Digital Accessibility FAQ

What is digital accessibility?

Digital accessibility is about digital inclusion and ensuring that everyone, whether they have a disability or not, has equal access to the same information and services. It ensures that digital services like websites, apps, and devices are accessible to all users, including those in disabling situations.

For a service to be accessible, it must be:

Perceptible: Users can identify and see the information.
Operable: Users can navigate and interact with the service.
Understandable: Users can comprehend the information and interactions.
Robust: The service works reliably across various devices and assistive tools.

Who benefits from digital accessibility?

Digital accessibility benefits everyone, not just those with permanent disabilities. In France, over 12 million people are in a situation of disability, and globally, more than 15% of the population experiences some form of disability. Over the course of life, almost everyone will experience at least one temporary disabling situation. Accessibility ensures that digital services remain usable by all, regardless of circumstances.

What are the applicable standards?

Digital accessibility standards vary by country and region. Here are some key standards:

International:some text
- WCAG (Web Content Accessibility Guidelines) 2.1: Published by the W3C, these guidelines are widely recognized and serve as the basis for many national standards.
European Union:some text
- EN 301 549: The European standard for digital accessibility, applicable across all member states, often referenced by EU legislation such as the European Accessibility Act.
France:some text
- RGAA (Référentiel Général d'Amélioration de l'Accessibilité) version 4.1.2: Specific to France, providing guidelines for public websites and applications.
Other EU Member States:some text
- Germany: BITV 2.0 (Barrierefreie Informationstechnik-Verordnung): Germany’s national accessibility standard, based on WCAG, with additional local requirements.
- Italy: Legge Stanca (Law 4/2004): Italy's accessibility law, which includes digital services and is aligned with WCAG principles.
- Spain: UNE 139803: The Spanish national standard for web accessibility, aligned with WCAG 2.1.
- Sweden: E-legitimationsnämnden’s web accessibility guidelines: These are based on WCAG 2.1 but with additional requirements specific to Sweden.
- Netherlands: DigiToegankelijk: Dutch accessibility standard, closely aligned with WCAG but also includes specific requirements for public sector websites.
United States:some text
- Section 508 of the Rehabilitation Act: Mandates federal agencies to make their electronic and information technology accessible to people with disabilities.
- ADA (Americans with Disabilities Act): Though not specific to digital, courts often apply it to websites and digital services.
Canada:some text
- AODA (Accessibility for Ontarians with Disabilities Act): Provincial law in Ontario, requiring compliance with specific accessibility standards.
- Accessible Canada Act (ACA): Federal law that includes digital accessibility requirements.
United Kingdom:some text
- Equality Act 2010: Broad anti-discrimination law that covers digital accessibility.
- Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018: Implements WCAG 2.1 AA level for public sector websites and apps.
Australia:some text
- Disability Discrimination Act 1992: Though not specific to digital, it has been interpreted to require web accessibility.
- Australian Government's Digital Service Standard: Incorporates WCAG 2.1 compliance.
Japan:some text
- JIS X 8341-3: Japan's standard for web accessibility, aligned closely with WCAG.
South Korea:some text
- Korean Web Content Accessibility Guidelines (KWCAG): Local guidelines based on WCAG with additional requirements.
China:some text
- China's National Standards (GB/T 37668-2019): Similar to WCAG, focused on web accessibility.
Brazil:some text
- eMAG (Modelo de Acessibilidade em Governo Eletrônico): A model for accessibility in electronic government, largely based on WCAG.

India:some text
- GIGW (Guidelines for Indian Government Websites): Accessibility guidelines for government websites, incorporating WCAG principles.
Israel:some text
- Israeli Standard 5568: A web accessibility standard based on WCAG, with additional local requirements.

Can international or European legislation apply globally?

International standards like WCAG 2.1 can be used worldwide as best practices, but compliance is typically required within the jurisdictions where the laws are enforced. The majority of these standards are similar because they are based on the same principles, with differences often being in their specific implementation or format. For example, while the EN 301 549 standard is specifically for the European Union, it might also be used as a benchmark outside the EU. However, in France, compliance with the EN 301 549 does not exempt organizations from adhering to the RGAA. The European Accessibility Act (EAA) will apply to all businesses offering services within the EU, regardless of where they are based.

Who must comply with digital accessibility obligations?

In France, all public legal entities and certain private entities must comply with the RGAA. Starting June 28, 2025, all public and private organizations with more than 10 employees or €2M in revenue offering services in the EU must comply with the EN 301 549 standard for new digital services.

Who will be affected by the European Accessibility Act (EAA)?

The EAA, effective from June 28, 2025, will require a wide range of products and services, including digital ones, to be accessible across the EU. It applies to any organization conducting business in the EU, not just those based there. This includes e-commerce websites, digital platforms, and other ICT services. Businesses with more than 10 employees or with annual revenues exceeding €2 million will need to ensure compliance with the EN 301 549 standard.

What does compliance with the RGAA involve?

Compliance with the RGAA involves several key steps:

Pre-Audit: Conduct a pre-audit to analyze and evaluate the current state of digital accessibility. This helps identify areas that need improvement and sets a baseline for the necessary changes.
Implementation of Corrections: Make the necessary corrections to the code and content to ensure that digital services meet the required accessibility standards. This step involves updating websites, applications, and other digital platforms to comply with RGAA guidelines.
Control Audit: After implementing the corrections, conduct a control audit to verify that all changes have been properly applied and that the digital services are fully compliant with accessibility standards.
Publishing Accessibility Declarations: Once compliance is confirmed, publish accessibility declarations to communicate the accessibility status of your digital services.
Adopting a Digital Accessibility Strategy: Develop and implement a digital accessibility strategy that includes a multi-year plan over several years and annual action plans. This strategy should cover planning, budgeting, and executing actions to maintain and continuously improve accessibility over time.

What are the risks of non-compliance?

In France, ARCOM monitors and enforces digital accessibility. Non-compliant services can lead to:

Fines up to €50,000, renewable every six months.
Fines up to €25,000 for not meeting RGAA reporting requirements, such as publishing an accessibility declaration.

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What are the benefits of implementing digital accessibility?

Reaching a broader audience.
Enhancing user experience for all.
Attracting more customers by making your services accessible to a wider audience.
Providing benefits for employees and partners with disabilities, fostering an inclusive work environment.
Boosting brand reputation and CSR initiatives.
Supporting diversity and inclusion (D&I) efforts.
Complying with the Corporate Sustainability Reporting Directive (CSRD) by demonstrating commitment to social and environmental responsibility.
Reducing legal risks and potential lawsuits.
Improving SEO and digital performance.

How does digital accessibility impact CSR, D&I, and CSRD compliance?

Implementing digital accessibility shows a commitment to social responsibility, supports inclusive practices, and aligns with D&I goals by ensuring equal access to digital resources. It also contributes to meeting the requirements of the CSRD by demonstrating the organization’s commitment to sustainability and inclusivity.

How does digital accessibility apply to mobile applications?

Mobile applications are an integral part of digital accessibility. They must adhere to the same principles of being perceptible, usable, understandable, and robust. In the EU, mobile applications provided by public sector bodies must comply with the EN 301 549 standard, which is aligned with WCAG 2.1 AA. In Luxemburg, mobile applications must also adhere to the RAAM (Référentiel d'Accessibilité des Applications Mobiles), which provides specific guidelines for ensuring mobile apps are accessible to all users.

This means ensuring that mobile apps are accessible to users with disabilities, including those who rely on assistive technologies like screen readers, voice commands, and alternative input methods. Compliance with these standards not only meets legal requirements but also improves the overall user experience and inclusivity of the app.

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