Accessibility statement in France: who must publish one, and what must it contain?
The short answer
In France, it applies to public bodies, certain private bodies with a public-service mission, and companies with over €250 million in French turnover. It states the website's conformity level, the content that isn't accessible, a contact for reporting problems, and the right to appeal to the Défenseur des droits, France's rights ombudsman.
Who must publish an accessibility statement?
The obligation comes from Article 47 of French law no. 2005-102. It covers:
- legal entities governed by public law;
- private bodies with a public-service mission, or financed or controlled by public entities;
- private bodies set up by those entities for non-commercial needs of general interest;
- companies whose average annual turnover in France exceeds €250 million over the last three closed financial years.
The text excludes audiovisual media service providers, as well as non-profit private bodies that provide neither an essential public service nor a service specific to disabled people.
What must the statement contain?
DINUM sets out four elements.
1. The conformity status, determined from the latest audit:
| Status | Condition |
|---|---|
| Full conformity | All RGAA control criteria are met |
| Partial conformity | At least 50% of the criteria are met |
| Non-conformity | Fewer than 50% of the criteria are met, or there is no valid audit result |
The exact calculation of that percentage holds a few surprises: I explain it in how the conformity rate is calculated.
2. The content that isn't accessible, in three separate categories: the non-conformities found, exempt content, and content under a disproportionate burden derogation, with the reasons for it.
3. A means of contact, by email or form, for reporting an accessibility defect. The person writing must get a reply within one week.
4. The right of appeal, meaning a mention that the person can refer the matter to the Défenseur des droits.
DINUM offers a template on its dedicated page. I'd advise starting from that rather than from an example copied from another website.
Where must it be published?
On an "accessibility" page, directly reachable from the home page and from any page of the website. The statement itself must be published in an accessible format: a scanned PDF won't do.
The statement must also be filed through an online service, under terms set by the public authorities. Check the procedure in force when you publish.
When must it be updated?
The statement is valid from its publication date. It must be updated in three situations:
- on the date of a substantial change or a redesign of the website;
- 3 years after its publication date;
- 18 months after a new version of the standard is published, if you apply the technical method.
That last point has a practical consequence: DINUM plans to publish RGAA 5 at the end of 2026. If that schedule holds, current statements will have to be reviewed within the following 18 months, even if the website hasn't changed.
What's the right approach?
In the order I'd do it:
- Check whether you're covered, using the list above.
- Have the audit carried out on a representative sample of pages. The list of expected pages notably includes the home page, contact, legal notice, sitemap and login, plus randomly chosen pages.
- Write the statement from the result, listing what isn't compliant.
- Publish it and add the link to every page, usually in the footer.
- Set up the contact, and someone who replies within the one-week deadline.
- Put the update dates in your calendar, and plan a review with every redesign.
A "partially compliant" statement is nothing to be ashamed of: it shows where you stand and what's left to fix.
The report and the statement are among the deliverables of my audits. The options are on the Accessibility page.
Frequently asked questions
Can you write a statement without an audit?
No, not to claim any conformity. The statement relies on an audit. Without a valid audit result, the website is declared non-compliant. The statement must still be published.
Can you carry out the audit yourself?
Yes, the texts allow self-assessment or an audit by a third party. The audit must be reliable, though: DINUM, the French digital directorate, mentions using an external provider, training internal experts or cross audits.
Does a disproportionate burden remove the need for a statement?
No. The disproportionate burden derogation doesn't exempt you from producing an accessibility statement. The content concerned and the reasons for the derogation must actually appear in it.
Does a small business covered by the European Accessibility Act have to publish the same statement?
Not exactly: this model comes from Article 47 of the French law of 2005. The European Accessibility Act has its own duty to inform consumers (Article 13 and Annex V of the directive). Many businesses meet it with a similar page, but have its content checked.
Sources
- RGAA: accessibility statement (French) · DINUM
- RGAA: scope of the obligation (French) · DINUM
- RGAA: conformity assessment (French) · DINUM
- Directive (EU) 2019/882 on the accessibility requirements for products and services · EUR-Lex, Official Journal of the European Union