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.

If your service reaches consumers in France, EAA enforcement applies the same way it does to a domestic provider. The "country of consumption" rule means a Shopify store run from outside the EU but selling into France is covered. There is no carve-out for non-EU sellers.

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.

DGCCRF (consumer protection) and ARCOM runs the audits. They start with the largest covered services and move down. The first cycle of EAA audits in 2025–2026 will focus on visible non-compliance — missing accessibility statements, obvious WCAG violations on the homepage, lack of feedback channel — because those are cheap to detect. Deep technical audits come later.

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

Frequently asked questions

Accessibility law in nearby jurisdictions