European Accessibility Act

France’s EAA: RGAA 4.1, Loi 2023-171, and the July 2025 Mises en Demeure

Last updated May 25, 2026

France transposed the European Accessibility Act through Loi 2023-171, which folds EAA obligations into the French Consumer Code while leaving the older disability-rights framework (Loi 2005-102, known as the Loi handicap) in place for public-sector and civil-rights questions. The operational technical reference is RGAA 4.1, the Référentiel général d’amélioration de l’accessibilité, maintained by DINUM. For ecommerce and consumer-facing services in EAA scope, supervisory authority sits primarily with the DGCCRF— the consumer protection arm of the French Ministry of the Economy. The most visible public test of the new regime so far is the July 2025 mises en demeure campaign against Auchan, Carrefour, E.Leclerc, and Picard, which escalated to emergency injunction proceedings on November 12, 2025. Crucially, those actions are private-party civil actions, not regulator-led enforcement — a distinction that changes how non-French sellers should read the signal. If you sell to French consumers from anywhere in the world and your service falls inside the EAA, you are inside France’s regime regardless of where you are headquartered. For the cross-country picture see our EAA compliance checklist.

Loi 2023-171 and the French legal stack

France’s digital-accessibility law did not start with the EAA. The foundational text is Loi 2005-102 du 11 février 2005, which established broad rights for people with disabilities. Article 47of that law imposed accessibility obligations on public-sector online services and was later extended to large private companies and public-service delegates. RGAA was created as the technical reference to make Article 47 auditable in practice.

Loi 2023-171 is the law that transposes EU Directive 2019/882 (the EAA) into French law. It works by amending the French Consumer Code rather than by creating a separate accessibility statute, which means EAA obligations sit alongside existing consumer-protection obligations and are supervised by the same authorities. In practice, you should expect three sources of rules to apply to a French consumer-facing site simultaneously: the EAA-transposed Consumer Code provisions, the older Loi 2005-102 / Article 47 regime where it overlaps, and the technical criteria of RGAA 4.1. The EAA framework is described in more depth in our EAA requirements guide.

RGAA 4.1 — France’s WCAG mapping

RGAA 4.1 is the version of the Référentiel général currently in force, maintained by DINUM (the direction interministérielle du numérique) and published at accessibilite.numerique.gouv.fr. RGAA is structured around 106 evaluation criteria split into a legal-obligations section and a technical methodology section. The criteria are aligned with WCAG 2.1 Level AA but specify French-language testing methodology, tester roles, and documentation expectations. The two important consequences for remediation work:

• If your site passes WCAG 2.1 AA, you are mostly in good shape for RGAA— but “mostly” matters. RGAA prescribes a specific audit methodology (a sampled page set, a documented test grid, a compliance percentage). A WCAG-clean audit report is not the same artefact as an RGAA audit report.
• The accessibility statement under RGAA is more structuredthan the bare EAA Annex V template. It must include the conformance level (totale / partielle / non conforme), the conformity percentage, a list of non-accessible content, and a documented contact route for users who hit blockers. We cover the statement format in the accessibility statement generator.

DINUM has signalled that an RGAA 5 is in development for publication horizon 2026, expected to track WCAG 2.2 more closely. Until then, RGAA 4.1 is the version your auditor and your supervisory authority will use.

Who enforces what

France splits accessibility supervision across several authorities depending on the kind of service. For non-French sellers worrying about EAA exposure, the practical answer is usually DGCCRF, but it is worth understanding all three:

• DGCCRF (Direction générale de la concurrence, de la consommation et de la répression des fraudes) — the consumer-protection arm of the French Ministry of the Economy. Because Loi 2023-171 attaches EAA obligations to the Consumer Code, DGCCRF is the authority that supervises ecommerce, online banking interfaces, and most consumer-facing digital services in EAA scope. This is who a French consumer who cannot use your checkout would normally complain to.
• DINUM— supervises public-sector and public-service-delegate accessibility under Article 47 / Loi 2005-102, and maintains RGAA itself. If you are not selling to the French state or operating a service of general economic interest, DINUM is not your primary supervisor, but its RGAA grid is what auditors will use against you.
• ARCOM— the regulator for audiovisual and electronic communications. ARCOM picks up accessibility for broadcast, streaming services, and elements of telecom that fall inside its remit.
• Civil-society organisations — under the French Consumer Code, accredited disability-rights associations have standing to bring civil actions on behalf of consumers. This is a parallel track to regulator enforcement, and it is the track that activated in July 2025.

The July 2025 mises en demeure— a worked example

The clearest public signal of how the new French regime is being tested comes from civil society, not from a regulator. The fact pattern, stated exactly:

Two French legal terms do most of the work in that paragraph and are worth defining for non-French readers. A mise en demeure is a formal pre-litigation notice with a stated remediation deadline; it is the standard French civil step that puts a party “on notice” before a suit is filed. An assignation en référé is an emergency injunction procedure before the tribunal judiciaire— faster than ordinary civil proceedings and aimed at obtaining a court order to stop or remedy a specific harm. The escalation from the July 7 mises en demeure to the November 12 référémeans the four retailers did not satisfy the plaintiffs’ remediation demands within the stated window. On May 5, 2026, the tribunal judiciairede Lille handed down its first decision in this group of cases — against Auchan E-Commerce specifically. The court acknowledged that the Auchan e-commerce site was not accessible (a fact Auchan did not dispute) but dismissed the action on the ground that no French statutory accessibility obligation attached to Auchan E-Commerce because the subsidiary did not exceed the €250 million revenue threshold set by French national accessibility legislation (a long-standing large-company threshold inherited from the pre-EAA Article 47 of Loi 2005-102 framework, not the EAA microenterprise rule). The ruling is widely viewed as a narrow and controversial reading of how Loi 2023-171 transposes the EAA; ApiDV, Droit Pluriel, and Intérêt à Agir have appealed to the Cour d'appel de Douai. Rulings against the other three retailers (Carrefour, E.Leclerc, Picard) are pending at the time of writing. The takeaway is procedural: France now has live EAA case law in référé, the first instance is on appeal, and the legal question of whether private-sector ecommerce sites below the €250M threshold are statutorily bound by accessibility obligations in France is unsettled until appellate guidance lands.

Non-French sellers serving France

The EAA is extraterritorial by design. Any economic operator that places covered products or services on the EU market is in scope regardless of headquarters, and Loi 2023-171 inherits that reach when those services touch French consumers. A US Shopify store shipping to French customers, a UK SaaS billing French businesses through a self-serve checkout, or an Irish-incorporated marketplace whose front-end speaks to French shoppers are all inside the regime. The threshold question is not where your company is — it is whether you are offering an EAA-covered service (ecommerce, banking, transport ticketing, etc.) to consumers located in France.

Two operational consequences follow. First, your accessibility statement should reference France as a covered market if you take French orders, and should name a supervisory authority a French consumer can escalate to (DGCCRF for ecommerce). Second, your remediation roadmap should be tracked against RGAA 4.1 criteria, not only against generic WCAG 2.1 AA — a French auditor or plaintiff’s expert will reach for the RGAA grid first.

Sanctions and remedies

France’s sanctions regime under Loi 2023-171 operates through Consumer Code mechanisms rather than a single headline fine ceiling. Public reporting and operator guidance describe enforcement in qualitative terms: administrative fines and injunctive measures imposable by DGCCRF following notice-and-cure, plus civil damages and court-ordered remediation available through private actions. We deliberately do not quote a specific maximum euro figure here because the applicable cap depends on the underlying Consumer Code article invoked and on whether the procedure is administrative (DGCCRF) or judicial (a référéor a substantive civil claim). For a comparative view of where France sits next to Germany (BFSG, €10,000–€100,000 per violation), Italy (D.Lgs. 82/2022 plus the older Stanca / DL 76/2020 stack), and Spain (Ley 11/2023, up to €1,000,000) see the country-by-country checklist.

The qualitative point worth taking seriously: a successful référé can produce a court order to remediate within a short, judicially-set deadline, with daily penalties (astreintes) attached. The leverage of the French civil system is speed and the threat of compounding daily fines, not a single headline ceiling.

The French accessibility statement requirement

France inherits the EAA Article 13 / Annex V accessibility statement requirement, with two French specifics layered on top: the statement must be published in French, and the RGAA conformance structure (conformance level, percentage, list of non-accessible content, named contact, supervisory authority escalation route) is the expected shape. The statement should live at a stable URL reachable from the site footer or an obvious accessibility link, and it should be updated when the underlying compliance posture changes. Generator and template guidance is in our accessibility statement generator.

How SweepHound supports France-EAA readiness

Honest scope statement first: SweepHound does not make your site “French-EAA compliant.” Compliance is a documented audit plus a remediation programme plus a published statement, and the last word always belongs to a human auditor and counsel. What SweepHound does is the part automation can honestly do:

• Dual-engine automated scanning that maps issues to the WCAG 2.1 AA criteria RGAA 4.1 is aligned with, so an RGAA auditor or a French plaintiff’s expert is working from the same evidence you are.
• Auto-generated accessibility statement scaffolding (English now, French planned) you can use as the starting point for your EAA Annex V publication.
• Code-level remediation hints rather than overlay band-aids — because the July 2025 cases are exactly the kind of fact pattern where an overlay defence collapses under cross-examination.

Start a free scan against your French-facing surface, or see the pricing tiers for ongoing monitoring. Sibling country guides: BFSG (Germany) and Italy (D.Lgs. 82/2022 + Stanca).