Digital accessibility: obligations

In brief:

1. Digital accessibility makes a website or app usable by everyone, including people with disabilities, against verifiable technical criteria.
2. The obligation applies with no threshold to the public sector, and to many private companies offering online services to the public, microenterprises excepted.
3. An audit evaluates a sample of pages against a reference framework, producing a compliance rate.
4. An accessibility statement published on the site reports that rate and the compliance plan.

Digital accessibility covers the practices that keep a website, app or digital document usable by anyone, whatever their situation: a motor, visual, hearing or cognitive disability, but also a limited connection or older hardware. For a local authority or a public service, it is not only an inclusion goal: it is a legal obligation, backed by an audit method and a duty to publish results.

Who is subject to the digital accessibility obligation

The obligation does not weigh the same way on every organisation that publishes online services. The table below situates the main categories concerned.

For a local authority, the obligation covers all of its online communication services: the institutional website, an online procedures portal, mobile apps, and documents published online (PDFs, forms), regardless of the size of the municipality, inter-municipal body or public establishment.

What digital accessibility covers in practice

Accessible digital content follows four broad principles, shared by international frameworks and the French reference framework alike: it must be perceivable through more than one sense (alt text accompanies an image, subtitles accompany a video), operable by keyboard as well as by mouse or touch, understandable in its structure and wording, and robust against assistive technologies, notably the screen readers used by visually impaired or blind users.

These principles translate into verifiable technical criteria, not a general impression: alt text on every image that carries information, sufficient contrast between text and background, the ability to complete a form without using a mouse, or a reading order that stays coherent for assistive technologies.

The legal framework behind the obligation

In France, the obligation to make public online communication services accessible goes back to the law of 11 February 2005 on equal rights and opportunities, participation and citizenship for people with disabilities, which set the principle for the State, local authorities and public bodies. The French general framework for improving accessibility (RGAA) turns this principle into verifiable technical criteria, aligned with international web standards.

A more recent change in the law extended this obligation to many private companies that offer online services to the general public, with the exception of microenterprises: online banking, e-commerce, telecoms, passenger transport. This extension transposes a European directive on the accessibility of products and services, and brings the regime that applies to these companies closer to the one long imposed on the public sector.

How a digital accessibility audit works

A digital accessibility audit evaluates a representative sample of a site’s or app’s pages against the criteria of the reference framework in force, grouped into broad themes: images, colour and contrast, multimedia, tables, links, scripts, mandatory elements, information structure, information presentation, forms, navigation and consultation.

Each criterion is marked compliant, non-compliant, or not applicable when it concerns no content on the audited page. The audit report then computes an overall compliance rate, which places the site at one of three levels set by the method: non-compliant, partially compliant, or fully compliant. That rate is not the end of the process: it is the starting point for an action plan that schedules fixes, from the simplest (missing alt text) to the most structural (redesigning a form template).

A thorough audit requires testing pages with the tools actually used by the people concerned, notably a screen reader and keyboard-only navigation, in addition to the automated checks that only cover part of the framework’s criteria.

The accessibility statement and the compliance plan

The obligation does not stop at technical fixes: every organisation concerned must publish an accessibility statement on its site, stating the measured compliance rate, listing the content that remains inaccessible with an alternative where one exists, and displaying a way for users to report a difficulty accessing a service or piece of information.

This statement comes with a multi-year accessibility plan, which sets a trajectory over several years, and an annual action plan detailing the fixes planned for the current year. Together, these documents give public visibility on how the process is progressing, well beyond the single compliance rate measured at a given moment.

The consequences of not meeting the obligation

The absence of an accessibility statement, or a statement that is clearly incomplete, exposes the organisation concerned to a review and, where relevant, to a financial penalty from the competent authority. Beyond the regulatory risk, an online service that stays inaccessible denies some users a way to reach the service on their own, and pushes them toward channels that cost the local authority more, such as in-person reception desks or phone lines.

Digital accessibility therefore ties into a broader stake for local authorities: an online service that excludes part of its users, whether for a disability or for being distant from digital tools, only fulfils part of its public service mission.

Digital accessibility and other digital inclusion levers

Digital accessibility differs from digital illiteracy, which describes a person’s difficulty using digital tools regardless of any disability, and from the territorial digital divide, which concerns access to equipment and connectivity. The three levers complement each other rather than overlap: an accessible online service that is poorly designed for a user uncomfortable with digital tools still excludes them, just as a well-designed service remains out of reach for a user with no connection.

This complementarity also explains why local authorities’ online services sometimes plateau in usage despite accessibility efforts: a form that meets every technical criterion, but whose processing behind it stays manual, does not deliver the time saving a user expects, whatever their situation.

Frequently asked questions