The public accessibility register: the obligation French training organisations forget
You probably know the safety register (registre de sécurité), and perhaps the log of adaptation requests kept by your disability officer. But the registre public d’accessibilité — the public accessibility register — is missing from many French training organisations, even though it has been mandatory in every establishment open to the public since 2017, small 5th-category premises included. The good news: it is one of the easiest obligations to meet, once you know what goes into it. Here is the content section by section, plus a method to draft it in half a day.
What the public accessibility register is
The public accessibility register is a document made available to the public in every ERP (établissement recevant du public, the French category for premises open to the public). It describes the services the establishment offers and how accessible they are to people with disabilities. Its purpose is informative, not administrative: it lets a visitor — for a training organisation, a learner or an applicant — know, before even travelling there, what is accessible to them and how the establishment has organised its welcome.
Two stable texts frame it: decree no. 2017-431 of 28 March 2017, which creates the obligation, and the ministerial order of 19 April 2017, which specifies its content and how it must be made available. Do not confuse it with the safety register (which logs fire-safety checks) or with the adaptation-request log kept by your disability officer (référent handicap): the three coexist and none replaces another.
Who is concerned: every ERP, including 5th category
The obligation applies to all establishments open to the public, with no headcount threshold: large category 1-4 structures as well as small 5th-category ones. As our article on ERP obligations for training premises explains, premises hosting learners are a type R ERP, and most training organisations — one or two rooms, a few dozen people at most — fall into the 5th category. If you operate dedicated premises, the register is your responsibility.
The organisation that rents a room
If you only train in occasionally rented rooms, at your clients’ sites or remotely, you operate no ERP yourself: the register for the venue is the operator’s responsibility (hotel, business centre, coworking space). That does not remove all diligence on your side. You remain responsible for choosing a room suited to your learners: ask the operator whether their public accessibility register is available, put the question of wheelchair access in writing, and keep those exchanges in the session file. That documented check is exactly the kind of evidence a Qualiopi auditor appreciates for rented rooms.
What goes into the register, section by section
The order of 19 April 2017 structures the register around simple sections. For a training organisation, here is how to fill them in practice:
| Section | What you actually put in it |
|---|---|
| Services offered | Your training services: types of courses, delivery modes (classroom, distance), associated services (reception, documentation) |
| Degree of accessibility of those services | What is accessible and to whom: approach path, room, toilets, adapted materials; any limits and the alternative solutions offered |
| Maintenance of accessibility equipment | How the lift, removable ramp, hearing induction loop or any other equipment is maintained, and how often it is checked |
| Training of reception staff | Description of awareness or training actions on welcoming people with disabilities — a formalised obligation (annual attestation) for category 1-4 ERPs; in 5th category, an information leaflet given to staff is enough |
| Administrative documents | Accessibility attestation if the premises were compliant, completion attestation of an Ad’AP (a phased accessibility works programme) if works were carried out, and any derogation orders |
Two useful clarifications. First, the degree of accessibility is assessed for all disabilities — motor, sensory, cognitive, psychological — not just wheelchair access. Second, if your premises benefit from a derogation, it must appear in the register: a derogation is documented, never presumed.
Free format: a binder at reception or a page online
The regulation imposes no format. The register can be a paper binder available at the reception point, a digital document on a tablet, or a dedicated page on your website — a relevant option for a training organisation, since it informs the learner before enrolment and fits naturally with your learner welcome booklet, which can point to it.
One caveat: publishing it online complements on-site availability, it does not replace it. The simplest approach is to do both: a paper version in the same binder as your mandatory notices, and an online version flagged on your website.
Why this obligation exists: what research shows
The register can look like just one more formality. It actually answers a well-documented finding: the ordinary built environment is not neutral for people with disabilities. A study by Rob Imrie and Marion Kumar published in 1998 in the journal Disability & Society (“Focusing on disability and access in the built environment”) shows, based on surveys of disabled people, that they remain structurally disadvantaged by the very design of the built environment, conceived for a “standard” user who does not match their reality (see the study on Google Scholar). This is precisely what led public policy to impose not only construction standards but also mandatory, public documentation of accessibility: as long as the information is not published, the person concerned carries the whole burden of finding out whether a place is usable for them.
The direct link with Qualiopi: indicators 26 and 17
The Qualiopi auditor does not check ERP compliance in place of the safety commission. But the public accessibility register directly serves two indicators:
- Indicator 26 (welcoming people with disabilities): the indicator assesses your organisational capacity to welcome, adapt or refer. An up-to-date register proves that the accessibility of your premises has been analysed, documented and communicated — valued evidence, complementary to the appointment of a disability officer and the welcome procedure. Remember the subject goes beyond premises: the accessibility of your materials and platform falls under digital accessibility and the RGAA, the French web accessibility framework.
- Indicator 17 (adequate human and technical resources): the register documents that your premises suit the audience you host, alongside your room-check sheets.
Drafting your register in half a day: the method
- Gather existing documents (30 min): accessibility attestation or Ad’AP completion attestation (ask the owner if you rent), any derogations, maintenance contracts for equipment.
- Walk the premises with a checklist (1 h): outdoor path, entrance, indoor circulation, room, toilets, signage — note what is accessible, for which type of disability, and the alternative solutions where something is not.
- Write the sections (1 h 30): follow the table above, in plain sentences readable by the public — the register is written for visitors, not for the administration.
- Add the reception-staff part (30 min): in 5th category, an information note handed to staff is enough; keep a record that it was circulated.
- Make it available and keep it alive (30 min): binder at reception, online version, mention in the welcome booklet. Update the register whenever something changes (works, new equipment, relocation).
If in doubt about a specific situation — an old derogation, unusual premises — check with the departmental territories directorate (DDT) or your town hall’s planning department rather than improvising.
Take action
The public accessibility register takes half a day to draft, but it belongs to a wider set: disability welcome procedure, evidence for indicators 17 and 26, public information documents. The Complete Kit Certif at €297 provides ready-to-customise templates for all 32 indicators, the ebook Create Your Training Organisation in 30 Days at €67 secures your administrative obligations from day one, and the Kit + Ebook Pack at €347 combines both to start on solid ground.
Frequently asked questions
+Is the public accessibility register mandatory for a small training organisation?
Yes, as soon as the organisation operates premises open to the public: decree no. 2017-431 of 28 March 2017 covers every ERP (établissement recevant du public), including the small 5th-category establishments most training rooms fall into. However, an organisation with no premises of its own (on-site client training, distance learning, occasionally rented rooms) does not keep a register itself: that duty sits with the venue operator.
+Who keeps the register when a training organisation rents a room?
The venue operator (hotel, business centre, coworking space): they run the ERP and must make the register available to the public. The training organisation must still check that the room is accessible to its learners and keep a record of that check — a written question to the operator and their answer is often enough — because it remains answerable for the suitability of the room to its clients and to the Qualiopi auditor.
+What format should the public accessibility register take?
The format is free: a paper binder available at reception, a PDF, or a dedicated page on your website. What matters is that it is genuinely made available to the public at the establishment's reception point and that it contains the sections set out by the order of 19 April 2017: services offered, degree of accessibility, equipment maintenance and administrative documents.
+Does the public accessibility register count as evidence in a Qualiopi audit?
Yes, and auditors value it. It does not replace the disability welcome procedure required by indicator 26, but it complements it by showing that the accessibility of your premises is documented and communicated to the public. It also supports indicator 17, which covers the adequacy of your technical resources for your services.