Accessibility statement: who needs one

Who must publish one

Across the EU, Directive (EU) 2016/2102 requires a statement from public sector bodies. France goes further: Article 47 of the law of February 11, 2005 extends it to large companies. The official RGAA site lists the organizations covered:

• public law entities: the State, local authorities, public institutions;
• private organizations that carry out a public service mission, or that were set up for a public-interest need and are mostly funded or controlled by public bodies;
• companies whose average annual turnover in France, over the last three financial years, reaches 250 million euros.

Nonprofits are exempt when they provide neither essential services to the public nor services intended for people with disabilities.

The European Accessibility Act asks something different of websites that sell to consumers: describing the accessibility of their service in their terms and conditions or in an equivalent document. A company above the Article 47 threshold that sells online falls under both texts.

What goes in it

In France, the content follows the official RGAA model:

• the conformance status: fully compliant if every RGAA criterion is met, partially compliant from 50%, not compliant below that or when no valid audit exists;
• the percentage of criteria met, taken from an audit carried out in house or by an outside firm;
• the list of content that is not accessible, separating failures, exceptions for disproportionate burden and exempt content;
• a way to report a problem or ask for content in another form, by email or through a form;
• the right to refer the matter to the Défenseur des droits, the French rights ombudsman, when a report gets no satisfactory answer;
• the date it was drawn up, the pages checked and the test environment.

The statement is updated after a redesign or a substantial change to the site, and at the latest three years after publication. Organizations that apply the RGAA method also review it within 18 months of a new version of the standard. Version 5 is announced for late 2026.

It comes with a multi-year accessibility plan, covering three years at most, and the action plan for the current year.

Where to link it

The home page displays a notice headed "Accessibilité", followed by "totalement conforme", "partiellement conforme" or "non conforme" (fully, partially or not compliant). The standard also requires an "Accessibilité" page, reachable from the home page and from any other page: in practice, a footer link next to the legal notice. It holds the statement, the multi-year plan and the action plan, or links to them.

The footer, shared by every page, meets both conditions at once.

What the audit looks at, and why

The audit looks for the statement on the pages it crawls, starting with the conformance notice, which the model requires word for word. That notice is what sets a statement apart from a page simply titled "Accessibility".

An accessibility page that does not state a conformance status is not enough to conclude. The report flags it as unverifiable: neither presented as compliant nor counted as missing.

A missing statement is only recorded once the duty is established. The audit infers it from public information about your company, such as its legal status and headcount. When that information cannot settle the question, which happens when turnover is not published, the report says the point remains to be confirmed and deducts nothing.

A missing statement counts under compliance, not under accessibility. A highly accessible site can forget it, and a poorly accessible site that declares itself "not compliant" meets that duty.

What can be published quickly, and what needs an audit

A "not compliant" statement can be published right away: the model provides for that case when no valid audit exists. Publishing the page, the notice and the contact method does not touch the rest of the site.

Claiming "partially" or "fully compliant" requires a conformance audit, criterion by criterion, on a sample of pages. Raising that percentage is a project: fix the barriers, then run the assessment again.

What this check doesn't tell you

By Quentin Mathis, Z29K · updated September 28, 2026