So what's the EAA, really?
The European Accessibility Act (EAA) is EU Directive 2019/882, adopted on April 17, 2019. It came into force on June 28, 2025 across all EU member states. The EAA is basically the EU saying: enough is enough -- accessibility can no longer be optional for the private sector.
Until now, accessibility rules mostly hit public bodies. In France, the RGAA framework applied to government sites and a handful of very large companies. With the EAA, private businesses are now squarely in scope. Your e-commerce site, your banking app, your streaming platform -- all of them.
Who's affected? (Spoiler: probably you)
The EAA casts a wide net. Here's what it actually means for you if you operate in the EU.
Services: consumer banking, e-commerce, telecommunications, transport ticketing and traveller information, audiovisual media platforms, and e-books.
Products: computers, smartphones, tablets, payment terminals, self-service kiosks, telecom equipment, and e-book readers.
What are the technical requirements?
Good news (sort of): the EAA doesn't invent new technical criteria. It references the EN 301 549 standard, which in turn incorporates WCAG 2.1 Level AA -- the same criteria as RGAA 4.1. So if you've been working towards WCAG compliance, you're already on the right track. The requirements follow the familiar POUR principles: Perceivable, Operable, Understandable, Robust.
How France transposed the EAA
France brought the EAA into national law through Law No. 2023-171 of March 9, 2023, integrated into the Consumer Code. The DGCCRF (the French consumer protection authority) is in charge of enforcement. Sanctions include administrative fines and market withdrawal for non-compliant products. Let me break this down: the private sector now has a regulator watching, and that regulator has teeth.
Exemptions -- but they're narrower than you think
Microenterprises (fewer than 10 employees AND less than EUR 2M annual revenue) are exempt -- but only for services, not products. Disproportionate burden exemptions exist, but they must be properly justified and documented. "It's too expensive" without evidence won't fly.
What this means for French businesses
Before the EAA, only the public sector had serious accessibility obligations. Now? Every business above micro-enterprise size is in scope. Sanctions are stronger (DGCCRF enforcement instead of the old EUR 20,000/year cap). And the scope isn't just websites anymore -- it's apps and digital products too.
Here's what it actually means for you: audit your sites and apps (tools like RGAA Test can help), identify critical barriers, plan realistic fixes, train your teams, and document everything. That documentation matters if enforcement comes knocking.
Here's what it comes down to: the EAA isn't just another regulation. It's the signal that digital accessibility now applies to everyone, not just public bodies. Companies that started early don't regret it. Those waiting for the first enforcement action to get moving... are taking a gamble.