Digital accessibility: what's changing for e-commerce sites since June 2025 - A French perspective

Since 28 June 2025, new European accessibility requirements been shaking up the e-commerce landscape. The European Accessibility Act (“EAA”), now requires e-commerce websites and applications to be accessible to all, in order to create a more inclusive society and facilitate independent living for persons with disabilities.

Objective: Making e-commerce accessible to all

The ambition is clear: to enable everyone to browse, shop and interact online without barriers through websites and mobile device-based services.

Whether users have visual, hearing, mental, intellectual or sensory impairment, or have motor difficulties – whether permanent or temporary – websites must now adapt.

In France, these rules are enshrined in the French Consumer Code¹.

In practical terms, websites must be perceivable, operable and understandable using simple language and visuals or explanations of technical terms for instance, and robust, i.e. compatible with assistive technologies such as screen readers.

It should be noted that in France, large companies (with a turnover of more than €250 million) were already subject to accessibility requirements. The European directive reinforces and expands this framework, without replacing it.

Who is affected?

The list is long, covering a wide range of mainstream products and services:

All companies offering these products or services must be compliant since 28 June 2025.

However, there are a few exceptions:

• for very small businesses (fewer than 10 employees and less than €2 million in turnover or balance sheet total);
• in cases where compliance would fundamentally alter the nature of the product or service;
• in situations where the cost of compliance would be disproportionate for the company.

The authorities are taking action

The DGCCRF (Directorate-General for Competition, Consumer Affairs and Fraud Control) is not sitting idly by. It has published several practical guidelines to assist consumers and professionals.
These notes explain, in particular, how to report non-compliance or notify an exemption.

Better still, a dedicated section has been created on SignalConso to make it easier for consumers to report inaccessible websites or services.

In December 2025, the DGCCRF published a specific note on e-commerce sites.

Message to professionals: you must inform the authorities AND your customers if your products or services do not yet comply with accessibility rules.

And beware: the first inspections are scheduled for January 2026. Penalties may be cumulative, product by product and service by service.

As a reminder, penalties applicable to digital accessibility are cumulative by product, service and obligation. They may take the form of 5th class fines of up to €7,500 (€15,000 in the event of a repeat offence), injunctions to comply with daily penalties, measures to publish the penalties and nature of the offences, or measures to suspend the marketing of non-compliant products.

The matter has already been referred to the courts

Disability advocacy associations did not wait for official inspections. Supported by the Juristes des Intérêts à Agir, a lawyer collective, several of them took four retail giants to court following a formal notice sent in July, which went unheeded.

The judge, seized of the matter in November 2025, must now rule.

What should be done now?

For the companies concerned, it is time to act. Here are the key steps:

• Conduct an internal review to determine whether products or services are covered by accessibility requirements;
• Update your documentation: internal policies, customer contracts and terms and conditions must incorporate these new requirements;
• Declare any non-compliance or use of an exemption to the authorities.

Further resources

For a broader overview of the EAA and to see a snapshot of the products and services it covers, recommended next steps and enforcement actions, see our infographic here.

For more information and articles on the EAA, please visit our dedicated site.
 

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[1] Article L. 412-13 of the Consumer Code