Since 28 June 2025, the European Accessibility Act (EAA) has made digital accessibility mandatory for a large proportion of professional websites — not only public services, as was previously the case. In France, the transposition (Law No. 2023-171 of 9 March 2023, known as DDADUE) assigns enforcement and sanctioning powers to ARCOM, operating under a two-tier framework1:
- up to €25,000 per breach for declarative obligations (publication of the accessibility statement, multi-year plan, homepage notice, reporting mechanism);
- up to €50,000 per breach for substantive obligations (the website/service is not effectively accessible in accordance with RGAA 4.1 / WCAG 2.1 AA).
If a breach persists, a further penalty may be imposed.
The question is no longer whether accessibility applies to you, but where your website currently stands. Here are seven concrete criteria to test it quickly.
1. Full keyboard navigation
Test: put your mouse down. Navigate your website using only Tab (forward), Shift+Tab (backward), and Enter (activate).
If you cannot access all key functions — or if you visually «lose» the focus indicator — your website is not compliant.
2. Visible focus indicator
When you press Tab, the targeted element must be visually identified (border, outline, background highlight). Without this, a keyboard user or screen reader loses track of where they are on the page.
3. Correct heading hierarchy
Open your browser's inspector or use an audit extension. Check:
- A single H1 per page (the main title)
- A hierarchy of H2 → H3 → H4 with no gaps (no H2 followed directly by H4)
- No empty headings or headings containing only an image without alternative text
Screen readers use this hierarchy to navigate quickly. Poor use renders your website unreadable for visually impaired users.
4. Sufficient colour contrast
WCAG 2.1 Level AA requires:
- A minimum of 4.5:1 for normal text
- A minimum of 3:1 for large text (18pt or 14pt bold)
A tool such as the WebAIM Contrast Checker lets you test this within seconds. Light grey on a white background almost always fails — it is the most common error we encounter.
5. Text alternatives for images
Every meaningful image must have an alt attribute describing its content. Decorative images must have an explicit alt="" (not absent — explicitly empty).
Check your most strategically important pages. Hero images, service icons, partner logos: all must be correctly labelled.
6. Accessible forms
Every form field must:
- Have an associated label (
<label for>) — not merely a placeholder - Clearly indicate when it is required
- Display errors in a textual format, not through colour alone
- Allow keyboard submission
An inaccessible contact form is a closed door to a significant proportion of your visitors. Across Europe, it is estimated that nearly 100 million people — approximately 1 in 4 adults in the EU — live with some form of disability2.
7. Videos and media
Your videos must include:
- A text transcript or synchronised subtitles
- Audio description if they convey essential visual information
- Accessible playback controls (play/pause/volume operable by keyboard)
YouTube and Vimeo offer automatic captioning — but the accuracy is insufficient to meet RGAA requirements. Human review remains essential.
If you fail one or more criteria
You are not alone. The vast majority of French professional websites fail at least one of these criteria — this is what we observe in practice during our express audits. The good news: most of these issues can be remedied within a few days of technical work, provided you have a partner who knows the RGAA and can write accessible HTML.
What you must document, compliant or not
Regardless of your website's current state, you must publish an accessibility statement covering:
- Compliance level (fully, partially, or non-compliant)
- List of non-accessible content with justification
- Contact details for an accessibility lead
- Recourse channels (Défenseur des droits)
Failing to publish this statement is itself an offence.
Our services
IMACS SERVICES offers:
- A free preliminary assessment within 48 hours (12 key criteria)
- A full RGAA 4.1 audit with user testing (106 criteria)
- Technical remediation by our developers
- Drafting of your accessibility statement
- Training for your editorial teams
Request your free preliminary assessment or contact us to discuss your compliance.
Sources
Transparency note: we have removed statistics we could not publicly source (for example, «80% of websites fail») and rephrased estimates based solely on our own field experience. If you find any claim questionable, please write to us: we will correct or remove it.
Footnotes
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Law No. 2023-171 of 9 March 2023 (DDADUE) transposing Directive (EU) 2019/882 — articles relating to the accessibility of products and services (JORFTEXT000047281777, Légifrance). Designation of ARCOM as the supervisory authority for digital accessibility. The two penalty levels (€25,000 for declarative obligations, €50,000 for substantive obligations) are referenced by FIPHFP («Accessibilité numérique — Des obligations renforcées et prochainement contrôlées», fiphfp.fr), the Banque des Territoires («Accessibilité web : l'Arcom pourra imposer des sanctions allant jusqu'à 50 000 euros», banquedesterritoires.fr), and summarised by EY Société d'Avocats («Accessibilité numérique sanctions», avocats.ey.com). ↩
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Estimate of «nearly 100 million people, approximately 1 in 4 adults in the EU»: European Parliament — Policy Department, briefing November 2024 (europarl.europa.eu). The European Commission also cites an established figure of approximately 87 million people living with a disability (Strategy for the Rights of Persons with Disabilities 2021-2030, commission.europa.eu): the two estimates coexist depending on the definition of disability applied. ↩
Keywords
- EAA
- RGAA
- WCAG
- Accessibilité numérique