Is my organization subject to the EAA ?

In 1 to 4 questions, you'll know if the European Accessibility Act applies to your organization, from when, and what first steps to take. Most importantly, you'll finally understand exactly what's expected of you.

What type of organization do you work for?

Who is Affected by the European Accessibility Act?

The European Accessibility Act (EAA) has applied since 28 June 2025 to any private company providing digital services to consumers, except for microenterprises (fewer than 10 employees AND less than 2 million euros in revenue). Public organizations remain subject to RGAA. Three criteria determine your status: organization type, audience served, size.

Scope of Application

The European Accessibility Act (EAA), transposed into French law by Law 2023-171, has applied since 28 June 2025 to any company providing digital services to consumers, except for microenterprises (fewer than 10 employees and less than 2 million euros in revenue).

EAA and web accessibility: what changes for your business in 2026

Public organizations remain subject to RGAA (General Framework for the Improvement of Accessibility), mandatory since 2016. The EAA extends these obligations to the private sector: e-commerce, online banking, passenger transport, audiovisual media, telecommunications, digital books. RGAA remains the French technical reference, while the European Accessibility Act harmonizes requirements at the European level.

Microenterprise: a threshold often misunderstood

The microenterprise exemption requires both conditions simultaneously: fewer than 10 employees and less than 2 million euros in revenue. An SME with 12 employees and 800,000 euros in revenue is therefore covered. A startup with 8 employees and 3 million euros in revenue also is. If you exceed either threshold, you are subject to the EAA.

Sanctions: up to 300,000 € in fines

In France, sanctions vary depending on the profile and the controlling authority. Two authorities coexist and actively monitor since June 2025: ARCOM for compliance reporting obligations, and DGCCRF for actual technical compliance.

ARCOM can impose up to 50,000 € in the public sector and 25,000 € on large companies (revenue > 250 million euros) for failures to meet reporting obligations (accessibility statement, multi-year plan, annual plan).

DGCCRF applies to private companies daily fines of up to 300,000 € and penalties (7,500 €, 15,000 € for repeat offenses) for failure to meet technical compliance requirements. The names of offenders may be published.

Frequently Asked Questions

Are B2B services really excluded from the EAA?

The EAA applies to services provided to consumers (B2C). If your business is strictly B2B, you are not directly subject to it. But beware: a B2B site with a consumer zone (public FAQ, appointment booking, request form) switches to B2C for that portion.

Is my mobile application also subject to it?

Yes. The EAA covers all digital services provided to consumers, regardless of channel: web, mobile, kiosks, vending machines. WCAG 2.1 (and soon 2.2) apply to any user interface.

Is a SME with 12 employees and small revenue really subject to it?

Yes, if one of the two thresholds is exceeded. The micro-enterprise exemption requires simultaneously fewer than 10 employees AND less than €2M in turnover. A SME with 12 employees is therefore subject even with €800,000 in turnover.

What happens if I discover now that I need to be compliant but I'm not?

Don't panic: ARCOM and DGCCRF prioritize formal notice before penalties. You generally have a few months to start a compliance plan (audit, corrections, declaration). Documenting your efforts is what really protects you.

Are RGAA and WCAG the same thing?

RGAA is the French transposition of WCAG 2.1, enriched with operational criteria (testing method, mandatory declaration, etc.). In practice: complying with RGAA is sufficient to comply with the EAA on the technical side. RGAA 5 (based on WCAG 2.2) is expected by end of 2026.