France accessibility law: RGAA explained

Who has to comply

Public-sector sites and apps under RGAA since 2005; private-sector services covered by Article 47 of Loi 2005-102 as amended by the 2023 EAA transposition law.

France is one of the largest consumer markets in the EU and, thanks to Loi du 9 mars 2023, one of the strictest on sanctions. A non-EU seller shipping into France is caught by the country-of-consumption rule the same way a French provider is, and France's fixed €25,000 penalty for simply failing to publish a compliant accessibility statement means a foreign store can be sanctioned on a paperwork gap alone, before any deep technical audit. If your French-facing site prices in euros and delivers to French addresses, plan for the RGAA declaration and score, not just a WCAG pass.

What the law actually requires

The technical baseline is WCAG 2.1 Level AA via RGAA 4.1. EN 301 549 references WCAG 2.1 Level AA in full and adds a few requirements specific to mobile apps and documents. Beyond the technical bar, France requires the following operational items, which auditors check first because they are simple to verify:

• Compliance with RGAA (currently version 4.1, aligned with WCAG 2.1 AA)

• Public accessibility declaration with a measured conformance score

• Multi-year accessibility action plan published online

• Annual update of the action plan

• Designated accessibility contact and feedback mechanism

Penalties and how enforcement actually works

Up to 4% of total annual turnover for serious or repeated non-compliance; €25,000 fixed penalty for missing accessibility statement.

France splits enforcement across two bodies with distinct remits: the DGCCRF, the consumer-protection directorate that already runs market sweeps and can levy the turnover-linked fines, and ARCOM for audiovisual and media services. The DGCCRF is an active, sweep-capable regulator rather than a purely complaint-driven one, and France's system is unusual in mandating a published conformance percentage under RGAA, so an incorrect or missing score is itself a citable breach. Expect a formal mise en demeure giving a remediation window before financial penalties escalate.

Public-sector obligations

France also has a separate public-sector law: Article 47 of Loi 2005-102 — public-sector accessibility since 2005, audited via RGAA criteria. It predates the EAA and remains in force for government and public-funded sites. Public bodies must publish a conformance statement and re-audit periodically.

Practical first steps for a France site

If you are starting now and want to land before enforcement, run an automated audit, fix the high-impact issues (contrast, labels, keyboard, focus), publish an accessibility statement, and set up a feedback inbox. That sequence covers 80% of what auditors look for in a first sweep.

• Run a baseline scan to know your current score

• Fix critical and serious issues in priority order — these are the ones cited in complaints

• Publish a public accessibility statement on a stable URL (France regulators expect this discoverable)

• Add a feedback channel and answer within the country-specified window

• Re-scan after every major release; track regressions