France's EAA Penalty: Why It's €1,500, Not €50,000 — and Why That Understates the Risk
France's EAA fine is a €1,500 criminal contravention, not the €50,000 quoted everywhere. But the biggest enforcement so far hasn't been the fine at all — it's been a court-ordered daily penalty. Here's how both work.
Quick answer
France's EAA product-and-service penalty is a 5th-class contravention — up to €1,500, and up to €3,000 for a repeat offence where the rules provide for it (Code pénal Art. 131-13). The €50,000 figure everywhere online is from a different law — the older public-sector website regime enforced by Arcom. But don't read €1,500 as "France is safe": the first major French enforcement was a civil court ruling against Carrefour (June 2026), which imposed €500 per day if the company doesn't make its site accessible in time.
France has two accessibility laws — and people mix them up
Almost every wrong French figure comes from confusing two completely separate regimes:
- The public-sector / big-company website law — Article 47 of the 2005 disability law, using the RGAA standard, enforced by the regulator Arcom. This is where the €50,000 comes from.
- The EAA product-and-service law — the 2023 transposition sitting in the Consumer Code, enforced through the criminal contravention system and market surveillance (DGCCRF). This is the EAA fine, and it's €1,500.
| EAA product & service law | Article 47 website law | |
|---|---|---|
| Who it covers | Businesses selling EAA products and services to consumers | Public bodies and companies above €250m French turnover |
| Enforced by | DGCCRF, through the contravention system | Arcom |
| Maximum fine | €1,500 (€3,000 repeat, where provided) | €50,000 (non-compliance) / €25,000 (missing documentation) |
| Legal basis | Décret 2023-931 + Code pénal Art. 131-13 | Loi 2005-102, Art. 47 |
They're different laws, different standards of who's covered, different regulators, and very different numbers. Quoting the Arcom €50,000 as "the EAA fine" is the single most common French error.
What the law says
France chose to enforce the EAA transposition not through administrative fines but through contraventions — minor criminal offences. The implementing decree, Décret n° 2023-931 (Art. R.451-4), classifies the EAA breaches — CE-marking violations, marketing a non-conforming product, failing to produce conformity documentation, providing a non-compliant service — as contraventions de la 5e classe (Légifrance).
And the Penal Code sets what a fifth-class contravention costs:
"5° 1 500 euros au plus pour les contraventions de la 5e classe, montant qui peut être porté à 3 000 euros en cas de récidive lorsque le règlement le prévoit, hors les cas où la loi prévoit que la récidive de la contravention constitue un délit."
("5° No more than €1,500 for fifth-class contraventions, an amount that may be raised to €3,000 for a repeat offence where the regulation so provides, except where the law makes a repeat contravention a délit.")
— Code pénal, Art. 131-13 (Légifrance)
So on paper, the EAA fine in France is small — the lowest fixed figure in the EU.
The €50,000 the internet quotes
For completeness, the €50,000 is real — it just belongs to the other law. Under Article 47 (the public-sector/large-company website regime), Arcom can impose up to €50,000 for accessibility non-compliance and €25,000 for missing documentation. Two important limits: it only applies to public bodies and private companies above €250 million in French turnover, and for those large private companies Arcom can only check the disclosure obligations, not the accessibility itself. None of this is the EAA product/service fine — but it's what gets miscopied as one.
Why €1,500 badly understates the real risk
Here's the part a headline number hides. The most significant accessibility enforcement in France to date didn't come from the €1,500 contravention or from a regulator at all — it came from a civil court, in a case brought by disability organisations.
On 4 June 2026, the Tribunal judiciaire de Caen ordered Carrefour to make its website and app fully accessible within six months, or pay €500 per day after that — under Article L.412-13 of the Consumer Code. The court described accessibility as "an obligation of result, not of means." A €500/day penalty running for a year is €182,500 — more than a hundred times the €1,500 contravention.
That's the real French risk model: a small statutory fine, but a live civil-litigation route — driven by well-organised associations — that can produce compounding daily penalties and a public court judgment.
Who enforces it
Three routes run in parallel in France:
- DGCCRF — the consumer-protection and market-surveillance authority — polices the EAA product/service rules, focused on e-commerce and consumer services, via the contravention system.
- Arcom — enforces the separate public-sector/large-company website regime (the €50,000 track).
- The civil courts — where consumers and disability associations can sue directly for compliance, as in the Caen ruling.
Has it been enforced yet?
Yes — more visibly than almost anywhere. While regulator-issued contraventions haven't made headlines, the Caen ruling shows the litigation route is active now. France is a case where "few fines" does not mean "low risk."
What this means for your business
Don't be reassured by €1,500. If you sell to French consumers online, your biggest exposure is a civil action producing daily penalties and a public judgment. The defensive move is the same everywhere — get to EN 301 549 / WCAG 2.1 AA and document it — but in France the motivation is litigation risk, not the statutory fine. And if you're above €250 million in French turnover, the Article 47 website regime is a separate obligation you may carry as well.
Frequently asked questions
Is the French EAA fine €50,000?
No. The EAA product-and-service fine is a €1,500 contravention (up to €3,000 for a repeat offence where provided). The €50,000 belongs to the separate public-sector/large-company website law enforced by Arcom.
So is France low-risk?
No. The statutory fine is small, but civil litigation is the real threat — the Caen court imposed a €500/day penalty if the company doesn't fix its site in time.
Who enforces the EAA in France?
DGCCRF for the product/service rules (via contraventions), Arcom for the separate public-sector website regime, and the civil courts for direct consumer and association actions.
What was the Carrefour ruling?
A June 2026 order by the Tribunal judiciaire de Caen requiring Carrefour to make its site and app accessible within six months or pay €500/day, in a case brought by disability organisations under the Consumer Code.
Related
- ← Back to EAA Fines by Country — the full 27-state comparison
- The Netherlands' EAA fine — another country quoted at the wrong number
- How we verified all 27 national laws — our sourcing method
