The case against Carrefour went to the Tribunal judiciaire de Caen. Its order of 4 June 2026, published by the claimants, is short and readable.

Figure 1Caen, 4 June 2026

Seventy one percent was not enough.

The order in apiDV and Droit Pluriel against Carrefour France, as the court wrote it.

Figure 1A 71% score did not stop an order to make the site and app accessibleTribunal judiciaire de Caen, order of 4 June 2026, published by Intérêt à Agir.

The court ordered Carrefour France to make its e-commerce website and app accessible. It gave six months, and set a penalty of €500 for every day of delay after that. It also ordered a provisional payment of €10,000 in damages to the two associations.

Two details matter for everyone else. The legal basis was the French transposition of the European Act, which France wrote into its Consumer Code. And the route was private: associations, an urgent procedure, a judge. No regulator had to act first.

71% accessible is not accessible

Carrefour's defence was its own accessibility statement. Under the French accessibility framework, its site met 71.21% of the criteria. The court accepted the number and rejected the argument. The judge wrote that an e-commerce site "cannot be only a little accessible, it must be so totally".

This is the part every website owner should read twice. A score is not compliance. A dashboard showing 85% green is a list of what still fails. For a blind customer, a checkout that works on nine screens out of ten does not work.

The same logic applies to a popular shortcut. An overlay widget that promises compliance by adding a toolbar to the page does not fix the code the site is built from, and that code is what a screen reader reads and what a court asks about.

The law has applied to websites since 28 June 2025

The European Accessibility Act is Directive (EU) 2019/882. Member States had to write it into national law, and under Article 31(2) they "shall apply those measures from 28 June 2025". That date has passed. There is no grace period for a new website built today.

A transition does exist, and it is narrower than it sounds. Article 32 lets service providers keep using products they already used before that date until 28 June 2030, and lets service contracts agreed before June 2025 run on. It is not a five year holiday for your homepage.

It covers you if you sell to consumers online and have ten or more staff

The Act does not cover every website. Article 2(2) lists the services in scope when they are provided to consumers, and the one that catches most businesses is e-commerce. Recital 42 defines it as a service provided at a distance, "through websites and mobile device-based services", at the request of a consumer, "with a view to concluding a consumer contract".

In plain terms: if a member of the public can buy from you, book with you or sign a contract with you through your website or app, the Act is likely to apply. The list also names consumer banking, e-books, passenger transport and electronic communications.

There is one exemption that matters to small firms. Article 4(5) says "microenterprises providing services shall be exempt". Article 3(23) defines a microenterprise as fewer than ten people, with annual turnover or balance sheet total of no more than €2 million. Ten staff or more, and the exemption is gone.

A purely business to business site, or a site that only presents a firm without taking orders or contracts, is outside this list. Whether your own service falls inside is a question for a lawyer in your country. The direction of travel is not.

The Act names no checklist. The standard behind it does

The Directive sets functional requirements in its annexes: perceivable, operable, understandable, robust. It does not mention a technical checklist. The checklist comes from the harmonised standard, EN 301 549. A service that meets it is presumed to meet the Act.

The version currently cited, EN 301 549 v3.2.1, sets its web requirements to match the Web Content Accessibility Guidelines (WCAG) 2.1 at level AA. And it has just moved. On 7 September 2026, the Commission's AccessibleEU centre reported that the new version, 4.1.1, "adopts WCAG 2.2" in place of 2.1. Until the Commission cites it in the Official Journal, the legal reference stays at WCAG 2.1 AA.

What that means for anyone building now: build to WCAG 2.2 AA. It includes everything in 2.1, and it is where the reference is going.

96 of every 100 home pages fail the automated test

Every year, WebAIM runs automated accessibility tests on the home pages of the top million websites. The 2026 report, from a February 2026 crawl, found detected WCAG 2 failures on 95.9% of home pages, up from 94.8% in 2025. The average page had 56.1 errors, 10.1% more than a year earlier.

Figure 2WebAIM Million 2026

Ninety six in a hundred home pages fail.

One mark per hundred home pages among the top million websites, tested automatically in February 2026.

Figure 295.9% of the top million home pages had detected WCAG failures, up from 94.8%WebAIM Million 2026, February 2026 crawl. Automated testing only: a floor, not an audit.

That is not a survey of neglected sites. It is the most visited million, including companies with legal teams and design budgets. And it is a floor. WebAIM says so itself: automated tools cannot detect every failure, and the absence of detected errors "does not indicate that a page is accessible".

The six most common failures are dull, and that is the good news

The same report lists the failures it found most often, as a share of home pages:

  • Low contrast text, on 83.9%. Grey text on white, white text on a pale photo, a footer set in a colour chosen because it looked quiet.
  • Missing alternative text for images, on 53.1%. The image says something and the screen reader says nothing.
  • Missing form input labels, on 51%. A field with placeholder text instead of a label, which vanishes as soon as someone types.
  • Empty links, on 46.3%. An icon linking to Instagram with no name, read out as "link".
  • Empty buttons, on 30.6%. A magnifying glass or a close cross that does not say what it does.
  • Missing document language, on 13.5%. One attribute, and a screen reader can pronounce the page correctly.

WebAIM found that 96% of all detected errors fall into these six categories. None of them needs research or new technology. They are the result of design and build habits, and habits can be changed across a whole site at once.

Elevates ran the test on its own site first

Before writing this, Elevates ran an automated WCAG check (axe, WCAG 2.2 A and AA rules) on its own homepage and on one of its articles, on 19 September 2026. Both failed on two of the six categories above: footer text in a colour too faint to meet the contrast minimum, and four social media icons linking out with no accessible name.

Both were fixed before this article was published: the footer colour moved to one that passes, and each icon link now says where it goes. The fix took minutes. Finding it took running the test. A site that has never been tested has not passed. It has simply not been asked.

What you can check this week without paying anyone

The first pass is free and does not need a developer.

  • Run a free automated checker on your homepage, your product or service page, and your checkout or contact form. WebAIM's WAVE and the axe browser extension are both free. Write down the failures by type.
  • Unplug the mouse. Try to reach every link, open the menu, fill the form and complete a purchase using only the Tab, Enter and arrow keys. If you get stuck, or cannot see where you are on the page, a keyboard user is stuck too.
  • Zoom to 200% in the browser. Text should reflow, not disappear off the side, and nothing should overlap.
  • Read your images. For each image that carries meaning, ask what it would say in one sentence. That sentence is its alternative text.
  • Look at your form fields. Every field needs a visible label that stays when someone types.
  • Check your contrast. Grey text on a light background, or text over photographs, is the most common failure on the web.

This will not make a site compliant. It will tell you, in an afternoon, whether you have a small tidy up ahead or a real problem.

Where the free check stops

Automated tools catch the failures that can be measured in code. They cannot tell whether a screen reader user can actually finish a purchase, whether an error message makes sense when read aloud, or whether a date picker can be used without a mouse. Those are found by testing with assistive technology, following real journeys through the site.

Then there is the part no tool touches: the obligation to say what you have done. Annex V of the Directive requires service providers to include information on how the service meets the accessibility requirements, in their general terms and conditions or an equivalent document. That is a document someone has to write, keep accurate and update when the site changes.

And the hardest part is keeping it. A site that passes in October fails in March when a new banner goes up in a colour the brand team liked, or a new plugin adds a button with no name. Accessibility is not a certificate on the wall. It is a property of the site that every change can break.

What it costs you, and what Elevates does about it

For a retailer with ten staff or more, the cost of doing nothing is no longer theoretical. It is a court order, a deadline and a daily penalty, and before that, customers who leave a checkout they cannot use. In 2024, 23.9% of people aged 16 and over in the EU had a disability, according to Eurostat. A checkout that fails them is a leak in revenue before it is a legal risk.

The work lands in one of two places. For many sites the free check turns up the familiar six: contrast, labels, names, alternative text. They are fixed in the templates once, and the whole site improves. That is days, not months, and it is the outcome to hope for. For others, the check shows a checkout, a booking engine or an app built on components that cannot be made accessible without rebuilding them. There the question is whether to rebuild that journey properly or keep patching a structure that fails every new test.

What Elevates does with a site like this: tests the real journeys with a keyboard and a screen reader, not only a scanner; fixes the failures in the templates so every page improves at once; builds anything new to WCAG 2.2 AA; and writes the accessibility statement alongside the site, so it stays true when the site changes.

The question to ask this week

Ask whoever runs your website one question: when did anyone last test the checkout, or the contact form, without a mouse?

If there is a date and a report, you have a starting point. If there is a shrug, you have the same answer Carrefour had before June, and a clearer view than Carrefour of what comes next.

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