1️⃣ ANALYTICAL SUMMARY

A legal framework that makes accessibility enforceable

The decree specifies Article 47 of the 2005 law and imposes the accessibility of online public communication services — websites, mobile applications, software packages, digital urban furniture. It targets public bodies, private individuals delegated with a public service mission and private companies with at least 250 million euros in turnover (Art. 1 ; notice). The beneficiary public consists of users with disabilities, who are largely excluded today: parliamentary reports document a low compliance rate for online procedures (external context). The version as of 27/08/2026 aligns the exempted content with the deadlines of the European directive 2019/882.

Specific obligations, but a « how » referred elsewhere

In practical terms, the decree requires: compliance with harmonised European standards (Art. 1) ; the publication of an accessibility statement for the defined content (Art. 6) ; a multi-year scheme accompanied by an annual action plan and a mention of the accessibility level on the homepage ; a mechanism allowing the user to report difficulties and avenues for redress (Art. 6). It opens a valve — the « disproportionate burden » (Art. 4) — and provides for sanctions (Art. 7). A methodological point of caution: the decree does not contain the technical method; this exists in the RGAA reference framework (Art. 5). The text states what to do, not how to do it.

2️⃣ KEY POINTS OF THE DOCUMENT

Reminder : references by article (no stable pagination — see Epistemic Framework).

1️⃣ Scope and reference standard (Art. 1 ; notice)

The obligation applies to public bodies, private service delegates and private companies with at least €250 million in turnover. The services must comply with harmonised European standards (directive 2016/2102); failing that, with international standards or norms.

2️⃣ The accessibility declaration and its content (Art. 6)

Three mandatory blocks: contact details of the responsible person + link to the multiannual plan; state of compliance + list of inaccessible content with reasons and alternatives; means of reporting difficulties + avenues for appeal. The declaration is submitted to the administration via an online service.

3️⃣ The RGAA as a technical foundation (Art. 5)

An accessibility framework, jointly established by the ministers responsible for disability and digital affairs, sets the format of documents, the methodology for checking compliance and the conditions for disproportionate burden. In practice: the RGAA (version 4.1.2; v5 expected by the end of 2026 — external source).

4️⃣ Disproportionate burden and exempted content (Art. 4 and 3)

Making accessible may constitute a disproportionate burden (size/resources of the organisation; cost in relation to the expected benefit), but an accessible alternative must then be provided when reasonably possible (Art. 4). Article 3 lists exempted content (old office files, pre-recorded audio/video prior to certain dates, live, maps, third-party content, heritage). It is precisely these dates/exemptions that the version as of 27/08/2026 aligns with directive 2019/882 (decree 2026-816 — exact scope not read).

5️⃣ The sanction regime (Art. 7)

Administrative fine: €2,000 for municipalities with fewer than 5,000 inhabitants (and associated groups/institutions), €20,000 for other entities, per service. To be placed within the expanded framework of Article 47-1 (ordinance 2023-859), with control from Arcom and higher ceilings — up to €50,000 (external source). Amounts to be reconfirmed on the consolidated version.

3️⃣ ACTIONS FOR LOCAL ACTORS

1️⃣ Check your liability

Determine if the structure falls within the scope (public body, public service delegate, or company ≥ €250 million in revenue). Most public or delegated medico-social structures are concerned (Art. 1; notice).

2️⃣ Publish or update the accessibility declaration

Fill in the three sections of Article 6: state of compliance, inaccessible content + alternatives, reporting mechanism + appeal procedures. Submit it via the designated online service.

3️⃣ Maintain a multi-year plan + annual action plan

Formalise the multi-year accessibility plan and the annual action plan, and display the level of accessibility on the homepage (Art. 6; Art. 47 of the law).

4️⃣ Audit with the RGAA

Evaluate the service with RGAA 4.1.2 (106 criteria; sample of at least 15 pages according to the DINUM methodology — external source). Internal audit is possible if the framework is mastered; otherwise, a specialised provider (Art. 5).

5️⃣ Open an accessible reporting mechanism

Set up the channel allowing users to report a difficulty and clearly indicate the appeal procedures, including the possible referral to the Defender of Rights (Art. 6, 3°).

6️⃣ Document the exemptions and check the updated version

For every content not accessible due to disproportionate burden, trace the reason and provide an alternative when possible (Art. 4). Check on Légifrance the consolidated version as of 27/08/2026 for updated exemption dates (decree 2026-816).

Needs not covered by the decree: the technical method (referred to RGAA), support for implementation, and the field of cognitive disability / Easy-to-Read beyond standards. These gaps call for additional resources (below).

4️⃣ ADDITIONAL REFERENCES

Internal reference Health Practices: 

External references (guides / resources post-2024, verified URLs):

2. Digital accessibility in the public sector: obligations and best practices RGAA (RGAA-Test, Feb. 2026). Practical guide: who is concerned, audit methodology, tools. — https://rgaa-test.fr/guide/accessibilite-secteur-public

3. Digital accessibility RGAA: bring your municipality into compliance (Town Hall Live, Nov. 2025). Operational guide aimed at local authorities. — https://www.mairieendirect.fr/fr/guide/collectivite/accessibilite-numerique-rgaa-commune

Official technical reference (to be cited as the basis for implementation, versions 2019/2023): RGAA — Interministerial Directorate for Digital (DINUM):

https://accessibilite.numerique.gouv.fr/

5️⃣ FREQUENTLY ASKED QUESTIONS (FAQ)

1️⃣ Is my organisation concerned?

If it is public, delegated for a public service mission, or private with a turnover ≥ 250 M€: yes, under this decree (Art. 1). A small non-delegated association and below the thresholds is not covered by this decree; but since the European Accessibility Act (28/06/2025), certain private services to the public are concerned by another text, decree 2023-931 (external context).

2️⃣ What is the accessibility declaration and what must it contain?

It is the public document that certifies the level of accessibility. Three sections: contact details + link to the multiannual plan; state of compliance + inaccessible content and alternatives; means of reporting + avenues for appeal (Art. 6).

3️⃣ What is the multiannual plan?

A plan for making accessible spread over several years, broken down into annual action plans, the link of which is included in the declaration (Art. 6; art. 47 of the law). It allows for smoothing the burden over time.

4️⃣ What technical standard should be applied concretely?

The decree refers to a framework established by the ministers (Art. 5): the RGAA, version 4.1.2 in force (106 criteria). A version 5 is expected by the end of 2026 (external source); the work carried out under 4.1.2 remains valid.

5️⃣ What are the risks of non-compliance?

An administrative fine: €2,000 for small municipalities, €20,000 for other entities, per service (Art. 7). The regime of article 47-1 (ordinance 2023-859) provides for higher ceilings — up to €50,000 (external source). The user can also contact the Defender of Rights. Amounts to be reconfirmed on the consolidated version.

6️⃣ Can one be exempted from making content accessible?

Yes, at the title of disproportionate burden (Art. 4), assessed according to the size/resources and the cost/benefit ratio — but an accessible alternative must then be proposed when it is reasonably possible. Some content is also exempt (Art. 3), with dates updated in the version on 27/08/2026.

7️⃣ How does a user report an accessibility issue?

Through the reporting system that the organisation must make available, and according to the appeal procedures indicated in the declaration (Art. 6, 3°). As a last resort, referral to the Defender of Rights.

6️⃣ REWRITING IN EASY TO READ AND UNDERSTAND (FALC)

What this text says

• This text is a law. It is called a decree.

• It talks about websites and applications.

• It says: websites must be easy to use for people with disabilities.

• This rule is for the State, local authorities, hospitals and large companies.

What needs to be done

• Write a document that states whether the site is accessible. It is called the accessibility declaration.

• Make a plan to gradually make the site accessible.

• Provide a way for people to say when it is not working.

• To do it well, we follow a technical guide. This guide is called the RGAA.

If we do not comply with the rule

• We can pay a fine.

• The fine is 2,000 euros for small municipalities.

• The fine is 20,000 euros for others.

• A person can also complain to the Defender of Rights.

Note : amounts to be verified on the updated version.

7️⃣ CROSS-ANALYSIS — VALUES OF HEALTH PRACTICES

Literacy : the decree does not equip literacy; it imposes a technical standard (RGAA) focused on access, not on simplified understanding. No specific FALC provision.

Empowerment : limited but real lever — the user has a means to report difficulties and exercise a remedy (Art. 6, 3°).

Participation : no co-construction mechanism with disabled people is described in the text.

Community health: absent collective dimension; individual logic of access to the service online.

Ethics : equitable access is stated as an obligation; cultural or social biases are not addressed (outside the scope of the text).

Human rights: strong anchoring in equality of rights (law 2005-102) and non-discrimination by access; consistent with the Convention on the Rights of Persons with Disabilities (external context).

Intersectorality : implicit inter-ministerial coordination (disability + digital) via the common framework; no ground-level intersectorality.

Partnership : reference to a jointly established inter-ministerial framework (Art. 5) ; no formalised operational collaboration model.

Fight against discrimination: this is the very purpose of the text — to combat the digital exclusion of people with disabilities. Non-judgment and diversity in the broad sense are not thematised beyond the scope of disability.

8️⃣ EVALUATION OF THE RELIABILITY OF THE RESOURCE

Scientific relevance: official primary source (positive law), maximum normative authority. This is not a study: no empirical data or research methodology. Current status: version as of 27/08/2026 up to date on the principle, but verified indirectly (Légifrance access blocked).

Operational relevance: high on the “what” (obligations, declaration, scheme, sanctions), low on the “how” (referral to RGAA). Usable directly for a self-diagnosis of compliance, but insufficient alone for the technical implementation.

Overall appreciation: maximum normative reliability (text of law); real practical utility but conditioned on the support of the technical reference (RGAA) and, if applicable, a service provider. To be used as a reference for obligations, not as a manual.

9️⃣ STRATEGIC HASHTAGS

#DigitalAccessibility #RGAA #Disability #DigitalInclusion #UserRights #PublicService #AccessToRights #healthpractices