Since summer 2025, the same question keeps coming up among shop owners and independents with a website: “Do I have to make my site accessible?” You read everything and its opposite, between those who claim everyone is concerned and those who think it only targets large companies. The reality is more precise, and it comes down to three questions: what kind of service do you offer online, how big is your business, and who do you sell to.
This article goes through the legal texts and the practical guide published by France Num, the French State service dedicated to the digital transformation of small businesses, to answer without approximation.
Where this obligation comes from
It stems from EU Directive 2019/882 of 17 April 2019 on the accessibility requirements for products and services, often called the “European Accessibility Act”. In France, it was transposed by article 16 of Law no. 2023-171 of 9 March 2023, which created article L412-13 of the French Consumer Code, then detailed by Decree no. 2023-931 and the order of 9 October 2023 setting out the accessibility requirements. These provisions apply to products placed on the market and services provided from 28 June 2025.
Article L412-13 sets out the principle: economic operators provide services that comply with the accessibility requirements set by order, with a decree listing the products and services concerned. The services covered by the directive include e-commerce services, consumer banking services, e-books, certain elements of passenger transport services and electronic communications services.
For the vast majority of small businesses with a website, e-commerce is what matters. That is what the rest of this article covers.
What is an “e-commerce service”?
France Num recalls the definition: services provided electronically at the individual request of a consumer, with a view to concluding a consumer contract. And it specifies that there is an e-commerce service as soon as a transaction (purchase of goods or services) is initiated, negotiated or concluded electronically at a distance. The contract may cover physical goods or services, through a website or an app.
Three practical consequences:
- An online store selling to private individuals is clearly covered: catalogue, basket, payment, customer account.
- A service that can be booked or paid for online (service, subscription, ticketing) also falls within the definition, since the contract is concluded remotely and electronically.
- A purely showcase site, which presents a business without allowing people to order, book or pay, does not conclude contracts online and therefore does not meet this definition. Be careful with in-between cases: the definition also covers a transaction merely “initiated” or “negotiated” online. If your site lets people start an order or booking, even if it is completed another way, take the subject seriously.
The text targets services aimed at consumers. A site that only sells to businesses is outside the scope of this obligation.
The micro-enterprise exemption: the exact thresholds
This is the most important point for small businesses. Article L412-13 exempts micro-enterprises providing services from the accessibility requirements and all related obligations. It covers businesses that employ fewer than ten people and whose annual turnover does not exceed two million euros or whose annual balance sheet total does not exceed two million euros.
How you read this matters: the headcount condition and the financial condition are cumulative (you need both), but the financial condition is alternative (turnover or balance sheet total). A few examples:
- An online store with 3 employees and €400,000 turnover: fewer than 10 people and under 2 million, so it is exempt.
- An online retailer with 8 people, €2.5 million turnover but a €1.2 million balance sheet total: fewer than 10 people, and the balance sheet total does not exceed 2 million. It therefore meets the financial condition, since it is alternative, and it is exempt.
- A retailer with 15 employees, whatever its turnover: it exceeds the headcount threshold and is not exempt.
This exemption covers micro-enterprises that provide services. Products (terminals, e-readers, vending machines and so on) follow other rules, which rarely concern the retailers we are discussing here.
According to France Num, those covered are therefore large companies, mid-sized companies and SMEs with more than 10 employees whose turnover or balance sheet total exceeds 2 million euros, as long as they run e-commerce services for consumers.
Not to be confused with article 47 of the 2005 law
Another, older scheme exists: article 47 of Law no. 2005-102 of 11 February 2005, detailed by Decree no. 2019-768 of 24 July 2019, requires online public communication services to be accessible for public bodies and for private companies above a threshold of 250 million euros in turnover. It does not concern small businesses and should not be confused with the 2025 obligation.
What “accessible” means in practice
France Num sums up the expected qualities in four words, which echo the main principles of international web accessibility guidelines. The content and features of an online store must be:
- Perceivable: easy-to-read text, characters that can be enlarged, sufficient colour contrast, subtitled videos.
- Operable: options that are easy to select, enough time to fill in a form without having to start over.
- Understandable: technical terms explained, acronyms spelled out, clear confirmation and error messages.
- Robust: code that follows best practice, correctly interpreted by all browsers and assistive technologies (screen readers, braille displays).
And the whole purchase journey is concerned, not just the home page. France Num lists navigation, the catalogue, the customer account, the basket, payment methods, order confirmation and online after-sales service. A site with perfect product pages but a checkout that cannot be used with a keyboard is not accessible.
The three obligations, step by step
1. Make the service accessible
This is the main obligation. France Num recommends starting with a quick diagnosis, requiring no particular expertise, before commissioning a full audit against a standard such as the RGAA, the general accessibility improvement framework used in France. For design and development, the best approach is to build accessibility in from the start rather than fixing it afterwards: it costs far less.
2. Inform consumers
The business must inform consumers about the accessibility compliance of its service. There is no mandatory template. According to France Num, this can take the form of an “Accessibility information” page covering the items listed in the annex to article D412-57 of the Consumer Code:
- a general description of the e-commerce service;
- the standard used to check accessibility;
- a statement that the site complies, and any exceptions;
- the list of derogations and exemptions relied on, with the alternatives offered;
- a contact method in case of difficulty using the service.
France Num advises offering at least two contact methods (message and phone), and points out that a site not yet compliant can already publish this page to explain how to reach the business and what work is under way.
3. Report non-compliance to the DGCCRF
This is the least known obligation. Under article D412-57 of the Consumer Code, when a service does not comply with the accessibility requirements, the provider must immediately inform the supervisory authorities, specifying in particular the non-compliance and any corrective measures taken. France Num points to a dedicated online procedure with the DGCCRF, the French consumer protection authority.
The two possible derogations
Article L412-13 provides that the requirements only apply to the extent that compliance:
- does not require a significant change to the service resulting in a fundamental alteration of its nature;
- does not impose a disproportionate burden on the operator, assessed against criteria set by decree (annex to article D412-60 of the Consumer Code).
These derogations are not automatic: the business must assess its situation, document that assessment and inform the DGCCRF, which can check it during inspections. Two important limits: an operator receiving external funding intended to improve accessibility cannot rely on disproportionate burden for that service, and France Num warns that this derogation is hard to obtain for a service launched after 28 June 2025, since any new service must build in accessibility from the design stage.
Inspections and penalties
Inspections are carried out by DGCCRF investigators in the local departmental services. According to France Num, breaches can be punished as fifth-class petty offences: 1,500 euros for a natural person (3,000 euros for a repeat offence) and 7,500 euros for a legal person (15,000 euros for a repeat offence). These fines are cumulative per e-commerce service and per obligation.
The DGCCRF also has administrative enforcement powers: it can order the business to bring its services into compliance within a set time, under penalty of daily fines. Finally, penalties and the nature of the breaches can be made public.
The most common questions
My site existed before 28 June 2025: am I covered?
The text covers services provided from 28 June 2025, not only sites created after that date. An online store still running today is therefore providing a service subject to the obligation, if the business is not a micro-enterprise. The difference mainly concerns the disproportionate burden derogation, which France Num considers hard to obtain for a service launched after that date.
Is my mobile app covered?
Yes, if it allows a contract to be concluded with a consumer. France Num specifies that e-commerce services can be accessed through websites or built into mobile devices.
I only sell to businesses
The obligation covers e-commerce services aimed at consumers. A site reserved exclusively for businesses falls outside its scope.
Who is responsible: me or my web provider?
The Consumer Code places the obligation on the economic operator providing the service, meaning the business that sells. So you are the one answerable to the DGCCRF for compliance. Hence the value of specifying, in your contract with your provider, the expected level of accessibility and the standard used to check it.
Is an information page enough?
No. That page is one of the obligations, but it does not replace making the service accessible. Publishing a page claiming the site complies when it does not would even be counterproductive during an inspection.
Where to start, even on a small budget
If you are covered, here is a sensible order of work. If you are exempt, the same points remain good practice that benefits all your customers:
- Check whether you are covered: headcount, turnover or balance sheet total, and the nature of your site (online sales or bookings for consumers, or a simple showcase).
- Run a quick diagnosis with the flash diagnostic tool provided by the French State on design.numerique.gouv.fr.
- Fix the purchase journey first: that is where a blocker actually stops someone from becoming a customer.
- Address the most common issues: sufficient contrast, alternative text for images that carry information, full keyboard navigation, properly labelled form fields, explicit error messages, and text that can be enlarged without breaking the page.
- Publish your accessibility information page, even while work is ongoing, with two contact methods.
- Document what has been done, what remains, and where applicable the assessment justifying a derogation.
Why care even if you are exempt
France Num stresses that, beyond the legal obligation, an accessible site reaches all potential customers, and these qualities benefit all users, well beyond people with disabilities. Contrast that stays readable in sunlight on a phone, a form that does not wipe itself at the slightest mistake, buttons large enough for a thumb: these are exactly the details that get a visitor to the end of their order.
There is also a timing argument. A micro-enterprise that grows may cross the thresholds: a site designed to be accessible from the start avoids a redesign on the day the exemption no longer applies.
Launching an online store or wondering whether yours is affected? Let's talk.
Sources
- Accessibility of e-commerce sites: what obligations for people with disabilities? (France Num, updated 17 December 2025, in French)
- French Consumer Code, article L412-13 (Légifrance, in French)
- French Consumer Code, articles D412-49 to D412-62 (Légifrance, in French)
- Law no. 2023-171 of 9 March 2023, article 16 (Légifrance, in French)
- Law no. 2005-102 of 11 February 2005, article 47 (Légifrance, in French)
- Directive (EU) 2019/882 of 17 April 2019 (EUR-Lex)
