The fines
Arcom, the French audiovisual and digital regulator, took over accessibility enforcement for public-sector sites in 2025. Two fines exist: €25,000 for a site with no accessibility statement, and €50,000 for a site whose statement does not match its real state or whose non-compliance is not being fixed. Both are renewable every six months while the situation lasts.
The first fine is the cheaper one to avoid and the one most sites incur: the statement is a document, it is required whatever the site's actual level, and it must say honestly where the site stands. A site at 40 % compliance with an accurate statement and a plan is in a better legal position than a site at 70 % with none.
What the standard actually asks
The RGAA, the French general accessibility framework, is the national reading of the international WCAG standard, version 4.1 today. It has 106 criteria in 13 themes: images, frames, colours, multimedia, tables, links, scripts, mandatory elements, structure, presentation, forms, navigation, consultation. Compliance is a percentage of applicable criteria met; the statement publishes it.
Most of the 106 criteria are not exotic. They ask that images have a text alternative, that colour is not the only carrier of information, that contrast is sufficient, that the page has one h1 and a heading order, that every form field has a label, that everything reachable with a mouse is reachable with a keyboard, that a screen reader can tell where it is. A site built with those in mind from the first screen passes most of them without trying; a site retrofitted passes them one ticket at a time.
The first four things
Publish the statement, even at a low level. Then fix, in this order: the keyboard, so that every page can be used without a mouse and the focus is visible; the structure, one h1, a heading outline, landmarks for the navigation and the main content, a skip link; the contrast, text on its background at 4.5:1 and interface elements at 3:1; the forms, a visible label per field and errors named in words next to the field, not in a colour.
These four are where automatic tools find most defects and where a screen-reader user is most often blocked. They are also cheap on a site whose templates are shared: fix the template, and every page is fixed.
How we build for it
Agora and m2 are built for the RGAA rather than audited into it: the shared blocks that compose every page carry the structure, the labels and the contrasts, so that an editor cannot publish a page that breaks them. Self-assessment against the 106 criteria is under way; the third-party audit and the accessibility statement are planned for the first quarter of 2027 and delivered with each client's instance.
For Eau de Paris the design system started from the same constraint: one typeface chosen for legibility, contrasts and keyboard paths checked page by page before the visual layer was even discussed. It is faster that way, and it is the only order in which it stays fixed.