The EAA in France: what your online shop must do

France is not a newcomer to digital accessibility. It legislated on it in 2005, twenty years before the EAA, and built a national audit framework — the RGAA — that has no equivalent in Germany, Spain or Italy. What the EAA changed on 28 June 2025 is who is covered: an obligation that used to concern public bodies and very large companies now reaches ordinary online shops. If you sell to consumers in France, here is the French regime as it actually stands — including the one penalty that most foreign merchants never see coming.

Which law: loi 2023-171 and ordonnance 2023-859

France transposed the European Accessibility Act — Directive (EU) 2019/882 — in two steps rather than one. Loi n° 2023-171 of 9 March 2023, a wide-ranging statute adapting French law to European Union law (known as a loi DDADUE), carried the directive into the national order and authorised the government to complete it. Ordonnance n° 2023-859 of 6 September 2023, with its implementing decrees, then set out the detail: which products and services are covered, what conformity means, who supervises, and what the penalties are. The substantive obligations apply since 28 June 2025, the date fixed across the whole Union.

Do not look for a single, memorable French « accessibility act » the way you would look for the German BFSG or the Spanish Ley 11/2023. In France the obligation is layered onto an older framework — article 47 of loi n° 2005-102 of 11 February 2005, which already imposed digital accessibility on public bodies and, later, on very large companies. The EAA is what extended that logic to consumer-facing digital services, e-commerce included.

Which services are covered

The French transposition follows the directive’s list of consumer-facing digital products and services:

• e-commerce — websites and apps that sell online;
• banking and payment services;
• passenger transport (ticketing, travel information);
• telephony and electronic communications;
• e-books and their distribution platforms;
• on-demand audiovisual media services.

In plain terms: if you sell a product or a service online to consumers in the European Union, you are very probably in scope.

How much: the French penalty ladder

Supervision of private companies runs through a formal notice first, penalty second sequence. The authority gives you a deadline to bring the service into line; if the breach survives that deadline, it can impose a financial penalty. What makes the French ladder distinctive is that it does not stop at a single, one-off amount.

Who enforces? ARCOM and the DGCCRF

France did not create a single accessibility regulator. Two existing authorities share the ground:

• ARCOM — the audiovisual and digital communication regulator — issues formal notices and can impose financial penalties, including publication of the decision, a reputational sanction that costs more than the fine for many consumer brands;
• the DGCCRF — the competition, consumer affairs and fraud-control directorate — carries out inspections, and it is the one that matters most for e-commerce and product conformity. It is the same body that already inspects your pricing display, your terms of sale and your consumer-law compliance.

An inspection can be triggered by a complaint — a disabled consumer unable to complete a purchase, for instance — as readily as by a routine check. For a shop already known to the DGCCRF for other consumer-law reasons, accessibility simply joins the list of things that can be looked at during a visit.

The French particularity: the declaration is punished on its own

Beyond technical accessibility, French law requires you to publish an accessibility declaration on the site. It states the conformity status, the evaluation method used, the content that is not yet accessible, and the routes of redress open to the user — in France, ultimately the Défenseur des droits, the independent rights ombudsman.

This is where foreign merchants are most often caught out. In most Member States the accessibility information is an obligation whose breach is absorbed into the general non-conformity finding. In France it carries its own penalty, up to €25,000. And it is, by a wide margin, the easiest breach to establish: an inspector does not need to audit fifty technical criteria to record that no declaration is published. It takes one look at your footer.

The technical standard: EN 301 549 / WCAG 2.1 AA — and the RGAA

As across the Union, a service’s conformity is presumed when it meets the harmonised standards whose references are published in the Official Journal of the European Union. For web services that standard is EN 301 549, which incorporates WCAG 2.1, level AA. A site built to WCAG 2.1 AA meets the core of the requirements.

What France adds is a named national method: the RGAA (Référentiel général d’amélioration de l’accessibilité), the French audit framework built on the same WCAG criteria but with its own test procedure and its own declaration template. You will meet the RGAA by name in French public procurement, in tender documents, and in the vocabulary of every French accessibility auditor. For an online shop, working to WCAG 2.1 AA and expressing the result in RGAA terms is what makes your compliance legible to a French buyer or inspector.

For e-commerce specifically, the requirements bear hardest on the parts of the journey that involve identification, security and payment: a checkout that cannot be completed with a keyboard or a screen reader is the failure that generates complaints.

Is my small online shop covered?

The EAA — and therefore the French regime — exempts microenterprises that provide services: fewer than 10 people and annual turnover or balance-sheet total not exceeding €2 million. Both conditions must hold. If you are over either threshold, you are covered now. The exemption also works differently for products, and most established shops and SaaS businesses exceed one of the two limits. Do not assume the exemption without checking it against your actual figures.

The mistake to avoid: « one-click accessibility » overlays

Widgets such as accessiBe or UserWay promise automatic compliance from a single line of code. They do not make you compliant. Their real effectiveness is contested by disability organisations; in the US, the FTC fined accessiBe one million dollars in 2025 over compliance claims found to be misleading. An overlay does not fix your site’s source code and does not produce the accessibility declaration French law requires — which, as we saw, is the breach worth up to €25,000 on its own.

The defensible path is the opposite: audit the site, fix what can be fixed, and publish an honest declaration documenting the actual state and the plan to close the gaps.

How to comply, in practice

1. Audit. An automated technical scan (WCAG 2.1 AA / RGAA) detects part of the non-conformities — contrast, image alternatives, structure, forms. It does not replace a full manual audit, but it establishes a factual, quantified baseline.
2. Fix the priority points — often few and inexpensive (colour contrast, form labels, keyboard operability).
3. Publish the accessibility declaration in the expected form, with an accurate conformity status and the routes of redress. In France this is the single fastest way to remove the easiest penalty from the table.
4. Keep it current: conformity degrades with every deployment. A periodic re-scan avoids drift — and, in France, avoids a six-monthly exposure quietly re-opening.

Frequently asked questions