Digital accessibility (RGAA) and French training organisations: are you actually covered?

Over the past few months, the same question keeps coming up in forums for people setting up a training organisation: “does my website have to comply with the RGAA?” The answer circulating online is often imprecise, torn between alarmism from providers selling accessibility audits to everyone and outright denial from those who have never heard of it. Here is what the texts actually say, and what concretely applies to a private training organisation.

What the law actually says

The obligation for digital accessibility in France originates from law n° 2005-102 of 11 February 2005 on equal rights and opportunities, which required online public communication services to be accessible to people with disabilities. This text primarily targeted government bodies, local authorities, and organisations carrying out a public service mission.

The framework was substantially broadened by ordonnance n° 2023-859 of 6 September 2023, which amends Article 47 and creates Article 47-1 of the 2005 law, supplemented by decree n° 2023-931 of 9 October 2023 on the accessibility of products and services for people with disabilities. These texts transpose the European Accessibility Act (European directive 2019/882) into French law, extending accessibility obligations to certain private-sector actors serving the general public: e-commerce, banking services, passenger transport, telecommunications, and audiovisual media.

These strengthened obligations have applied since 28 June 2025 for newly marketed products and services, with a transitional period until 28 June 2030 for services already in place at that date. The sanctions, set out in Article 47-1 and overseen by ARCOM, can reach 50,000 euros, renewable every six months in the absence of remediation — but they target public bodies, public service delegates, and large companies with revenue exceeding 250 million euros.

Is a typical training organisation actually in scope?

This is the point most marketing articles gloss over: the list of sectors explicitly covered by the European Accessibility Act (e-commerce, banking, transport, telecoms, audiovisual media) does not mention vocational training or e-learning as such. A private, independent training organisation, unconnected to the public sector and far below the 250-million-euro revenue threshold, is therefore not automatically subject to a strict legal RGAA compliance obligation under these texts.

Two situations, however, can pull an organisation into a more demanding scope:

• A public service mission link: a CFA or training organisation under agreement, attached to a local authority, a university, or a public interest group, inherits its delegating body’s accessibility obligations — obligations that in fact predate the European Accessibility Act.
• Online sales resembling e-commerce: if your enrolment and payment process amounts, strictly speaking, to concluding a B2C contract electronically, the legal analysis may move closer to the scope covered by the directive. This point remains debated and, in case of genuine doubt, deserves the opinion of a specialised lawyer rather than a quick reading of a blog article — including this one.

Why it’s worth caring about anyway

The absence of a strict legal obligation doesn’t mean there’s no reason to act. Two concrete reasons justify getting ahead of it, independent of the letter of the law.

The link to your Qualiopi indicators. Indicator 1 requires that information published for the public specify how people with disabilities can access your services. Indicator 26 requires you to mobilise the expertise, tools, and networks needed to welcome, support, or guide these audiences — a disability accessibility contact who is poorly equipped digitally struggles to fulfil this role. An auditor who finds that a visually impaired trainee can’t read your training programme online, or that an enrolment form is unusable with a keyboard alone, can reasonably question how real your disability-inclusion approach is beyond a statement of intent.

The 2030 deadline is closer than it looks. The scope of the European Accessibility Act could evolve, and several certification bodies and funders (OPCOs, France Travail) already include digital accessibility criteria in their referencing requirements. An organisation building its FOAD platform or website today has every reason to bake in good practices from the design stage rather than rebuild under pressure later.

A 2025 study published in the journal Médiations et médiatisations by researcher L. Calmelet, based on responses from 516 French education professionals, shows that the medical categorisation approach to disability and an integrative mindset remain major obstacles to deploying pedagogical accessibility practices, including through digital tools — a finding that helps explain why so many organisations treat accessibility as a box to tick rather than a practice built in from the start (study available on the Médiations et médiatisations journal site).

What to check concretely, without a full RGAA audit

A full RGAA audit, carried out under the official methodology, is a heavy technical exercise, generally out of reach for a small organisation and disproportionate given the actual legal obligation. A few simple checks cover most of the situations a trainee with a disability is likely to face:

1. Contrast and readability: does the text on your website and digital course materials stay readable for someone with mild visual impairment (sufficient contrast, adjustable font size)?
2. Keyboard navigation: can your enrolment form and learner portal be used without a mouse, for people with reduced mobility in their upper limbs?
3. Text alternatives: do the images, diagrams, and videos in your course catalogue have alt text or a transcript?
4. Screen reader compatibility: are your PDF documents (programme, agreement, welcome booklet) structured with tagged headings, or are they scanned images unreadable by a screen reader?
5. LMS platform: if you use a distance-learning tool, does it natively offer accessibility features (subtitling, keyboard control, screen reader compatibility)? The vendor’s documentation usually states its RGAA or WCAG compliance level.

Documenting these checks, even briefly, feeds both your evidence file for Indicator 26 and a common-sense approach — without the weight of a formal accessibility certification reserved for organisations actually within the strict legal scope.

How to position yourself without overreacting

Three profiles emerge among training organisations:

Profile	RGAA/EAA legal obligation	Recommended action
Public or agreement-based training organisation/CFA	Yes, as a matter of right	Full RGAA audit, published compliance statement
Large training company (revenue > €250M)	Yes, as a large company	RGAA audit, compliance before June 2030
Typical independent private training organisation	No, generally	Common-sense good practices, monitor how the scope evolves

For the vast majority of people setting up a training organisation who read this blog, the challenge isn’t launching into a costly, unnecessary RGAA certification, but treating accessibility as a quality criterion — consistent with the spirit of the Référentiel National Qualité — rather than an immediate regulatory constraint.

Take action

Building accessibility into your thinking from the moment you set up your organisation avoids a corrective scramble after a Qualiopi audit or a trainee complaint. The Kit Certif Complet provides the document templates you need to structure your evidence file for Indicators 1 and 26, including the accessibility and disability-contact section; the ebook Créer son organisme de formation en 30 jours lays out good practices from the design stage of your offering; and the full pack combines both resources to secure your compliance without unnecessary complexity.