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Who likes to go and read legal texts? Quite frankly, not me! Unfortunately, it is however a mandatory step before publishing an application, in order to comply with the legislation.

In the field of accessibility Of mobile applications, the task seems even more difficult: in France, there are no less than seven different texts to describe all the requirements! Not to mention European texts... And since most popular articles are limited to websites, it becomes complicated to find your way around!

To untangle all this, I therefore offer you a short complete tour of the laws in France for accessibility of mobile applications ! To facilitate reading, links to legal texts will be indicated at the end of the article.

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Which applications are affected by the accessibility requirement?

To find out if your application is affected by the obligation, there are in fact two cases to distinguish.

First, all your applications are concerned if you are:

A legal person under the law public [I];
a private company completing public service missions or satisfying general interest needs [I];
one private company whose turnover in France exceeds 250 million euros [I] [II];

If you are in one of these cases, then you have already been subject to the accessibility obligation since 2005 (or 2019 in the case of private companies).

Note that applications internal to a company (intranet, extranet...) are also concerned (see the Reminder of the scope of application of DINUM).

For other applications, there is no accessibility requirement today. However, new rules will apply from 28 June 2025 for products and services, following theAccessibility Act. The applications concerned will be [VII]:

The services of electronic communications (messaging, email...);
The services of audiovisual media (television, radio, streaming platform...);
applications related to transport services (air, rail, subway, bus...);
The banking services ;
The trade services online.

Note that applications published before June 28, 2025 will have until June 28, 2030 to comply [V]. In addition, small businesses employing fewer than 10 people and with a turnover of less than 2 million euros will also be exempt from these obligations [VI].

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How do I know if my application is accessible?

An application is considered to be reachable (in the legal sense) if it respects all criteria of the European standard EN 301-549 V3.2.1. Attention, do not open this link right away! The document is 186 pages long, so keep it in a corner as a last resort 😉.

To check if an application meets this standard, the easiest way is to use the Mobile Application Accessibility Assessment Framework (RAAM), published by the Government of Luxembourg. It offers a list of 107 control criteria to check if your application is compliant, with a test method for each criterion!

For the most curious, the RAAM is directly inspired by RGAA, its equivalent for websites published by the DINUM. Also note that the European standard is a transcript of WCAG, corresponding to level AA.

What are the legal obligations?

For organizations (public or private) already concerned by the accessibility obligation, reporting obligations are added to prove the good faith of the organization. Each application must then contain:

The accessibility statement [III]: it explains the test method carried out (the RAAM therefore) with its result, and contains a link to The multi-year accessibility plan of the organization (also mandatory [I]). It must also provide A means of complaint for users, and must be renewed at least every 3 years. To write it, it is recommended to use The DINUM model.
The mention of the state of compliance [I]: this mention indicates the level of compliance of the application, the objective being to achieve 100% to comply with the accessibility obligation. It should normally be displayed on each page in the case of websites, but a tolerance is granted for mobile applications: the mention may be in a menu (next to the links to the legal notices and the accessibility statement generally).

For applications subject to the accessibility requirement as services (so those concerned from 2025), the constraints are slightly different. First, in addition to the accessibility requirement, the application must meet specific obligations specific to the type of service [X], including:

for electronic communications services: have a text transcript in real time for voice communications;
for audiovisual media services: program guides accessible electronics and captioning for the deaf or hard of hearing;
for transport services: accessibility information the means of transport, accessibility of ticket offices;
for banking services: accessibility of functionalities Of identification, of electronic signature And payment services ;
for online business services: information on the accessibility of the products sold, accessibility of identification and payment functionalities.

The application must also provide a technical documentation, explaining how the service meets accessibility requirements [VIII]. Again, this documentation can be based on the RAAM.

Sanctions

In the case of applications considered to be services (from 2025), the breach of one of the obligations is sanctioned by a 5th class ticket (up to €7,500 for a company).

For public bodies and large companies, theARCOM Can pronounce a penalty of €20,000 in the event of a breach of obligations declarative [IV] (accessibility statement, multi-annual plan, or mention of the state of compliance). A period of 3 months However, it is granted to them before imposing the penalty, in order to comply.

Note that this last penalty is reduced to €2,000 for municipalities or groups of municipalities with less than 5,000 inhabitants.

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And for other digital media? (websites, TV apps...)

All digital products are affected by these laws, whether they are websites, TV applications, payment terminals, audiobooks, etc.

The main difference will be mainly in the technical evaluation method : if we have the RGAA for websites and the RAAM for mobile applications, there is no equivalent for other products and you will therefore have to refer directly to the European standard (or at the WCAG).

In the context of a software or an application, the obligations will also be limited to the technical capabilities of the host operating system.

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Conclusion

That's it, you are An expert on accessibility laws! Well almost, this article only aims to popularization, and is not intended to replace real legal expertise 😁

If you want to explore digital accessibility even more, feel free to go read or reread This article for improve the design of your app, or This one to make accessible applications with React Native !

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