All the Possibles

The European Accessibility Act for French e-commerce sites: what the DGCCRF checks

Updated October 28, 2026. By All the Possibles.

France put the European Accessibility Act into the Code de la consommation and handed e-commerce to the DGCCRF, which has been checking shops since January 2026. This page quotes the DGCCRF's own guidance, names the articles, and ends with a free check of your site.

The law in France

Directive (EU) 2019/882 was transposed through Article 16 of loi n° 2023-171 of 9 March 2023, décret n° 2023-931 of 9 October 2023 on the accessibility of products and services for disabled persons, and an arrêté of the same date that sets the technical requirements. The duties sit in the Code de la consommation: Article L. 412-13 carries the obligation, Articles D. 412-49 to D. 412-62 carry the detail, and Article R. 451-4 carries the fine. The obligations apply from 28 June 2025. E-commerce is on the DGCCRF's list of covered services, next to telephony, audiovisual media access, transport, consumer banking and e-books.

One point the DGCCRF makes in bold on its own page: a website or a mobile app is not a "product" within the meaning of the Directive. The five-year transition that lets a provider keep using products it already used before 28 June 2025 does not cover an online shop that existed before that date. Consumer contracts concluded before 28 June 2025 may run unchanged until their end, and at the latest until 28 June 2030; that does nothing for a new customer arriving today.

Who checks, and what has happened so far

The DGCCRF is the authority for e-commerce, and it coordinates with ARCOM, ARCEP, the Banque de France, the ACPR and the AMF for communications, audiovisual and financial services. In its review of 25 June 2026, one year after the rules took effect, it reported three investigations opened in January 2026: one into the accessibility of e-commerce websites and mobile apps, together with the fairness of the firms that sell accessibility audits to companies; one into multimedia products; one into coach, maritime and river transport. It plans to check around one hundred establishments in 2026. Its earlier rail transport investigation, April 2025 to March 2026, covered 38 establishments and ended in corrective and educational measures rather than fines.

Law firms report a further DGCCRF statement of 4 September 2026 on the e-commerce investigation: more than twenty sites examined since the start of the year, corrective or repressive follow-up planned for about half of them, and close to one hundred consumer reports filed through SignalConso. I have read that statement only through those reports, so treat the figures as reported rather than quoted. Since December 2025 any consumer can report an inaccessible site or app through the SignalConso platform, and the DGCCRF says it uses those reports to target its checks.

The sanctions, in the DGCCRF's words

The practical sheet for professionals, dated 13 November 2025, says the DGCCRF's agents can order a professional to bring products and services into conformity, and that these injunctions can carry a daily penalty and a publicity measure. The offences against the accessibility obligations in the Code de la consommation are fifth-class contraventions: "amendes de 7 500 euros, cumulatives en fonction du nombre d'infractions constatées". For products, a suspension from the market can be ordered if non-conformity persists. The sequence in practice is a request for documents, a record of findings, a contradictory procedure, then an injunction with a deadline. The fine is small next to the German ceiling, but it stacks, and the injunction with a daily penalty is the instrument that costs most.

Who is exempt

The DGCCRF describes the size exemption this way: companies with fewer than 10 employees and annual turnover or balance sheet total under EUR 2 million get a specific treatment; no accessibility obligation applies to such service providers, and manufacturers, importers and distributors of products at that size may derogate without having to justify it. Two further routes exist for everyone: a fundamental alteration of the nature of the product or service, and a disproportionate burden, assessed against the annex to Article D. 412-60. For those two routes the company must inform the authority and be able to produce a technical file on request; the DGCCRF offers an online procedure on demarches-simplifiees.fr for declaring a non-conformity or invoking an exemption, handled by the departmental directorate where the company has its seat.

Separately, Article 47 of the law of 11 February 2005 keeps its own regime for large companies, with a EUR 250 million turnover threshold and ARCOM as the authority. A court in Lille applied that threshold in May 2026 to dismiss a claim by associations against a retailer, and the associations have appealed; a court in Caen in June 2026 ordered another retailer to make its site and app accessible within six months. Both are first-instance rulings reported in the press, and neither changes what the DGCCRF can do under the Code de la consommation.

What a French shop has to publish

The DGCCRF lists the service provider's duties as designing and providing the service to the accessibility requirements, establishing information that states its conformity and making it available to the public (it gives an RGAA audit report as the example), keeping monitoring procedures, and taking corrective measures and informing the authorities when in doubt about conformity. The practical form is a page in French, linked from the footer and the terms, that says which standard the shop follows, what is accessible, what is not yet and why, and how to report a barrier. The DGCCRF points to EN 301 549 V3.2.1, the RGAA 4.2.1 and WCAG 2.1 as the references, so a French shop that already follows the RGAA has the right vocabulary.

What to fix first

  1. Checkout and account sign-in by keyboard only, from product page to order confirmation. The DGCCRF's own description of "utilisable" starts with every function reachable from the keyboard.
  2. Accessible names on icon buttons and image links: cart, search, menu toggle, product thumbnails, payment method radios.
  3. Labels and error messages on the address, delivery and payment forms, and a focus move to the first error; "aider l'utilisateur à corriger les erreurs de saisie" is on the DGCCRF's list.
  4. Page language set to fr, document titles per page, a skip link, a single h1.
  5. Contrast on prices, promotion badges, buttons and placeholder text, and target size on mobile.
  6. Alt text on product images that names the product, and empty alt on decoration.
  7. The published accessibility information, in French, dated, with a contact route that someone answers, and the figures that support any exemption you rely on.

Run the free check below on your busiest product page, then on checkout. The Designers page audit runs the same check inside an agent session, and the Accessibility Readiness Report covers up to ten pages for $149 once, with a fix list in order and a draft of the accessibility information for your terms.

Free check of one page, about a minute

We read the page the way a crawler does, name each problem with its WCAG clause, and email you a link to the result. An automated draft, not legal advice.

One page, one check per site every 7 days, link live for 30 days. The full report covers up to ten pages and costs $149 once.

Sources

This is a reading of public texts by a tool builder, not legal advice.

Questions people ask

Who enforces the European Accessibility Act for online shops in France?

The DGCCRF, the consumer protection and fraud authority inside the Ministry of the Economy. Its practical sheet for professionals lists e-commerce among the services it checks, in coordination with ARCOM, ARCEP, the Banque de France, the ACPR and the AMF for their own sectors. Since January 2026 it has been running an investigation into the accessibility of e-commerce websites and apps.

What is the fine for a non-accessible shop in France?

The DGCCRF describes the offences as fifth-class contraventions under Article R. 451-4 of the Code de la consommation: a fine of EUR 7,500, cumulative with the number of breaches found. Before any fine, its agents can issue an injunction to comply, which can carry a daily penalty and a publicity measure.

Is my small French shop exempt?

A service provider with fewer than 10 employees and annual turnover or balance sheet total under EUR 2 million has no accessibility obligation for its services, in the DGCCRF's words. The exemption is for services. A microenterprise that places covered products on the market can derogate too, without having to justify it. If you rely on the exemption, keep the headcount and the turnover figure on file.