France: EAA transposition (Ordonnance 2023-859 + Decret 2023-931)
- Official name
- Ordonnance n. 2023-859 du 6 septembre 2023; Decret n. 2023-931 du 6 octobre 2023
- In force
- 28 June 2025
- Who must comply
- Operators placing covered products or services on the French market.
- Official source
- Legifrance - Ordonnance 2023-859
France transposed the EAA via Ordonnance 2023-859 (substantive rules) and Decret 2023-931 (implementing detail). Builds on the existing RGAA framework for the public sector.
What it is
France transposed the EAA in two steps:
- Ordonnance n. 2023-859 of 6 September 2023 - substantive rules covering covered products and services.
- Decret n. 2023-931 of 6 October 2023 - implementing detail, accessibility statement requirements, complaint-handling and reporting.
Both apply from 28 June 2025. They sit alongside the existing RGAA (Referentiel general d'amelioration de l'accessibilite, version 4.1+), which continues to govern the public sector and now also serves as a practical checklist for private-sector EAA compliance.
Who it applies to
The transposition applies to economic operators active on the French market: manufacturers, importers, distributors and service providers covered by the directive's catalogue. Microenterprises providing services are exempt from substantive obligations.
Consumer banking, e-commerce, e-books, electronic communications, passenger transport apps and self-service terminals are all covered.
Penalties and enforcement
Market surveillance is shared between the DGCCRF (consumer affairs and fraud control) and sector-specific regulators. Sanctions follow the existing French framework for accessibility violations:
- Administrative fines up to EUR 50,000 per service or product for repeated failure to comply
- For digital services already covered by the wider French accessibility regime, fines up to EUR 25,000 per service for missing or insufficient accessibility statements
- Court-ordered corrective measures
Standards
EN 301 549 (which references WCAG 2.1 AA) gives a presumption of conformity. The RGAA 4.1+ is the de-facto French testing methodology and is used by many auditors as the structured checklist when arguing conformance.
How EAAGuard helps
EAAGuard's scanner runs axe-core, which maps directly to WCAG rules. French-language reports are produced from the same scan data. A human auditor through the marketplace can deliver an RGAA-aligned report when your buyer or regulator asks for one.
This page summarises Ordonnance n. 2023-859 du 6 septembre 2023; Decret n. 2023-931 du 6 octobre 2023 for orientation. It is not legal advice. Always check the linked official source and consult a qualified lawyer for compliance decisions.