Accessibility law · Europe

France RGAA 4.1.2 → WCAG 2.1 AA

In France, the standard to meet is RGAA 4.1.2 → WCAG 2.1 AA. It binds public bodies, companies with average French turnover of at least €250 million, and providers of the consumer products and services covered by the European Accessibility Act. This page was reviewed against primary sources on 30 September 2026.

Standard
RGAA 4.1.2 → WCAG 2.1 AA
Private sector
Partly
Accessibility statement
Required
Next deadline
Dec 2026
Reviewed
30 September 2026
The 50 criteria All jurisdictions Checklist

Scope

Who it applies to

Public bodies and companies with at least €250 million in average French turnover must make their websites, apps and web-based software accessible (RGAA 4.1.2, based on WCAG 2.1 A and AA). They must also publish an accessibility statement, a plan of up to three years with yearly action plans, and a compliance notice on the home page. Arcom can issue public formal notices and fines of up to €50,000, and fine again if the breach continues six months later. Since 28 June 2025, the EAA rules in the Consumer Code also cover e-commerce, banking, transport, telecoms and e-books, with fines for contraventions.

  • Public sector

    Legal persons governed by public law, private bodies that carry out a public service mission or meet general-interest needs and are mainly publicly funded or controlled, and private bodies set up by them (Loi n° 2005-102, art. 47 I 1° to 3°).

  • Private sector

    Partly

    Companies whose average annual turnover in France over the last three closed financial years is at least €250 million (art. 47 I 4° and décret n° 2019-768, art. 2). Separately, since 28 June 2025, any economic operator placing EAA products on the market or providing EAA services to consumers (Code de la consommation, art. L. 412-13), except service microenterprises. Private non-profits that provide neither essential services nor services for disabled people are outside art. 47.

Coverage

What it covers

Websites are only part of it. Each tile says whether these rules reach that kind of product, with the detail.

  • Websites

    Covered

    Internet, intranet and extranet sites of covered bodies.

  • Mobile apps

    Covered

    Mobile apps, excluding the operating system and hardware.

  • Documents

    Covered

    Downloadable documents are in the audit sample; office files published before 23 Sep 2018 are exempt unless needed for an administrative procedure.

  • Software

    Partly

    Software packages (progiciels) used through a browser or mobile app; the EAA rules add consumer operating systems and e-book software.

  • Kiosks and terminals

    Covered

    The interactive part of digital street furniture under art. 47; ATMs, ticketing, check-in and payment terminals under the EAA rules.

  • Public procurement

    Partly

    The multi-year plan must cover accessibility clauses in tenders and acceptance testing; no stand-alone procurement rule was found.

Timeline

Deadlines

Next: Dec 2026. Planned, not fixed: DINUM expects to publish RGAA 5 at the end of 2026, adding WCAG 2.2 and criteria for apps and office documents. Existing statements then stay valid for 18 months, within their three-year limit.

Dates move, so check the linked source before you plan around one.

  1. 23 Sep 2019 In force

    Public bodies: sites created since 23 September 2018 must comply.

    Source

  2. 1 Oct 2019 In force

    Companies above €250 million: sites created from this date must comply; older sites followed on 1 October 2020.

    Source

  3. 23 Jun 2021 In force

    Public bodies: mobile apps, software packages and digital street furniture must comply (1 July 2021 for companies).

    Source

  4. 8 Sep 2023 In force

    Arcom becomes the enforcer of art. 47, with fines of up to €50,000 (art. 47-1).

    Source

  5. 28 Jun 2025 In force

    The EAA rules in the Consumer Code apply to products placed on the market and services provided from this date.

    Source

  6. 27 Aug 2026 In force

    Décret n° 2026-816 takes effect: the rules point to the EU harmonised standards, the decree's own fine article is repealed and a yearly ministerial follow-up is added.

    Source

  7. Dec 2026 Expected

    Planned, not fixed: DINUM expects to publish RGAA 5 at the end of 2026, adding WCAG 2.2 and criteria for apps and office documents. Existing statements then stay valid for 18 months, within their three-year limit.

    Source

  8. 28 Jun 2030 Upcoming

    Transition ends for services run on products used before 28 June 2025 and for service contracts agreed before then. Older self-service terminals may run up to 15 years from entry into service.

    Source

Instruments

The law in France

6 laws, rules and rulings, oldest first. Each links to its primary source.

Every fact points at a primary source. Dates move, and several moved in 2025 and 2026, so check the source before you rely on one.

  1. 2005

    Loi n° 2005-102, article 47

    as amended in 2023 (loi n° 2023-171 and ordonnance n° 2023-859)

    Online public communication services of public bodies and of companies above a turnover threshold must be accessible, unless this creates a disproportionate burden. Covered bodies publish an accessibility statement, a multi-year plan with annual action plans and a home-page compliance notice.

    Primary source

  2. Jul 2019

    Décret n° 2019-768

    implementing decree for art. 47, amended by décret n° 2026-816

    Sets the €250 million threshold, the exempt content, the disproportionate-burden test, the statement contents and the compliance dates. Requires training for staff who work on online services.

    Primary source

  3. 2019

    RGAA 4.1.2

    Référentiel général d'amélioration de l'accessibilité, maintained by DINUM

    The technical method: 106 criteria covering the 50 WCAG 2.1 Level A and AA success criteria in the European standard, plus the audit sample, statement model and plan contents. Companies may use another test method if they map it to the standard and say so in the statement.

    Primary source

  4. Sep 2023

    Loi n° 2005-102, article 47-1

    created by ordonnance n° 2023-859

    Makes Arcom the enforcer: investigations, public formal notices, fines of up to €50,000 or €25,000, and a new fine if the breach continues six months later.

    Primary source

  5. Jun 2025

    Code de la consommation, article L. 412-13, and décret n° 2023-931

    EAA transposition by loi n° 2023-171, art. 16, with the arrêté of 9 October 2023

    Economic operators must place accessible products on the market and provide accessible services to consumers in the EAA sectors. Service microenterprises are exempt. Breaches are fifth-class contraventions.

    Primary source

  6. Aug 2026 Latest

    Décret n° 2026-816

    JORF n° 0198, 26 August 2026

    Ties the art. 47 rules to the EU harmonised standards and requires the RGAA to be kept up to date with them. Repeals the decree's own sanctions article and adds a yearly compliance follow-up by the minister.

    Primary source

Enforcement

Enforcement and penalties

  • Who enforces

    Arcom (Autorité de régulation de la communication audiovisuelle et numérique) for art. 47. For the EAA rules, the consumer-protection agents (DGCCRF) and sector regulators, including ARCEP, Arcom, ACPR, AMF and Banque de France. DINUM maintains the RGAA.

  • How

    Arcom can investigate, including by proportionate automated collection of publicly available data, then issue a public formal notice (mise en demeure) with a deadline and, if it is ignored, fine. It enforces all of art. 47 against public bodies, but only the statement, plan and home-page duties against companies above the threshold. The minister for disabled people runs an annual compliance follow-up and reports to the European Commission every three years. Arcom's first published notice against a ministry, over impots.gouv.fr, came in 2026.

  • Penalties

    Arcom fines of up to €50,000 for failing the accessibility duty and up to €25,000 for failing the statement, plan or home-page duties, with publication possible and a new fine if the breach lasts six months after the first. Breaches of the EAA rules are fifth-class contraventions: up to €1,500 per offence for an individual (Code pénal art. 131-13) and five times that for a company (art. 131-41).

  • Individuals

    Users report defects through the site's contact route and can then refer the matter to the Défenseur des droits. Disability associations have also gone to court under the EAA rules: in May 2026 the Lille court dismissed a case against Auchan's e-commerce arm, and an appeal was announced.

Accessibility statement

A statement is required

Required

Every body covered by art. 47, including companies above the €250 million threshold, publishes a déclaration d'accessibilité in the RGAA's fixed format: compliance status (totally compliant, partially compliant if at least 50% of RGAA criteria are met, or non-compliant), non-accessible content with reasons, a contact route, and the right to refer the matter to the Défenseur des droits. It must be updated after a substantial change, three years after publication, or 18 months after a new RGAA version. The same bodies publish a multi-year accessibility plan (schéma pluriannuel, at most three years) with an annual action plan, and show the compliance status on the home page.

Exemptions

What is exempt

Exemptions are narrow and usually have to be claimed and explained, not assumed.

  • Disproportionate burden, invoked case by case for a feature or content, justified in the statement and paired with an accessible alternative where possible.
  • Microenterprises providing services under the EAA rules: fewer than 10 staff and turnover or balance sheet of no more than €2 million.
  • Office files published before 23 Sep 2018, unless needed for an administrative procedure.
  • Pre-recorded audio and video published before 23 Sep 2020, and live audio and video.
  • Online maps, if essential location or route information is given in accessible form.
  • Third-party content the body neither funds, develops nor controls.
  • Heritage collection reproductions that cannot be made fully accessible.
  • Intranet and extranet content published before 23 Sep 2019 until substantially revised, and archives not updated after 23 Sep 2019.
  • Private non-profits that provide neither essential services nor services for disabled people.
  • Digital street furniture installed before the deadline may stay in service to the end of its economic life, up to 15 years.

The standard

What WCAG 2.1 Level AA asks for

50 success criteria: 30 at Level A and 20 at Level AA. 4.1.1 Parsing counts in this version, but WCAG 2.2 removed it as obsolete, so it has no page here.

1. Perceivable

2. Operable

3. Understandable

4. Robust

Beyond the law

6 Level A and AA criteria in WCAG 2.2 that these rules do not require yet. Meeting them now costs little and is where the rules are heading.

Meeting it

Where to start

The standard named here is WCAG 2.1 Level AA.

  1. Audit your pages against WCAG 2.1 Level AA: 50 success criteria at Level A and AA.
  2. Check text and control contrast in the Contrast Checker.
  3. Run the URL Analyzer for the problems a machine can find, then test with a keyboard and a screen reader.
  4. Publish an accessibility statement that says what does not meet the standard yet, and how to report a problem.
  5. If you sell to the public sector, document conformance in an accessibility conformance report, such as a VPAT or an EN 301 549 statement.
  6. Work through the Accessibility Checklist and keep a record of what you tested.

This is a summary to orient you, not legal advice. For a decision that matters, read the primary sources and ask a lawyer who practices there.

Questions

Common questions

  • Does it apply to private companies?

    Two ways. Art. 47 covers companies with at least €250 million average annual turnover in France, which also owe the statement and plan. Since 28 June 2025 the EAA rules cover any business, other than a service microenterprise, that sells EAA products or provides EAA services to consumers, such as an online shop or a bank.

  • What fines can Arcom impose?

    After a public formal notice that is not followed, up to €50,000 for failing the accessibility duty and up to €25,000 for failing the statement, plan or home-page duties. It can fine again if the breach lasts six months after the first fine.

  • What must the home page show?

    One of three notices: Accessibilité : totalement conforme, partiellement conforme (at least 50% of RGAA criteria met) or non conforme. It should also link to an accessibility page with the statement, the multi-year plan and the current year's action plan.

  • Is RGAA 5 coming, and should we wait for it?

    DINUM plans RGAA 5 for late 2026, adding WCAG 2.2 and criteria for mobile apps and office documents. It says current work must not be paused, and statements made before RGAA 5 stay valid for 18 months after it is published, within the three-year limit.

  • Does the €250 million threshold limit the EAA duties for online shops?

    It is disputed. In May 2026 the Lille court (tribunal judiciaire) applied the art. 47 threshold and dismissed a case against Auchan's e-commerce arm, even though it found major accessibility failures. The associations said they would appeal, and similar cases against Carrefour, E.Leclerc and Picard were still pending.

Sources

Sources

Every fact on this page comes from one of these; the few secondary sources are marked. Reviewed 30 September 2026.

Elsewhere

Also in Europe

Other regions