Website Digital Accessibility: What the Law Requires From Businesses in 2026

Since June 28, 2025, digital accessibility is no longer a public-sector-only requirement. With the entry into application of the European Accessibility Act (EAA) in France, tens of thousands of private companies, including small and medium-sized businesses, must now make their website accessible to people with disabilities. According to estimates by the DINUM (France's interministerial digital directorate), between 200,000 and 300,000 French companies are affected by this obligation. The question is whether your business is one of them, what the law actually requires, and where to start without a disproportionate budget. That is what this guide covers.

Who is actually concerned by the accessibility obligation?

The reference text is the decree of October 9, 2023, which transposes the European Accessibility Act into French law and which entered into application on June 28, 2025. It broadens the scope of the RGAA (France's general reference framework for digital accessibility), previously focused on the public sector, to a large part of the private sector.

Companies now concerned include those selling certain digital products and services: e-commerce sites, online banking and insurance, transport, telecommunications, e-books, and self-service terminals. An exemption threshold does exist: micro-businesses with fewer than 10 employees and under 2 million euros in annual revenue are not subject to the obligation, unless your sector already requires accessibility for other reasons (a public tender, a large client's specifications, and so on).

Showcase site or e-commerce site: the distinction matters

A simple showcase website, with no online sales or booking, does not strictly fall within the most demanding scope of the EAA. However, as soon as a site offers a transactional feature (a shopping cart, payment, booking, or a client portal), it moves into the scope of covered services. Many professional practices that added an online booking or payment module have found themselves covered without having anticipated it. If you are unsure of your situation, talking to a specialized agency quickly clarifies your scope of obligation before you invest in unnecessary fixes.

The RGAA, the technical reference framework

The version currently in force, RGAA 4.1, translates the international WCAG 2.1 standards into 106 verifiable success criteria spread across 13 themes: color and contrast, page structure, keyboard navigation, forms, multimedia, and screen reader compatibility. This framework is just as useful for evaluating an existing site as it is for framing a website creation project from the design stage onward, which always costs less than fixing issues after the fact.

One technical point is worth knowing before starting an audit: according to data published by RGAAudit, an automated audit only detects around 62% of the criteria, with the remaining 38% requiring manual verification by an expert (actual keyboard navigation, consistency of alt text, reading order for screen readers). A simple online scanning tool is therefore never enough to establish reliable compliance.

What you risk in case of non-compliance

Controls began in late 2025, and the first sanctions were issued in 2026. Two sanction regimes coexist:

• For an RGAA breach, France's media regulator Arcom can impose a fine of up to €50,000 per non-compliant service, in case of persistent non-compliance after formal notice.
• For a breach of the European Accessibility Act, the fine can reach up to €300,000, or a daily penalty of €3,000 per day of delay.

Beyond the financial risk, an inaccessible site closes the door to a significant share of your visitors and potential customers, with a direct impact on your image and conversion rate. It is also increasingly scrutinized in public tenders and large clients' specifications.

The four-step method for bringing your site into compliance

1. Self-assessment: am I concerned, and to what extent?

Before any paid audit, start by answering three questions: do your headcount and revenue exceed the exemption threshold? Does your site offer a transactional feature (sales, booking, payment, client portal)? Does your sector appear on the list of services covered by the EAA? This first filter often helps prioritize effort on the sites that are genuinely at risk, rather than treating everything at once.

2. The RGAA audit: automated, then manual

A thorough audit combines an automated scan (fast, to catch obvious contrast or HTML structure errors) with a manual review by an expert, notably on keyboard navigation and screen reader compatibility. The outcome should be a list of non-conformities ranked by theme and severity, not a single overall score.

3. Prioritizing by cost and impact

Not all fixes are equal. Color contrast, image alt text, and form field labeling are generally inexpensive to fix and have an immediate impact. Reworking keyboard navigation or restructuring an entire page template requires more development work. Ranking non-conformities on this dual grid (cost of fixing, impact for the user) lets you move forward in realistic stages rather than aiming for 100% compliance in the first quarter, a goal that is rarely achievable for a small or medium-sized business.

4. The accessibility statement and ongoing monitoring

The law requires the publication of an accessibility statement, indicating the level of compliance achieved (full, partial, or non-compliant), the content that remains inaccessible, and a way to report a difficulty. This statement must be updated with every significant change to the site, which means accessibility needs to become part of your ongoing site maintenance and evolution process, not just a one-off audit.

The timeline to know through 2030

For digital products and services launched after June 28, 2025, compliance is required immediately. For sites and services already commercialized before that date, a transition period runs until June 28, 2030. That deadline should not be seen as a reason to wait: since controls have already started, companies that act early limit both their risk of sanction and the cost of a compliance effort carried out under pressure. This is especially true if a site redesign is already on the agenda for other reasons: it is the ideal moment to build accessibility in from the start, rather than treating it as a separate project.

Building accessibility into a redesign or creation project

The good news is that most RGAA criteria overlap with the best practices already recommended for performance and search engine optimization: a clear heading structure, controlled load times, well-labeled forms. A site designed to be accessible from the graphic design mockups stage onward costs noticeably less to fix than an existing site audited after the fact. If you are preparing a redesign, it is worth checking the state of your site before you start: our article on auditing a site before a redesign details the method to follow, as does our guide to preparing a redesign without losing your organic search rankings. E-commerce sites, particularly exposed by the EAA, should also revisit the fundamentals covered in our article on the anatomy of an e-commerce site that sells. And because load speed and technical accessibility share many common criteria, our analysis of load speed as a ranking factor usefully complements this approach. You can see examples of projects built on these principles in our portfolio.

Frequently Asked Questions

Is my company concerned if I do not have an online store?

If your site is a showcase site with no transactional feature (no sales, payment, or online booking), it does not fall within the strictest scope of the European Accessibility Act. Stay alert, however, if your sector or clients require accessibility for other reasons, and reassess your situation if you later add a transactional feature.

What does a small business below the exemption threshold risk?

Below 10 employees and 2 million euros in annual revenue, a company is exempt from the legal obligation, unless a sector-specific rule says otherwise. Making your site more accessible remains advisable regardless: it broadens your potential audience and generally improves the experience for all visitors, including on mobile.

How long does RGAA compliance take?

It depends on the site's starting state and the number of non-conformities found. Low-cost fixes (contrast, alt text, form labeling) can typically be handled within a few weeks. Heavier structural fixes, such as keyboard navigation on a complex site, take longer and are often more efficiently handled as part of a broader redesign project.

Do I need to rebuild my entire site to be accessible?

No. A progressive compliance approach, prioritized by impact and cost, is the method recommended by most experts in the field. A full rebuild is only justified if the site has other limitations (technical, design, performance) that make a complete overhaul more relevant than a targeted fix.

Is the accessibility statement mandatory even with partial non-compliance?

Yes. The statement must be published regardless of the level of compliance achieved: full, partial, or non-compliant. It must specify the inaccessible content, the reasons where relevant, and a way for users to report a difficulty they encounter.