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On 4 June 2026 the Tribunal judiciaire de Caen ordered Carrefour France to make carrefour.fr and its mobile app fully accessible to disabled users, gave it six months, and attached a penalty of €500 for every day it runs over.
The detail every online retailer should sit with is this: an audit put Carrefour’s platform at roughly 71% accessible for blind and partially sighted users. The court held that was not compliance. In the words reported from the decision, an e-commerce site « ne peut pas être seulement un peu accessible, il doit l’être totalement » — it cannot be only somewhat accessible, it has to be completely accessible. The judgment treats digital accessibility as an obligation of result, not an obligation to make an effort.
If you sell eyewear to customers in the European Union, that is the standard now being applied to your prescription form.
With one caveat that arrived a month earlier and that almost nobody reporting the Carrefour decision mentions: a different French court reached the opposite answer about a different retailer. We come back to it below, because the gap between the two rulings is exactly where an independent eyewear store sits.
The deadline is not coming. It went.
The European Accessibility Act — Directive (EU) 2019/882 — required in-scope services, e-commerce among them, to be accessible from 28 June 2025. 2026 is not a planning year. It is the year the machinery started moving.
In France the DGCCRF has now published twice. On 25 June 2026 it reported a rail-sector investigation covering 38 establishments and said around a hundred establishments would be inspected during 2026, with e-commerce websites and mobile applications named among the target sectors. On 4 September 2026 it published interim results, and the e-commerce numbers are the ones to read: of roughly fifty sites planned for inspection, more than twenty had been checked and more than half of those were found wanting, with corrective or enforcement measures planned for half of the sites inspected. In the rail sector, 8% of establishments checked faced corrective or enforcement action. Nearly a hundred reports have come in through the dedicated accessibility route on SignalConso since it opened in December 2025. Several e-commerce operators have committed to being compliant by the end of 2026, and the DGCCRF expects to publish final results in early 2027.
The defects it lists are not exotic. Insufficient colour contrast. Information lost when a page is enlarged. Functions that cannot be reached by keyboard. Missing or irrelevant text alternatives for images. And one that is pure paperwork: failing to declare a non-conformity to the DGCCRF at all. If you read that list and recognised your own prescription form, you are the target profile rather than an outlier.
What has not happened, as far as any reliable account goes — re-checked on 17 September 2026 — is a confirmed monetary fine under any national law transposing the EAA. Accessibility specialists reviewing the first year concluded in June 2026 that enforcement so far has run through notices, civil suits, information requests and regulatory monitoring rather than cheques. Be careful with sources that tell you otherwise: at least one widely linked “first year enforcement” report circulating in 2026 lists precise five- and six-figure penalties while attributing them to national authorities that do not enforce this directive. Precise numbers are not the same as verified numbers.
The Carrefour decision is the more useful signal anyway, because it did not come from a regulator at all. It came from two disability associations, apiDV and Droit Pluriel, going to court. That route does not require a state inspector to get to you first.
Two courts, two answers — and the gap between them is where you sit
Here is the part that did not travel with the Carrefour headlines. On 5 May 2026, a month before Caen, the Tribunal judiciaire de Lille heard a comparable digital accessibility claim against Auchan E-Commerce — and rejected it. The reported reasoning was not that the site was accessible. It was that the obligation did not apply at all: the court found the company fell below the €250 million turnover threshold in France’s own accessibility law of 11 February 2005. The claimant associations disagree and have appealed to the Cour d’appel de Douai.
So the honest state of French case law is two first-instance decisions, two months apart, pointing in opposite directions, one of them under appeal. Neither binds anybody. Anyone telling you the courts have settled digital accessibility in France is describing the half of the record they preferred. No appeal by Carrefour has been reported, but a first-instance judgment is not a precedent either way.
What matters more than the outcomes is what the disagreement was about. Auchan’s escape — if it survives appeal — came from a threshold in a French national statute that predates the EAA and was written for very large companies. That is not the test that governs you. The exemption in the directive is the microenterprise one, and it starts at fewer than 10 people. Between ten employees and €250 million of turnover there is no shelter in either instrument.
That range contains essentially every independent eyewear retailer in Europe. The Auchan decision is not your defence. It is a reminder that the only threshold available to you is a far lower one.
Does it apply to you?
The directive covers e-commerce services, defined in Article 3(28) as “a service provided at a distance, through websites and mobile device-based services, by electronic means and at the individual request of a consumer, with a view to concluding a consumer contract.” An online eyewear store is squarely inside that definition.
The obligation attaches to the market you serve rather than the country you are registered in, so the generally accepted reading is that a US or UK store selling prescription eyewear to consumers in the EU is in scope. Two honest caveats: the directive itself speaks in terms of services provided on the Union market rather than spelling out a long-arm rule, and how vigorously a national authority pursues a seller with no EU establishment is a practical question nobody has a confident answer to yet. If you have an EU entity, an EU warehouse or an EU-facing storefront, treat the question as settled.
The microenterprise exemption is narrower and wider than people tell you
Article 4(5) is short: “Microenterprises providing services shall be exempt from complying with the accessibility requirements referred to in paragraph 3 of this Article and any obligations relating to the compliance with those requirements.”
Two things about that sentence get misreported constantly.
First, the threshold test is not what most summaries say. Article 3(23) defines a microenterprise as an enterprise “which employs fewer than 10 persons and which has an annual turnover not exceeding EUR 2 million or an annual balance sheet total not exceeding EUR 2 million.” The headcount limb and the financial limb are joined by and; the two financial measures are joined by or. A great many compliance guides write it as “fewer than 10 staff and turnover under €2m,” which quietly deletes the balance-sheet alternative and makes the exemption look tighter than it is.
Second, it exempts microenterprises providing services. It says nothing about products. Which matters more to an eyewear retailer than it sounds.
The half of this law nobody writes about for eyewear
Almost everything published about the EAA and online retail treats it as a website law. It is not. It is a products and services directive, and Article 2(1) lists the products: consumer general purpose computer hardware and its operating systems; certain self-service terminals; e-readers; and — the one that matters here — “consumer terminal equipment with interactive computing capability, used for electronic communications services.”
If your catalogue includes smart glasses that take calls, handle messages or run an assistant over a paired connection, there is a serious argument that the product itself is in scope. We have not found guidance that settles it for eyewear specifically, so treat it as a question to put to your supplier in writing rather than a decided point. But if the answer is yes, a second set of obligations lands on you, and it is not the website set.
A retailer who did not manufacture or import the product is a distributor, and Article 10 gives distributors their own duties. Before making the product available you must verify that it bears the CE marking, that it comes with the required documents and with instructions and safety information “in a language which can be easily understood by consumers” in the member state concerned, and that the manufacturer and importer have done their part. If you have reason to believe a product does not conform, you must not sell it until it does, and you must tell the manufacturer or importer and the market surveillance authorities. If something you have already sold turns out to be non-conforming, you have to see corrective measures through or withdraw it, and inform the competent national authorities in every member state you supplied.
Note what is absent from that list: any microenterprise relief. Article 4(5) covers services. A four-person shop selling smart eyewear into the EU still carries Article 10.
This will be familiar if you have been reading along. It is the same line that decides everything else about selling eyewear into Europe: whether the object in the box is a medical device, whether it is regulated hardware, whether it generates data somebody has a right to, who is liable when it goes wrong, and now whether the software inside it is high-risk AI. The accessibility directive draws the same line in the same place. A frame is a frame; a frame with a radio in it is a regulated product, and each regime hands you a different pile of paperwork for it.
Article 14: the escape hatch, and its price
The directive does not actually require the impossible, and this is the provision most eyewear-facing coverage leaves out entirely.
Under Article 14(1), the accessibility requirements apply only to the extent that compliance does not require a change resulting in “the fundamental alteration of its basic nature” and does not impose “a disproportionate burden on the economic operators concerned.” That is a real derogation and small sellers can reach it.
It is not free. If you want to rely on it you must:
- Assess it against the criteria in Annex VI, rather than simply declaring it (Article 14(2));
- Document the assessment and keep the result for five years from the last time the service was provided, and hand a copy to a market surveillance or compliance authority on request (Article 14(3)). Microenterprises are relieved of the documentation itself but must still supply the facts if asked (Article 14(4));
- Notify the authority in your member state that you are relying on the derogation — microenterprises excepted (Article 14(8));
- Redo the assessment when the service changes, when an authority asks, and in any event at least every five years (Article 14(5)).
And one trap worth knowing: under Article 14(6), an operator that has taken external funding to improve accessibility cannot then claim disproportionate burden.
This is also where a widely repeated number comes from and gets misapplied. You will see advice that the EAA imposes “a five-year documentation cycle” on every in-scope business. It does not. The five-year re-assessment in Article 14(5) applies to operators claiming the disproportionate burden derogation. If you are simply complying, that clock is not yours.
What you are actually required to publish
The obligation here is narrower and more specific than “put up an accessibility statement.” Article 13(2) requires service providers to prepare information in accordance with Annex V and explain how the service meets the requirements. Annex V, point 1, says that information goes in the general terms and conditions, or an equivalent document, and must include:
- a general description of the service in accessible formats;
- descriptions and explanations necessary to understand how the service operates;
- a description of how the relevant Annex I accessibility requirements are met.
Annex V also asks for documentation showing that your delivery process and its monitoring keep the service in line. Article 13(2) ties retention to the life of the service — the information is kept for as long as the service is in operation, which for a live storefront means indefinitely rather than for a fixed term.
Worth saying plainly: the “accessibility statement” format familiar from public sector websites comes from a different instrument, the Web Accessibility Directive, which does not apply to your shop. Publishing one is a perfectly sensible way to discharge the Annex V duty. It is not the thing the law names. And note from the DGCCRF’s September findings that failing to declare a non-conformity was itself among the defects recorded — the paperwork is not decoration.
Why eyewear has the harder version of this problem
Most e-commerce accessibility advice assumes your worst screen is checkout. For an optical store it is not. It is the prescription step, for reasons specific to the category.
It is a dense medical form. Sphere, cylinder, axis, add power, prism, base curve, diameter — per eye. A dozen or more inputs where a t-shirt store has one size dropdown. Every one needs a real <label>, a programmatic relationship to its error message, and a sensible tab order.
It is usually a modal or a drawer. Overlays are where accessibility breaks: focus is not moved into the dialog, focus is not trapped, Escape does not close it, and the page behind stays reachable by keyboard. A prescription form in an untrapped modal is unusable with a screen reader even if every field is labelled perfectly.
It is frequently a third-party widget. Whatever your theme scores, an embedded prescription tool is part of your service in the eyes of the law. Compliance is not delegable by installing an app — though it is heavily determined by which app you install.
The error states are where people actually get stuck. “Invalid axis” rendered as red text beside a field, with no aria association and no focus move, is invisible to a screen reader user. They know the form failed. They do not know where or why.
Then there is PD. A camera-based pupillary distance measurement is by definition a visual task. It should never be the only route; a manual entry path, clearly explained, is what keeps that step from being a hard barrier. It is also worth knowing that the camera has its own legal weather in the United States, for entirely separate reasons.
And there is an irony worth naming in your own copy: eyewear stores serve people with impaired vision. Low-vision customers, magnification users and screen reader users are not an edge case in this category, they are the market. This is the one retail vertical where inaccessible design is most obviously aimed away from its own buyers.
About those German warning letters
If you sell into Germany you may have heard that the BFSG — the German transposition — has produced a wave of Abmahnungen, the competitor warning letter with costs attached. Letters are certainly circulating. Whether they hold up is a different question: German practitioners reviewing them in 2026 have argued that a large share are legally challengeable, not least because § 8 UWG restricts who may send one at all, and the sender frequently has no genuine competitive relationship with the recipient.
The sane posture is neither panic nor dismissal. Do not pay a demand because it arrived on letterhead; have it looked at. And do not conclude from a shaky letter that the underlying obligation is shaky, because the Caen judgment shows what happens when someone with proper standing does bring a claim.
A practical checklist
Find out where you stand
- Run an automated scan (axe, Lighthouse, WAVE) over home, collection, product, prescription flow, cart, checkout and account pages. Automated tooling catches perhaps a third of real issues — treat the output as a floor, not a score.
- Do the two manual tests that matter: complete an entire prescription purchase using only the keyboard, then again with a screen reader. Nearly every serious defect surfaces in those two runs.
- Check yourself against the DGCCRF’s own list of recorded defects: contrast, enlargement, keyboard reachability, image alternatives, and declaring non-conformity.
- Remember the standard the Caen court applied. A number like 71% is a progress report, not a defence.
Fix the prescription flow first
- Every input has a visible, persistent label. Placeholder text is not a label.
- Errors are announced, associated with their field, and focus moves to the first one.
- Modals and drawers move focus in, trap it, and close on Escape.
- The whole form is completable by keyboard, in a logical order.
- Text contrast meets 4.5:1, and colour alone never marks a required field or an error.
- PD has a non-camera alternative, plainly explained.
- Nothing is time-limited without a way to extend it.
Fix identification and payment
- Login, two-factor and payment entry all work by keyboard and screen reader.
- Do not block paste. It breaks password managers and penalises people with motor impairments.
Do the paperwork the directive actually names
- Put the Annex V information into your terms and conditions, covering all three points.
- If you are relying on Article 14, write the assessment, keep it, notify your authority, and diarise the five-year review.
- Re-run your assessment whenever you change theme, prescription app or checkout.
Ask vendors the direct question
- Before installing anything that touches the buying flow: “Does this conform to WCAG 2.2 AA, and can you provide a conformance report?” A vendor who cannot answer has answered.
- If you stock smart eyewear, ask the supplier in writing whether they treat the product as in scope of the EAA, and for the accessibility information that is supposed to travel with it.
One date that is not 2030
You will see the year 2030 attached to the EAA and it is worth being precise about what it covers. Article 32 gives a transitional period ending 28 June 2030 during which service providers may keep using products they were lawfully using to provide similar services before that date. Service contracts agreed before 28 June 2025 may run to expiry, but no more than five years from that date. Self-service terminals in lawful use before 28 June 2025 can run to the end of their economically useful life, up to twenty years from entry into use.
None of that postpones anything about your website. There is no transitional period for a storefront launched after June 2025, and none for the prescription form on it.
The part that is not about compliance
Roughly one in four adults in the EU reports some form of disability, and the population buying prescription eyewear skews older than the general population, which correlates with reduced dexterity, hearing and sight. The accessible version of a form is also the version that works on a phone in poor light for a 68-year-old filling it in without their reading glasses — because their reading glasses are the thing they are trying to buy.
Labels that stay visible, errors that explain themselves, a keyboard path that works, and a prescription step that does not depend on a camera. None of that is charity, and none of it is only for auditors. It is a better checkout for everybody. The legal deadline is just the reason it finally gets scheduled.
Frequently asked questions
Has any court actually ruled on this?
Two French courts have, and they disagreed. On 4 June 2026 the Tribunal judiciaire de Caen ordered Carrefour France to make its platform fully accessible within six months with a €500-a-day penalty. A month earlier, on 5 May 2026, the Tribunal judiciaire de Lille rejected a comparable claim against Auchan E-Commerce on the basis that it fell below the €250 million turnover threshold in France’s 2005 accessibility law; that decision is under appeal to the Cour d’appel de Douai. Both are first instance and neither is binding precedent. No appeal by Carrefour has been reported.
Does the European Accessibility Act apply to my store if I am not in the EU?
If you sell to consumers in the EU, the generally accepted answer is yes — the obligation follows the market you sell into rather than where you are registered. How aggressively that is enforced against a seller with no EU presence is still untested.
Is there an exemption for small businesses?
Yes, for services. Microenterprises — fewer than 10 people, and either turnover or balance sheet total not exceeding €2 million — are exempt from the service accessibility requirements under Article 4(5). The exemption does not extend to the product-side duties in Article 10 if you sell in-scope hardware. The €250 million figure that appeared in the Auchan case comes from a separate French statute and is not an EAA threshold.
Which standard do I have to meet?
The directive sets functional criteria in Annex I rather than naming WCAG. In practice, conformance with WCAG 2.1 AA or 2.2 AA through the European standard EN 301 549 is the accepted route to demonstrating it.
If my prescription form is a third-party app, is that the vendor’s problem?
Legally it is yours — the service you offer includes everything on the page. Practically it is theirs, because you cannot fix their code. Choose accordingly and ask for a conformance report before you install.
What if fixing it genuinely is not affordable?
That is what Article 14 is for, but it is a process rather than an excuse: assess against Annex VI, document it, notify your authority, and review it at least every five years.
What is the fastest way to find my worst problems?
Complete a full prescription purchase on your own store using only the keyboard. Twenty minutes will tell you more than an automated scan.
This article is general information about a fast-moving area of law, not legal advice, and it does not describe the compliance status of any particular product or store. National transpositions of the EAA differ, and you should take advice on the member states you actually sell into.
VisioncarePro’s prescription forms ship in several layouts — sidebar, modal, horizontal and vertical — with labelled fields, keyboard-completable flows, multi-language support, and manual entry alongside camera-based PD, so no customer is pushed down a single route.
