How the EAA Is Enforced in France

Livana Team7 min29 April 2026

France was ahead of most EU countries on digital accessibility long before the European Accessibility Act existed. The country introduced its first accessibility requirements in 2005, and its national framework - the RGAA - has been a reference point for accessibility compliance in Europe ever since.

With the EAA now enforceable, France's existing infrastructure gives it a head start on enforcement. Here's how it all fits together.

France's accessibility history

France's digital accessibility journey started with the Law of February 11, 2005 (Loi 2005-102), also known as the Law for Equal Rights and Opportunities. This law required public sector websites to be accessible, making France one of the first EU countries to mandate web accessibility.

The technical implementation of this law is the RGAA (Referentiel General d'Amelioration de l'Accessibilite) - France's national accessibility standard. The RGAA translates WCAG success criteria into testable rules with specific testing methodologies. The current version, RGAA 4.1, maps to WCAG 2.1 Level AA.

Key milestones

- **2005** - Law 2005-102 established accessibility requirements for public sector
- **2009** - First version of RGAA published
- **2012** - Decree extending requirements to certain large private companies
- **2019** - Law for a Digital Republic strengthened enforcement, added penalties
- **2023** - EAA transposed into French law
- **2025** - EAA enforcement begins

How France transposed the EAA

France integrated the EAA into its existing legislative framework rather than creating standalone legislation. The transposition was handled through amendments to the Code de la Consommation (Consumer Code) and the existing accessibility legislation.

This approach means France's EAA implementation builds on years of existing accessibility law and enforcement experience. The requirements align with EN 301 549, consistent with the EAA directive, while leveraging the RGAA as the practical testing methodology for web content.

Enforcement bodies

France has multiple bodies involved in accessibility enforcement, each with different responsibilities.

ARCOM (Autorite de Regulation de la Communication Audiovisuelle et Numerique)

ARCOM is France's audiovisual and digital communications regulator, formed in 2022 from the merger of CSA and Hadopi. For EAA purposes, ARCOM oversees:

- Audiovisual media services (streaming platforms, video on demand)
- Telecommunications services
- Digital communication services

ARCOM has the authority to investigate complaints, conduct audits, and recommend penalties for non-compliance in its sector.

DGCCRF (Direction Generale de la Concurrence, de la Consommation et de la Repression des Fraudes)

The DGCCRF is France's consumer protection authority. It handles enforcement for consumer-facing services covered by the EAA, including:

- E-commerce websites and platforms
- Banking and financial services (in coordination with financial regulators)
- General consumer services

The DGCCRF conducts market surveillance, responds to consumer complaints, and has the power to impose administrative fines.

Defenseur des Droits

The Defenseur des Droits (Defender of Rights) is an independent authority that handles discrimination complaints, including disability discrimination. While not the primary EAA enforcement body, it can:

- Receive complaints from users who encounter accessibility barriers
- Investigate potential discrimination
- Mediate between consumers and businesses
- Refer cases to other enforcement bodies

Penalty structure

France's penalty framework for EAA non-compliance builds on its existing accessibility penalty regime.

Administrative fines

For private sector businesses covered by the EAA, penalties include fines up to 50,000 euros per violation. The amount considers:

- Severity of the non-compliance
- Number of users affected
- Duration of the violation
- Whether the business has shown good faith in attempting to comply
- History of previous violations

Public sector penalties

For public sector websites (under the WAD/existing French law), the penalty for failing to publish an accessibility statement is 20,000 euros per year. This existing framework gives an indication of how seriously France treats accessibility compliance.

Service suspension

For repeat offenders or serious violations, enforcement bodies can order the suspension of non-compliant services until accessibility is achieved. This is a powerful enforcement tool that goes beyond financial penalties.

Public naming

France allows enforcement bodies to publicly name non-compliant organisations. The results of public sector accessibility audits are already published on government websites, and a similar approach is expected for private sector EAA enforcement.

The RGAA conformity requirement

France's approach to measuring accessibility compliance is notably specific. Rather than a simple pass/fail against WCAG, the RGAA uses a conformity percentage system.

How it works

When an RGAA audit is conducted, each applicable criterion is tested across a representative sample of pages. The result is a conformity rate - the percentage of applicable criteria that are fully met.

- **100%** - full conformance
- **75-99%** - partial conformance with significant compliance
- **50-74%** - partial conformance with notable gaps
- **Below 50%** - non-conformant

Public sector organisations are required to display their conformity rate on every page of their website. While this specific display requirement hasn't been extended to the private sector under the EAA, the percentage-based assessment methodology is likely to be used in enforcement.

What this means for your business

If you operate in France, expect enforcement bodies to evaluate your accessibility in quantitative terms. A website with 90% conformity will be treated differently than one at 40%. This creates an incentive for incremental improvement rather than an all-or-nothing approach.

How French enforcement differs

France's approach to accessibility enforcement stands out from other EU countries in several ways.

Mature infrastructure

With nearly 20 years of accessibility legislation, France has established processes, trained auditors, and institutional knowledge that most other member states lack. This means enforcement is likely to be faster and more thorough.

Quantitative assessment

The RGAA's conformity percentage approach provides a more nuanced evaluation than a binary compliant/non-compliant assessment. It allows enforcement bodies to differentiate between businesses making genuine efforts and those ignoring accessibility entirely.

Existing private sector obligations

Unlike many EU countries where the EAA is the first time private sector businesses face accessibility requirements, France has had obligations for large private companies since 2012. The EAA expands the scope, but the concept isn't new.

Active disability advocacy

France has a strong network of disability organisations and advocacy groups that actively monitor accessibility and file complaints. Organisations like Braillenet (now Access42), APF France Handicap, and the CNSA play an active role in pushing for enforcement.

What businesses in France should do

If you're already subject to French accessibility law

The EAA may expand your obligations. Review whether any additional services you provide fall under the EAA's scope using our EAA Scope Checker. Ensure your existing RGAA conformity work extends to these services.

If the EAA is your first accessibility obligation

**Audit your website** - run a [multi-engine scan](/) to establish your current accessibility baseline. Understanding where you stand is the first step.
**Prioritise against RGAA criteria** - while EN 301 549 and WCAG are the legal reference, the RGAA provides the most practical testing framework for France.
**Fix critical barriers first** - keyboard navigation, form accessibility, image alternatives, and heading structure are the most common failure areas.
**Publish an accessibility statement** - use our [Accessibility Statement Generator](/tools/accessibility-statement-generator) to create one that meets French requirements.
**Set up continuous monitoring** - accessibility breaks with every code change. Catch regressions before they become complaints.

Working with French auditors

If you need a formal RGAA audit, look for auditors certified by the French government or accredited by COFRAC (Comite Francais d'Accreditation). An automated scan from Lumi gives you a strong baseline, but a formal RGAA audit includes manual testing that goes beyond what any automated tool can cover.