Directive EU 2019/882 · Verified Generate report

The First Major EAA Lawsuit: Four French Supermarket Giants Summoned Before the Tribunal Judiciaire de Paris

On 12 November 2025, four of France's largest grocery retailers — Auchan, Carrefour, E. Leclerc and Picard Surgelés — were summoned before the Tribunal Judiciaire de Paris in a référé cessation de l'illicite for failing to make their e-commerce websites and mobile apps accessible under the French transposition of the European Accessibility Act (Loi 2023-171 DDADUE and Code de la consommation). This is what happened, with every date, every plaintiff and every legal reference verified.

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Tribunal Judiciaire de Paris· ApiDV · Droit Pluriel · Intérêt à Agir· 12 November 2025· Loi 2023-171 DDADUE · Directive EU 2019/882
First major EAA-era lawsuit in Europe

Four of France's biggest grocery chains are in court because they ignored an EAA remediation notice issued on 7 July 2025 with a deadline of 1 September 2025. The plaintiffs are two disability rights organizations (ApiDV and Droit Pluriel) backed by the legal collective Intérêt à Agir. The venue is the Tribunal Judiciaire de Paris. The procedure is an assignation en référé (emergency summary proceedings), which forces judicial response within weeks, not months. The plaintiffs have a recent track record: they won a 2024 judicial ruling against the French State for the inaccessibility of educational software. If you run an e-commerce business in any EU country and you haven't addressed accessibility, this case is the template.

Case timeline: from the EAA entering into force to the summons

Four events, 137 days. The sequence from law to lawsuit was fast and deliberate.

Date Event Actor Status
28 June 2025 EAA enters into force across all 27 EU member states All EU member states ✅ Law active
7 July 2025 Formal notice (mise en demeure) issued to all four retailers ApiDV · Droit Pluriel · Intérêt à Agir 📋 Pre-litigation
1 September 2025 Compliance deadline expires with no meaningful remediation Retailers — no adequate response ❌ Deadline missed
12 November 2025 Référé cessation de l'illicite filed — all four retailers summoned Plaintiffs before Tribunal Judiciaire de Paris ⚖️ Case active

What exactly happened on 12 November 2025

The EAA came into force on 28 June 2025. Nine days later, on 7 July 2025, ApiDV and Droit Pluriel — backed by the legal collective Intérêt à Agir — issued a formal mise en demeure to Auchan, Carrefour, E. Leclerc and Picard Surgelés. The notice set a compliance deadline of 1 September 2025. That is a five-week window. The retailers did not meet it.

On 12 November 2025, the plaintiffs filed a référé cessation de l'illicite before the Tribunal Judiciaire de Paris. A référé cessation de l'illicite is an emergency summary procedure under French civil law specifically designed to obtain the cessation of an unlawful situation. It is not a standard civil lawsuit that takes years. It is a fast-track proceeding that can produce binding court orders — injunctions, daily penalties (astreintes), and public registration of the violation — within weeks. The objective here is an immediate injunction compelling the four retailers to remediate their websites and apps.

The plaintiffs are not government agencies. ApiDV (Association pour Promouvoir, Intégrer les Déficients Visuels) was founded in 1949 and has had public utility status since 1959. Droit Pluriel specializes in disability rights legal advocacy. Intérêt à Agir is the legal collective providing litigation support. This is civil society enforcement — precisely the mechanism the EAA framework is designed to enable.

Prior precedent — same plaintiffs

On 21 May 2024, the Tribunal administratif de Paris condemned the French State for failing to make educational software (including Pronote, the school management platform) accessible. The plaintiffs in that case were ApiDV and Intérêt à Agir — the same organizations now suing the supermarkets. They have an established track record of successful judicial action in accessibility enforcement.

Why only 3.4% of major French websites are actually accessible

3.4%
of major French company websites were accessible as of June 2025
Source: Observatoire du respect des obligations d'accessibilité numérique · Fédération des aveugles et amblyopes de France

The case did not emerge from nowhere. French law has required large private companies (annual turnover above 250 million euros in France) to make their websites accessible under Article 47 of Loi 2005-102, as extended by Décret n° 2019-768 of 24 July 2019. Effective compliance for those companies has been required since October 2020 for websites and July 2021 for mobile apps. That means the four defendants had multiple years to comply before the EAA ever came into force. The EAA did not create a new surprise obligation. It strengthened and broadened an existing one that was already being ignored.

The self-reported compliance figures make this concrete. Carrefour publicly claims its site is "71% accessible" — its own unverified statement. E. Leclerc's declared compliance went from 32% RGAA in May 2023 to 50% in August 2025. Fifty percent. Still illegal. Still the subject of litigation. The gap between marketing claims and audited reality is the litigation.

🛒 Auchan
auchan.fr · mobile app
Compliance level: not publicly disclosed in available documentation
🛒 Carrefour
carrefour.fr · mobile app
71%
Self-declared — not independently verified
🛒 E. Leclerc
e.leclerc · leclercdrive.fr · app
50%
Declared Aug 2025 (was 32% in May 2023) — still illegal
🛒 Picard Surgelés
picard.fr · mobile app
Compliance level: not publicly disclosed in available documentation

Why this case is a template for every EU country

Three reasons this matters far beyond France.

First, the EAA came into force in all 27 EU member states simultaneously on 28 June 2025. The legal standing to file an equivalent action exists in every member state under the national transposition law. What ApiDV and Droit Pluriel did in France, equivalent organizations in Spain, Germany, Italy, the Netherlands, Ireland and Sweden can do tomorrow.

Second, the plaintiffs demonstrated that this works. The 2024 ruling against the French State on educational software inaccessibility — involving the same plaintiff organizations — proved that accessibility litigation has judicial teeth in France. That track record is exactly what makes the 2025 supermarket case credible and well-resourced.

Third, the press coverage across specialized e-commerce, legal and accessibility media (Ecommerce Mag, Clubic, Points de Vente, testparty.ai, deque.com) means that compliance and legal teams across the EU are watching. The legal community is learning from this case. Expect advocacy groups in other member states to use the same procedural playbook: formal notice with short deadline, then emergency proceedings when the deadline is missed.

What you should do if you run an EU e-commerce site

The Auchan/Carrefour/Leclerc/Picard case is not a France-specific story. It is the first documented execution of a playbook that works across EU jurisdictions. Four steps, in order of urgency:

1

Honestly assess your WCAG 2.1 AA compliance

Do not rely on automated tools alone — they miss the majority of real WCAG issues. Commission a manual audit by users who rely on assistive technology. Your actual compliance level is the only defensible starting point.

2

Publish an accurate accessibility statement

Not a marketing percentage. A real statement with documented gaps, your remediation plan, and a working contact channel. "71% accessible" is not a legal defense — it is the kind of claim that will be audited in court.

3

Document a remediation roadmap with dates

Partial compliance with a documented plan is a far stronger legal position than unclaimed non-compliance. Show that you are actively working toward full WCAG 2.1 AA conformance with specific milestones.

4

Do not install an overlay as a substitute

The FTC's $1 million civil penalty against accessiBe confirms what European regulators have also signaled: an accessibility overlay does not constitute EAA compliance. It may increase your legal exposure if it creates a misleading appearance of compliance without the underlying remediation.

The documented technical failures — verified by expert audit

These failures were documented by blind and visually impaired IT experts commissioned by the plaintiff organizations. They are WCAG 2.1 AA violations, not subjective accessibility preferences.

🖼️

Missing alternative text

Images without alt attributes are invisible to screen-reader users. A product image with no description cannot be understood.

🎨

Insufficient color contrast

Text and UI elements that do not meet the 4.5:1 contrast ratio required by WCAG 2.1 criterion 1.4.3.

🔗

Non-explicit links

"Click here" and "Read more" links that lack meaningful context for users navigating by screen reader.

⌨️

Keyboard-inaccessible components

Interactive elements — menus, filters, carousels — that cannot be operated without a mouse.

📄

Broken content structure

Missing or incorrect heading hierarchy, landmark regions, and ARIA attributes that make page navigation impossible for screen readers.

🛒

Inaccessible checkout flows

Forms and payment flows that cannot be completed with assistive technology — effectively blocking 2 million visually impaired users from purchasing.

⚠️ Important notice: All dates, names and procedural details on this page are sourced from identified public materials: Intérêt à Agir press release of 12 November 2025, testparty.ai, deque.com, Ecommerce Mag, Clubic and Points de Vente. Case outcome is pending as of the publication date of this page. Not legal advice.

Frequently asked questions

Who exactly is suing the French supermarkets?
Two French disability rights organizations: ApiDV (Association pour Promouvoir, Intégrer les Déficients Visuels, focused on visual impairment, founded in 1949) and Droit Pluriel (disability rights legal advocacy). They are supported by the legal collective Intérêt à Agir. None of them are government agencies — this is civil society enforcement, which the EAA framework specifically enables.
What court is hearing the case, and what procedure is being used?
The Tribunal Judiciaire de Paris, through a référé cessation de l'illicite (emergency summary proceedings to obtain the cessation of an unlawful situation). This is a fast-track civil procedure that can result in binding court orders within weeks rather than months. The objective is to obtain an immediate injunction ordering the retailers to remediate their websites, not just a long-term ruling.
What did the retailers do wrong specifically?
Their e-commerce websites and mobile apps are not usable by visually impaired users. Documented technical failures include missing alternative text for images, insufficient contrast, non-explicit links, interactive components not accessible by keyboard, broken content structure, and checkout flows that cannot be completed with a screen reader. These are WCAG 2.1 AA violations.
How long had these companies had to comply with accessibility requirements?
French law has required large private companies (annual turnover above 250 million euros in France) to make their websites accessible since the Décret n° 2019-768 of 24 July 2019, with effective compliance dates in October 2020 for websites and July 2021 for mobile apps. The EAA did not create a new obligation for them; it strengthened existing ones and broadened the scope to consumer-facing services regardless of company size.
Can the same kind of lawsuit happen in other EU countries?
Yes. The EAA came into force in all 27 EU member states on 28 June 2025. Any disability rights organization in any member state has legal standing to file similar actions under the national transposition law. Spain, Germany, Italy, the Netherlands and others have active advocacy groups with legal resources comparable to ApiDV and Droit Pluriel.
What should an EU e-commerce business do right now to avoid becoming the next case?
Four urgent steps: honestly assess WCAG 2.1 AA compliance (do not rely on automated tools alone, which miss the majority of real issues), publish an accurate accessibility statement with real information about gaps and remediation plans (not a marketing percentage), document a remediation roadmap with dates, and do not rely on an accessibility overlay as a substitute for real compliance.

⚠️ Important notice: EAA-Report is a self-assessment documentation tool, not legal advice and not a third-party accessibility audit. The Accessibility Report is generated from your input data.

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✓ Last regulatory check: 27 April 2026 · No substantive changes detected · View history