On 4 June 2026, the Tribunal judiciaire de Caen ordered Carrefour to make both its website, carrefour.fr, and its mobile app fully accessible within six months, with a penalty of €500 for every day it misses the deadline. The order is the first ruling under a national transposition of the European Accessibility Act (EAA) to go against a retailer and order remediation, and the first anywhere in the EAA regime to cover a mobile app explicitly. A month earlier, a different French court had dismissed a near-identical case against Auchan on a domestic revenue threshold, a technicality we cover in our breakdown of the first EAA court ruling. Caen answered that dismissal with an order to comply in full.
What the Caen Court Actually Ordered
The case was an emergency proceeding, known in France as a référé, a fast-track civil procedure that asks a court to stop an ongoing harm rather than settle a full trial. It was brought by the disability associations apiDV and Droit Pluriel, backed by the legal collective Intérêt à Agir, the same groups behind the Auchan case. Their published account of the decision(opens in new tab) sets out the order.
The order has two parts. First, an injunction: Carrefour France must bring carrefour.fr and its mobile app to full accessibility within six months, a deadline that falls around 4 December 2026. Second, an astreinte of €500 per day. An astreinte is a coercive daily penalty a court attaches to an order to push a party towards compliance. It is not a fine. Nothing is owed today, and nothing is owed if Carrefour meets the December deadline. The money only starts to run if the deadline passes with the work unfinished. The order carried no damages and no costs.
That distinction matters, because it is the one most coverage will blur. No company has been fined under any EAA-transposed law anywhere in the EU as of July 2026. The Caen order is a forward-looking penalty for future non-compliance, not a sanction for past conduct. For how the actual penalty regimes are structured country by country, see our guide to EAA fines. The legal basis for the order was Article L.412-13 of the French Consumer Code, the provision that transposes Directive 2019/882(opens in new tab), the EAA, into French law.
71% Compliant Is Not Compliant: The Obligation of Result
At the hearing, Carrefour did not claim its site was perfect. It argued that it had reached 71% conformity with the RGAA, France's national accessibility standard (the Référentiel général d'amélioration de l'accessibilité, which is aligned with WCAG 2.1 AA), and that this was enough. It pointed to real progress. The 71% figure is roughly double where the company stood three years earlier, it has committed to reaching 100% by the end of 2026, and it has set up an internal accessibility observatory, staffed in part by visually impaired testers, to keep checking its own work.
The court was not persuaded. It held that accessibility is an obligation of result, not an obligation of means. In plain terms, the law asks whether the outcome is accessible, not whether the company tried hard. As the disability press reported(opens in new tab), the judgment put it directly:
Le site de e-commerce concerné ne peut pas être seulement un peu accessible, il doit l'être totalement.
In English: the e-commerce site concerned cannot be only somewhat accessible; it must be totally accessible.
There is a fair way to read this and an unfair one. The unfair read is that Carrefour did nothing, which is not true. The fair read is the one the court set out: partial conformity and a credible improvement plan are mitigation, not compliance. A progress narrative, however genuine, did not stop the order, because the standard the court applied was full conformance. Seventy-one percent conformity means that close to a third of the audited criteria still fail, and every one of those failures is a barrier for a real person trying to finish a real task, whether that is completing a shop or tracking an order. For any product team, the lesson is uncomfortable but clear. "Mostly accessible" is a project status, not a legal defence.
Why the App Is the Real Headline
Most EAA enforcement so far has stopped at the website. Sweden's telecoms regulator opened its e-commerce inspections against websites only. Germany's market surveillance work has centred on web shops. The comfortable assumption for app-first companies has been that mobile was a later phase, and that there was time.
The Caen order removes that assumption. It is the first compliance order under the EAA regime to name a mobile app and require it to reach full accessibility on the same timeline as the website. Carrefour's app was not in the original July 2025 formal notice, which named the website alone. It entered the case at the November 2025 filing, and the June order now covers both surfaces together.
The point for anyone shipping a consumer app in the EU is simple. A native app sits inside the scope of the EAA in the same way a website does, and a court has now treated the two as one obligation with one deadline. If your accessibility work has focused on the website because that is where the early attention went, the app is no longer a job you can leave for next year. If you have not audited yours, start with how to test a mobile app for accessibility.
What Happens Next in the French Cases
The Carrefour order is not the end of the French docket, and it is not necessarily the last word for Carrefour either. The company has said, in comments reported by the French trade press, that it is examining the ruling and reserves the right to appeal, though it had not filed an appeal as of early July 2026. Its six-month clock runs to around 4 December 2026.
The other cases are still moving. The Auchan associations have appealed the Lille dismissal to the Cour d'appel de Douai, which has not yet set a hearing date. The E.Leclerc case is listed for 22 September 2026 in Créteil. The Picard case has been postponed with no new date.
It is worth being clear about what the Caen ruling did not do. It did not overturn or correct the Lille threshold reasoning that dismissed Auchan. That question simply did not arise, because Carrefour's revenue clears every threshold in play. The two rulings sit side by side, answering different questions.
What This Means for Your Product
The pattern across the first year of enforcement rewards preparation, not panic. The companies that come through this environment best are the ones with a current audit and an evidence trail before anyone writes to them. Even Carrefour's 71% audit gave it a public story to tell about direction and intent. A company with no audit at all has no story, no baseline, and no way to show a court or a regulator what it has done.
The practical steps are the same whether you are in France, Germany, or the UK selling into the EU. Audit your website and your app against EN 301 549, the EU's harmonised accessibility standard, which incorporates WCAG 2.1 AA (RGAA is France's national equivalent). Fix what you find in order of severity, so the barriers that block real tasks go first. Publish and maintain an accessibility statement that reflects your real, current status. Then keep the record current as you ship, because accessibility slips with every release, and a year-old audit describes a product that no longer exists.
Build the Record Before Someone Asks for It
AUDITSU is the guided audit toolkit that lets product and compliance teams run this audit themselves and keep it current. It walks your team through EN 301 549 screen by screen, logs every result, tracks remediation over time, and generates an accessibility statement from the evidence you gather. Websites are free to audit, and mobile apps are covered on the Beta plan, so the surface a court has just put in scope is one you can check yourself this week. No accessibility expertise required, and no code access needed. When a letter arrives, you answer with a record rather than a scramble.