Digital accessibility in France: who must comply, who enforces, what inaction costs

Digital accessibility in France rests on two overlapping regimes: article 47 of the law of 11 February 2005, which covers the public sector and large companies, and the rules derived from the European Accessibility Act, which have applied to many consumer services since 28 June 2025. This analysis sets out who must comply, what each text actually requires, which authority enforces what and what inaction costs, keeping the official French names and explaining them for organisations whose head office is outside France. It reflects the texts and decisions published up to October 2026, including Arcom's formal notice concerning impots.gouv.fr and the decree of 24 August 2026.

Digital accessibility in France: the essentials in 2026

Two sets of rules coexist, and they need to be told apart from the outset. The first is article 47 of Law No. 2005-102 of 11 February 2005. It requires public bodies, certain private bodies entrusted with a public service mission and companies with a turnover above €250 million to make their websites, intranets, extranets, mobile apps and software packages accessible. These services are assessed against the RGAA (Référentiel général d'amélioration de l'accessibilité, the General Accessibility Improvement Framework), and enforcement lies with Arcom (Autorité de régulation de la communication audiovisuelle et numérique), the French regulator for audiovisual and digital communication.

The second regime transposes Directive (EU) 2019/882, known as the European Accessibility Act or EAA. It sits in the French Consumer Code (code de la consommation) and has applied since 28 June 2025 to products and services intended for consumers: e-commerce, banking services, transport, electronic communications, e-books and access to audiovisual media services. It depends neither on whether the operator is public or private nor on a €250 million threshold. Enforcement falls mainly to the DGCCRF (Direction générale de la concurrence, de la consommation et de la répression des fraudes), the French government directorate in charge of consumer protection and fraud control.

The two regimes are cumulative. A retailer whose turnover in France exceeds the article 47 threshold and which sells online must both publish its accessibility statement, its compliance notice and its multi-year plan under the 2005 law, and make its purchase journey meet the EAA requirements. For an international group, this means that the French subsidiary may carry national obligations that the group's other European entities do not have, on top of the EAA rules that apply everywhere in the Union. The page Digital accessibility in France sets out this framework in a few key points; the sections below go into detail.

2026 changed the picture in three respects. On 18 June 2026, the Cour des comptes, France's supreme audit institution, published a severe assessment of the accessibility of central government online procedures. In a decision of 24 June 2026, Arcom served formal notice on the ministry responsible for impots.gouv.fr, the French tax administration's website. Finally, Decree No. 2026-816 of 24 August 2026 amended the 2019 implementing decree, and Decree No. 2026-883 of 23 September 2026 supplemented the consumer law side. RGAA 5 is also announced for the end of 2026.

• Public bodies: obligation to comply with the RGAA, documents to publish, Arcom enforcement, fines of up to €50,000 for failing to meet the accessibility requirements;
• companies with a turnover in France above €250 million: the same obligations, but Arcom can only penalise failures relating to display and documentation, up to €25,000;
• operators covered by the EAA: accessibility requirements for products and services, enforcement by the DGCCRF and sector regulators, fines of €7,500 per offence recorded;
• micro-enterprises providing services: exempt from the EAA obligations, and outside the scope of article 47 unless they perform a public service mission.

French accessibility law: the applicable texts and how they have changed

Article 47 of the law of 11 February 2005

In its original version, article 47 only covered the online public communication services of the State, local authorities and their public institutions. The 2016 Digital Republic Act (loi pour une République numérique) extended it to bodies entrusted with a public service mission and to companies whose turnover exceeds a threshold set by decree. The text was then rewritten in 2023: first by Law No. 2023-171 of 9 March 2023, which transposes the EAA, then by Ordinance No. 2023-859 of 6 September 2023, adopted on the basis of that law.

This ordinance created an article 47-1 giving Arcom responsibility for enforcing the obligations of article 47 (Légifrance, in French). Article 47 itself is divided into paragraphs that Arcom cites separately in its decisions: paragraph I sets out the accessibility obligation and the list of bodies concerned, paragraph III covers the accessibility statement and planning, and paragraph IV covers direct access to documents, the compliance notice and the reporting of issues. The distinction matters, because the maximum penalties are not the same for each paragraph.

Decree No. 2019-768 of 24 July 2019

The decree of 24 July 2019 implements article 47. It sets the €250 million threshold and how it is calculated (article 2), the list of exempt content (article 3), the criteria for disproportionate burden (article 4), the reference to a framework adopted by the ministers responsible for disability and for digital affairs (article 5), the content of the accessibility statement and of the home page notice (article 6), staff training (article 7) and the implementation timetable (article 10).

In its original wording, its article 8, in the chapter on penalties and monitoring, set out a penalty regime that predated Arcom's powers. That mechanism is no longer relevant: it was repealed by the decree of 24 August 2026, and the regime of article 47-1, administered by Arcom, now applies.

Decree No. 2026-816 of 24 August 2026

Published in the Journal officiel, France's official gazette, on 26 August 2026 and in force since 27 August 2026, this decree brings the 2019 text into line with the dates and deadlines of Directive (EU) 2019/882. It requires services to be accessible in accordance with the harmonised standards whose references are published in the Official Journal of the European Union. It asks the national framework to specify the categories of services, content and features to which its criteria apply, and to be kept up to date so that it remains at least equivalent to the European standards.

The same decree turns the chapter “Penalties and monitoring” into a chapter titled simply “Monitoring” and repeals article 8. The minister responsible for disability carries out an annual review of the compliance of the websites, intranets, extranets and mobile apps of public and equivalent bodies, drawing where appropriate on information gathered by Arcom; a report is sent to the European Commission every three years. The decree also adjusts the list of exempt content and allows digital street furniture that is already installed to remain in service until the end of its economic life, up to a maximum of fifteen years from when it was brought into service.

RGAA 4.1.2, pending RGAA 5

The General Accessibility Improvement Framework is the technical document provided for in article 5 of the decree. Version 4 was adopted by an order (arrêté) of 20 September 2019; the version in force is 4.1.2. It is based on the European standard EN 301 549 V2.1.2 and on WCAG 2.1, and turns their requirements into 106 criteria, each broken down into tests. The frameworks and their versions are presented in detail in our article on digital accessibility standards.

The official RGAA website states that version 5 is being drafted, with publication planned for the end of 2026, and makes clear that this deadline is in no way a reason to suspend or postpone work. One practical consequence follows: organisations that apply the RGAA technical method must update their statement within 18 months of a new version of the framework being published.

Who is subject to digital accessibility obligations in France?

The scope of article 47 is defined first by the nature of the organisation and then, for companies, by a turnover threshold. The official page on the scope of the obligations (in French) gives the full list; here is how to read it in practice.

The public sector in the broad sense

The first category is every legal person governed by public law: the State and its ministries, regions, départements, municipalities and groupings of municipalities, and public institutions, whether a hospital, a university, a tourist office with public status or a joint local authority syndicate (syndicat mixte). Size is irrelevant: a municipality of a few hundred inhabitants is subject to the same obligations as a ministry.

Also covered are legal persons governed by private law that are entrusted with a public service mission, or that were created to meet needs in the general interest that are not industrial or commercial in nature, where they are mainly financed or controlled by public bodies or where most members of their governing body are appointed by public bodies. An association running a social service funded by a département, a semi-public company (société d'économie mixte) operating a transport network under a concession, or a social security fund typically fall into this category. Excluded, on the other hand, are providers of audiovisual media services, as well as private non-profit bodies that provide neither essential services to the public nor services specifically intended for persons with disabilities. The page local authorities and public sector details the steps specific to these organisations.

Companies with a turnover above €250 million

Companies are subject to article 47 when their turnover exceeds €250 million. This figure is calculated for each legal person as the average annual turnover achieved in France over the last three financial years closed before the year in question. Two clarifications given by Arcom avoid common mistakes: only turnover achieved in France counts, and, within a group, the relevant figure is that of the company named in the legal notice (mentions légales) of the service, not the group's consolidated turnover.

Take a retail brand whose website is published by a company that achieved €240 million in France in 2023, €255 million in 2024 and €262 million in 2025. The average is roughly €252 million: the company is subject to article 47 for 2026. Conversely, a French subsidiary with €180 million in turnover within a group worth several billion is not covered by this regime, even if the brand is well known; it may, however, be covered by the EAA. For multinationals, the practical question is therefore which entity is named as publisher on each French-facing website and app, and what that entity's French turnover is. Group-wide compliance programmes are presented on the page large companies.

Other companies

A company below the threshold is not free of all obligations. If it offers consumers a service covered by the EAA, such as an online shop or a transport booking app, it must meet the requirements of the Consumer Code, unless it is a micro-enterprise providing services, meaning fewer than 10 employees and an annual turnover or balance sheet total not exceeding €2 million. It may also be bound by contract to a public-sector client that writes the RGAA into its specifications. The page SMEs and mid-sized companies helps with this diagnosis.

What the EAA transposition has changed since 28 June 2025

Directive (EU) 2019/882 was transposed by Law No. 2023-171 of 9 March 2023, which wrote the obligation into the Consumer Code at article L. 412-13. Decree No. 2023-931 of 9 October 2023 and an order of the same day setting out the accessibility requirements completed the framework; the implementing rules are in articles D. 412-49 to D. 412-62 of the code. Decree No. 2026-883 of 23 September 2026, published in the Journal officiel of 24 September 2026, further supplements the application of article L. 412-13: for the detail of its provisions, refer to the consolidated version of the Consumer Code.

These obligations have applied since 28 June 2025. They cover two families, summarised in the DGCCRF practical guide to the Accessibility Directive (in French):

• products: computers and operating systems, payment terminals and certain self-service terminals, smartphones and telecommunications equipment, television equipment giving access to digital television services, and e-readers;
• services: telephony and electronic communications, access to audiovisual media services, certain passenger transport services, consumer banking services, e-books, e-commerce, and emergency communications to 112.

Service providers must design and provide compliant services, draw up information explaining how they comply and make it available to the public, monitor that compliance over time and take corrective action. Manufacturers bear obligations similar to those of CE marking: technical documentation, an EU declaration of conformity, and retention of the file for five years. Importers and distributors check compliance before placing products on the market or making them available.

Two exceptions can be claimed case by case: fundamental alteration of the nature of the product or service, and disproportionate burden. In both cases, the operator informs the market surveillance authority and keeps a supporting file; exchanges go through the competent departmental directorate for the protection of the population, known by its French acronym DD(ETS)PP. Transition periods exist: a service provider may continue to use until 28 June 2030 products it was lawfully using before 28 June 2025; service contracts concluded before that date may continue unchanged until they expire, and at the latest until 28 June 2030; self-service terminals already in place may remain in service until the end of their economic life, up to a maximum of fifteen years. The DGCCRF points out that websites and mobile apps are not “products” within the meaning of the directive, so these transitional arrangements do not cover them.

For a company operating in France, the EAA mainly changes the nature of the question. Under article 47, you ask whether the organisation is covered; under the EAA, you ask whether the service is. A single group may therefore have a brand website outside the scope of the EAA, an e-commerce site subject to the EAA, and reporting obligations under article 47 for all its services if it exceeds the threshold. A company that already complies with the EAA in another Member State will find the same European requirements in France, but must still check whether the French entity also falls under article 47. Our analysis of the European Accessibility Act details the products and services covered; assessment against WCAG and EN 301 549 is the subject of a compliance audit.

RGAA compliance: the six concrete requirements of article 47

Article 47 does not stop at a general principle of accessibility. It imposes a set of verifiable obligations, which Arcom checks one by one. Here they are, in the order in which an organisation should tackle them.

1. Make the services compliant. Services must meet the accessibility requirements, which the RGAA translates into 106 criteria. The assessment covers a representative sample that includes at least, where they exist, the home page, the contact page, the legal notice, the accessibility page, the site map, help and login pages, as well as pages specific to each type of service, downloadable documents and the steps of each process. Randomly selected pages must make up at least 10% of the sample. The organisation may assess itself or use a third party. Companies covered because of the threshold may use another test method, on three conditions: they must disclose it on request, produce a correspondence table with the chosen standard and mention it in the statement.
2. Publish an accessibility statement. For each service, the statement (déclaration d'accessibilité) gives the compliance status, the list of inaccessible content and the reasons, any alternatives, the way to report an issue and the available remedies. It is published in an accessible format on a dedicated page that can be reached directly from the home page, and it is filed through a government online service. It must be updated no later than three years after publication, after a redesign or substantial change, and within 18 months of a new version of the framework for organisations that apply its technical method. Our guide to the accessibility statement goes through the template section by section.
3. Display the compliance notice on the home page. Only three wordings are possible, and on a French-language site they appear in French: “Accessibilité : totalement conforme” (fully compliant) if all applicable criteria are met, “Accessibilité : partiellement conforme” (partially compliant) if at least 50% are met, and “Accessibilité : non conforme” (non-compliant) below 50% or where there is no valid audit result. The notice may be a link to the accessibility page or to the statement.
4. Adopt a multi-year accessibility plan. Lasting no more than three years, the multi-year plan (schéma pluriannuel de mise en accessibilité) describes the organisation's policy: the place of accessibility in its digital strategy, the role of the accessibility lead, human and financial resources, training, use of external expertise, accessibility requirements in procurement, testing with persons with disabilities, planned audits and the timetable for fixes, starting with the most visited content.
5. Publish an annual action plan. The multi-year plan is broken down each year into an action plan. The plan for the current year must be online: an out-of-date plan does not meet the obligation. This is precisely one of the breaches Arcom identified on impots.gouv.fr, where the published plan covered the year 2024.
6. Provide a means of contact and respond. Users must be able to report an accessibility issue through a mechanism that is itself accessible, such as an email address or a form. According to the framework, the organisation responds to any complaint within one week of it being sent. The statement then reminds users that they can refer the matter to the Défenseur des droits.

Two less visible obligations complete this foundation. The 2019 decree provides that the continuing training of staff who work on digital services includes theoretical and practical teaching on accessibility. It also governs the exemption for disproportionate burden: it is assessed case by case and item by item, must be justified in the statement with an accessible alternative where reasonably possible, and cannot be based on a lack of priority, time or knowledge.

Intranets, mobile apps, PDFs, video: the real scope

The term “website” is misleading. Article 47 covers online public communication services in the broad sense: websites, intranets and extranets, software packages used through a browser or a mobile app, mobile apps themselves, and the interactive part of digital street furniture, such as an information kiosk. Operating systems and hardware remain out of scope. Most of the difficulties arise within this wider perimeter.

Intranets and extranets

A local authority's intranet or a public institution's supplier extranet is subject to the same requirements as its public website. Intranet or extranet content published before 23 September 2019 is exempt until it is substantially revised. In practice, replacing the leave management tool or the HR portal removes the exemption: that is the right moment to write accessibility into the specifications. The issue goes beyond compliance, since an employee who uses a screen reader must be able to book leave or view a payslip without assistance.

Mobile apps and software packages

The iOS and Android apps of covered organisations have been in scope since 2021, as have business software packages accessed through a browser. RGAA 4.1.2 was designed primarily for web content, and the August 2026 decree specifically asks the future framework to state which categories of services its criteria apply to. In practice, a native app is assessed against EN 301 549 and tested on real devices with VoiceOver and TalkBack; this is the purpose of a mobile app audit. Web views embedded in an app, such as a payment form opened in an in-app browser, are assessed with the RGAA.

Office documents

Office files published before 23 September 2018 are exempt, unless they are needed for an administrative procedure in progress. A local authority that publishes its council minutes each month as scanned PDFs must therefore make sure that recent documents are tagged, titled and have a language set, or offer an accessible version. The impots.gouv.fr case is telling: Arcom found that the tax notice in PDF, downloadable from the personal account area, had no title, no defined language and no structure tagging, and that no accessible alternative was offered (RGAA criterion 13.3).

Video and live content

Pre-recorded audio and video content published before 23 September 2020 is exempt, as is live content. A video presenting a service published in 2026 must therefore have subtitles, a transcript and, if the images convey information that the soundtrack does not, audio description or an equivalent alternative. The live stream of a municipal council meeting is exempt, but the recording put online afterwards becomes pre-recorded content.

Maps, third-party content and archives

Maps and mapping services are exempt if essential information, such as an address or a route, is provided in an accessible digital form. Third-party content that the organisation neither funds, develops nor controls is also exempt, which does not cover an appointment booking module that the organisation itself has bought and integrated. Finally, content that is not needed for an active procedure and has not been updated since 23 September 2019, archives in particular, is exempt. Because the decree of 24 August 2026 adjusted this list, check the consolidated version of the decree before relying on an exemption.

Who enforces what since 2025

The division of responsibilities follows the distinction between the two regimes. It was set in two stages: in September 2023 for article 47, with the ordinance giving enforcement to Arcom, and then on 28 June 2025 for the products and services covered by the EAA.

• Arcom enforces the obligations of article 47 for public and equivalent bodies: compliance with the accessibility requirements as measured by the RGAA, the compliance notice, the existence and conformity of the statement, the multi-year plan and the annual plan, and the reporting mechanism. Breaches are recorded by sworn officers;
• for companies above the threshold, Arcom is only competent for the display and documentation obligations: it cannot act solely on the basis of a failure to meet the accessibility requirements;
• the minister responsible for disability carries out the annual review of the compliance of public services and prepares the three-yearly report for the European Commission;
• the DGCCRF enforces the rules for products and most EAA services, in coordination, depending on the sector, with Arcom, Arcep (the telecoms and postal regulator), the Banque de France, the ACPR (Autorité de contrôle prudentiel et de résolution, the banking and insurance supervisor) and the AMF (Autorité des marchés financiers, the financial markets regulator);
• since 28 June 2025, Arcom also enforces the accessibility of services giving access to audiovisual media services: websites, apps, electronic programme guides and distributors' offers.

Arcom's English-language page on the accessibility of digital sites and services also contains a useful warning: the authority does not delegate to any person or group the task of acting on its behalf. A letter presented as a “compliance check” mandated by Arcom that goes on to offer a paid audit should therefore be treated with suspicion. Foreign head offices that receive such letters through their French subsidiary should route them to their legal team rather than to the web team.

For a large company, this division has a direct consequence. Arcom will check that the notice, the statement, the multi-year plan and the annual plan exist and are consistent; the actual quality of an online checkout journey will be examined by the DGCCRF under the EAA. A compliance file must therefore be able to answer both bodies, with different kinds of evidence.

Digital accessibility penalties in France: amounts, procedure, hidden costs

Under article 47

The procedure starts with formal notice (mise en demeure). If the breach persists after the deadline set, Arcom may impose a financial penalty of up to €50,000 for failing to meet the accessibility requirements and up to €25,000 for the other obligations, namely the statement, the notice, the multi-year plan, the annual plan and the reporting mechanism. The amount is adjusted according to the nature, seriousness and duration of the breach.

Arcom's decision of 24 June 2026, available in English, shows how these rules are applied. On impots.gouv.fr it identifies four breaches of the accessibility requirements: the tax notice in an inaccessible PDF, a messaging section whose hidden content can be reached neither by keyboard nor by screen readers, a drop-down menu for choosing the tax year that only opens with a mouse, and a table of furnished letting income whose cells are not linked to their headers. On top of these come five breaches relating to the accessibility statements and one relating to the action plan. The authority grants nine months for the accessibility requirements and two months for the documentation obligations.

These deadlines give every organisation a useful sense of scale: fixing components takes months, but republishing an accurate statement and an up-to-date plan takes a few weeks. Documentation breaches are the easiest to establish and the quickest to fix; they should be dealt with first.

Under the EAA

DGCCRF officers can order businesses to bring their products and services into compliance; these injunctions can carry a periodic penalty payment (astreinte) and a publicity measure. Breaches are fifth-class petty offences (contraventions de la cinquième classe) under article R. 451-4 of the Consumer Code, punishable by fines of €7,500 that are cumulative according to the number of offences recorded. For products, marketing can be suspended by ministerial order if non-compliant practices persist. An e-commerce site with several distinct defects in its checkout process therefore faces an amount that rises with each offence recorded.

What inaction costs beyond fines

Maximum penalties do not tell the whole story about the real cost. The Cour des comptes stresses that inaccessibility is not a saving: when a procedure cannot be completed online, the administration has to fall back on more expensive channels, such as the telephone and the front desk. The same reasoning applies to a company: every customer who cannot complete an online payment calls customer service or goes to a competitor.

Other costs come on top. An Arcom decision is published in the Journal officiel, which exposes the organisation publicly. Public buyers and large companies increasingly include accessibility requirements in their tenders, and the Cour des comptes recommends making standard clauses widespread in public procurement. Finally, fixing a service already in production costs more than designing it accessibly: every non-compliant component in a design system is multiplied across all the pages that use it.

Summary table: obligations, penalties and authorities by type of organisation

The table below summarises the position of each category of organisation as at 27 October 2026. It does not replace an analysis of your own case, particularly where you fall under both article 47 and the EAA.

User remedies against an inaccessible service

Remedies are not reserved to the authorities. A user who cannot fill in an application form for social assistance, get past a visual captcha or download a certificate has several options, and organisations benefit from knowing them in order to anticipate them.

1. Direct reporting. The first step is the means of contact given in the accessibility statement. The organisation must respond within one week and, if the content cannot be fixed quickly, offer an alternative: sending the document in another form, handling the request by telephone, or providing assistance.
2. The Défenseur des droits. If there is no response or no solution, the user can refer the matter, free of charge, to the Défenseur des droits (Defender of Rights), France's independent authority for the protection of rights and freedoms: through the online form, by meeting a delegate in their region, by post without a stamp to Défenseur des droits, Libre réponse 71120, 75342 Paris CEDEX 07, or by telephone on 09 69 39 00 00 (+33 9 69 39 00 00 from abroad). Deaf and hard-of-hearing people can use the Acceo service. The contact options are summarised on the English-language page of the Défenseur des droits.
3. Reporting to the enforcement authorities. For a product or service covered by the EAA, consumers can report the defect on SignalConso, the government's consumer reporting platform, or call RéponseConso on 0809 540 550. These reports feed into DGCCRF inspections.
4. Formal notice and legal action. A user or an association can send the organisation a written formal notice, which recalls the obligation, describes the blockage precisely and sets a reasonable deadline. If there is no response, legal action remains open before the competent court, the administrative court where a public service is concerned.

For the organisation, the best defence is the quality of the first response. A complaint handled within a few days, with an immediate workaround and a commitment to fix the issue recorded in the action plan, defuses most disputes. The “Feedback and contact” section of the statement should therefore point to a mailbox that is actually monitored, not to a generic address with no identified owner. For international groups, this mailbox must be staffed by people able to reply in French, since most complaints concerning a French service will be written in French.

State of play: what the official figures show

The most recent assessment is that of the Cour des comptes, in its observations published on 18 June 2026 (in French). In 2019, the State had set itself the goal of making 250 essential administrative procedures, tracked by the Observatory of the quality of online procedures, fully compliant with the RGAA. In January 2026, only 7% of the main online procedures met all 106 criteria of the framework. The Cour des comptes notes that the tools and funding are under-used and that the power to impose penalties had not been exercised until then.

The Cour des comptes usefully qualifies this figure: a partially compliant procedure may still be usable from start to finish by a person with a disability. The reverse is also true, and it is the main lesson for teams: a high compliance rate does not guarantee that a journey can be completed, if the criterion that is not met is the one that blocks form submission. Its recommendations cover standard clauses in public procurement, building accessibility into every stage of IT projects, and training for both civil servants and contractors.

On the enforcement side, the situation moved on after the report was published. Arcom made public its formal notice concerning impots.gouv.fr on 6 July 2026. The annual review entrusted to the minister by the August 2026 decree should also produce regular data on public-sector websites, intranets, extranets and apps, sent to the European Commission every three years. For the private sector, no consolidated official statistics on the compliance of companies above the threshold or of EAA services have been published to date.

For an organisation, these figures have a practical consequence: the risk is no longer theoretical. The first decisions target a heavily used central government service, the breaches identified are precise and documented criterion by criterion, and the deadlines granted for the documentation obligations are short.

Timeline: the dates that matter

Digital accessibility in France for companies and the public sector: an eight-step action plan

Bringing services into compliance follows a simple logic: establish what applies, measure, publish what must be published, then fix in order of impact. The eight steps below apply to a local authority as much as to a company; only the evidence expected differs.

1. Establish your position. Determine whether you fall under article 47 (legal status, public service mission, average turnover in France of the publishing company over three closed financial years) and whether some of your services fall under the EAA. Record the result and the reasoning behind it: it is the first document in your file. For a group, carry out this analysis entity by entity, using the publisher named in each service's legal notice.
2. Inventory services and content. List websites, subdomains, intranets, extranets, apps, software packages and kiosks, but also families of documents (council minutes, forms, notices, invoices) and videos. For each, identify the internal owner, the supplier and the date of the next redesign.
3. Have a representative sample audited. Build the sample according to the RGAA rules, with the mandatory pages, the key journeys and randomly selected pages. An RGAA audit carried out manually, criterion by criterion and with assistive technologies, gives the compliance rate and the list of non-conformities to fix; our audits take three weeks on average.
4. Publish the declarative elements without delay. As soon as the result is known, put online the correct notice, the statement, the accessibility page and a monitored means of contact. These are the breaches that are easiest to establish and those for which Arcom grants the shortest deadlines. The template and filing process are described on the official page on the accessibility statement (in French).
5. Fix by journey, not by criterion. Prioritise complete blockages on the most used procedures: login, payment form, a drop-down menu that cannot be used by keyboard, a document to download, a captcha with no alternative. A remediation team can deal with shared components, which fix many pages at once.
6. Adopt the multi-year plan and the annual plan. Set out over no more than three years the accessibility lead, the budget, training, accessibility clauses in procurement and the timetable for fixes, then break this down into the plan for the current year, published and dated.
7. Secure every new release. Build accessibility into the design system and the acceptance criteria, and check releases before they go into production through accessibility acceptance testing. This is what prevents you from losing within six months the level gained through the audit.
8. Train teams and check real-world use. Train content editors, developers, project managers and buyers in their role through targeted training, and have the essential journeys tested by persons with disabilities during real user testing. Finally, schedule the update of the statement: three years at most, and within 18 months of RGAA 5 being published.

Checklist before a request from Arcom or the DGCCRF

• the compliance notice appears on the home page and matches the rate from the latest audit;
• the statement is less than three years old, follows the regulatory template and has been filed through the online service;
• the multi-year plan and the plan for the current year are online, in an accessible format, and linked from the statement;
• the means of contact works, is itself accessible, and complaints receive a reply within one week;
• each exemption for disproportionate burden is justified, limited in time and accompanied by an alternative;
• recent PDFs needed for a procedure are tagged, or an accessible version is offered;
• for services covered by the EAA, public information on compliance exists and a monitoring procedure is documented.

Frequently asked questions