The reasoning fits in one sentence, and it is wrong: “the RGAA is for the public sector and large groups, so it does not apply to us”. The first half is accurate. The conclusion is not, because there is not one text but two.
Confusing the two leads a forty-person company selling online to believe it is out of scope when it came into scope on 28 June 2025.
The first regime: Article 47 and its €250 million threshold
This is the one everyone knows as the RGAA — the technical reference used to measure compliance. The obligation itself comes from Article 47 of the Act of 11 February 2005, as specified by the decree of 24 July 2019.
It covers the State, local authorities, public institutions, bodies entrusted with a public service mission — and companies whose turnover in France exceeds €250 million, assessed as a three-year average.
For a smaller business, the conclusion is the hoped-for one: this regime does not bind it. That is not where to stop reading.
The second regime: services sold to consumers
The European directive on the accessibility of products and services, transposed into French law by an ordinance of September 2023, has applied since 28 June 2025. It reasons by type of service, not by company size.
- e-commerce — so any online sale to consumers, whatever the size of the catalogue
- consumer banking services
- passenger transport, for ticketing and information
- electronic communications and audiovisual media access services
- e-books and the software that reads them
The exemption exists, but it is narrow: it covers micro-enterprises, meaning fewer than ten employees and less than €2 million in turnover or balance sheet total. A twenty-person company selling online does not qualify.
It is not company size that triggers the obligation, it is the nature of what is sold and to whom.
Who inspects, and why it matters
The distinction is little known and has practical consequences. Arcom oversees accessibility obligations for public bodies’ websites. For services under the second regime, supervision is exercised by the competition and consumer fraud authority, within its sectors of competence.
A private company following Arcom decisions to gauge whether the subject is becoming serious is therefore watching an indicator that does not concern it — and will miss its own.
What the obligation covers in practice
It is not limited to the technical quality of pages. It includes a declarative part, simpler to handle and easier to inspect — and therefore the first to be flagged:
- an accessibility statement published and reachable from the site, stating the level actually achieved
- the compliance status shown where a visitor can see it, not buried in a legal notice page
- a reporting route available to anyone who hits an obstacle, with a real person behind it
- a plan stating what will be fixed and in what order — admitting non-compliance is not the failing, having no plan is
The formal notice issued in June 2026 against the tax website bears on precisely those two strands: essential services unusable for some users, and no display of the compliance level. The second failing takes a day to fix. It had not been fixed.
What to settle before commissioning an audit
A company that does not know which regime applies to it will buy the wrong deliverable. The first regime calls for assessment against the French reference and precise declarative obligations. The second reasons in European accessibility requirements, with a product-conformity logic.
The question to ask is therefore not “are we compliant” but “what are we supposed to be compliant with”. That is a matter of legal qualification, not technical work, and it comes before any quotation.
Once the regime is identified, the assessment itself holds a surprise: a compliance score is not accessibility, and the two are easily confused.
Qualifying before commissioning holds for any regulatory obligation, not just accessibility: a GDPR audit fails in exactly the same way when the opening question is badly put.
The thresholds, scopes and amounts cited here describe the state of the texts as at 1 September 2026. A qualification you rely on is made with legal counsel, on the company’s actual situation.
Common questions
Who is covered by digital accessibility obligations?
Two regimes coexist. Article 47 of the 2005 French law covers the public sector and companies with French turnover above €250 million. The regime derived from the European directive, in force since 28 June 2025, covers certain services sold to consumers, including e-commerce, whatever the size of the business.
Must a small business selling online make its site accessible?
Yes, in most cases. Only microenterprises are exempt: fewer than ten employees and less than €2 million in turnover or balance-sheet total. A twenty-person business selling online to consumers does not qualify.
What does RGAA stand for?
RGAA is the French general accessibility improvement framework: the technical reference used to measure the compliance of sites covered by Article 47. It does not by itself sum up accessibility obligations, which also depend on the nature of the services sold.
Who enforces accessibility for private companies’ websites?
For services sold to consumers, oversight falls to the competition and consumer-fraud administration, within its areas of competence. Arcom, for its part, monitors the obligations of public bodies’ websites.