Over the past few years, we have seen increasing legislative and regulatory activity around the globe on the issue of digital accessibility. Most recently, the French government issued a new law and corresponding technical order (known as the General Accessibility Reference for Administrations, or RGAA) last year that impose a broad range of accessibility obligations on businesses earning more than €250 million in annual revenue in France (as averaged over the prior three years). The RGAA requires covered businesses to make websites, mobile apps, and other online services that have been localized for France accessible to people with disabilities. Specifically, these online services must comply with the Web Content Accessibility Guidelines version 2.1, Levels A and AA, or ETSI/EN 301 549 v.2.1.2 (2018-08). In addition to meeting this accessibility requirement, covered businesses must satisfy a number of other testing, notification, training, and documentation requirements. Websites created on or after October 1, 2019, are already subject to the RGAA, but websites created before October 1, 2019, will need to be compliant by October 1, 2020, and compliance obligations will become effective for mobile apps, software, and other online services on July 1, 2021.
