Decision of 24 June 2026 giving formal notice to the Ministry of Public Action and Accounts

Published on 06 July 2026 | Assemblée plénière 24 June 2026

  • Formal notice
  • Accessibility
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The French regulatory authority for audiovisual and digital communication,

Having regard to Act No. 2005-102 of 11 February 2005 on equal rights and opportunities, participation and citizenship for people with disabilities, in particular Articles 47 and 47-1 thereof;

Having regard to Decree No. 2019-768 of 24 July 2019 on the accessibility of online public communication services for people with disabilities, in particular Articles 1, 5 and 6 thereof;

Having regard to the Order of 20 September 2019 establishing general guidelines for improving accessibility;

Having regard to the letters of 4 March 2024, 19 November 2024, 28 March 2025, 21 October 2025 and 19 January 2026 from the French regulatory authority for audiovisual and digital communication to the Directorate-General for Public Finance;

Having regard to the letters of 16 July 2024, 7 March 2025, 11 December 2025 and 6 May 2026 from the Directorate-General for Public Finance to the French regulatory authority for audiovisual and digital communication;

Having regard to the statements of offence drawn up by the authorised and sworn agents of the French regulatory authority for audiovisual and digital communication on 30 April and 2 June 2026;

Whereas :

On the legal framework

  1. Firstly, Article 47 of Law No. 2005-102 of 11 February 2005 provides that: “I. – The following organisations’ online public communication services shall be accessible to persons with disabilities under the conditions set out in this Article, and in accordance with the accessibility requirements laid down by the Decree of the Council of State referred to in V: 1° Artificial persons governed by public law[..]”.

    II.— The accessibility of online public communication services concerns access to all types of information in digital form, regardless of the means of access, the content or the method of browsing, in particular websites, intranets, extranets, mobile applications, software packages and digital street furniture, insofar as they relate to their application and interactive features. It shall be implemented provided that it does not impose a disproportionate burden on the organisation concerned. A disproportionate burden is defined by decree of the Council of State, following the opinion of the council referred to in Article L. 146-1 of the Social Action and Families Code.

    III.— The persons referred to in I shall publish an accessibility statement and draw up a multi-annual plan for making their online public communication services accessible; this plan shall be made public and broken down into annual action plans, the duration of which may not exceed three years.

    IV.— The home page of any online public communication service shall include a clearly visible statement specifying whether or not it complies with the rules on accessibility. All such online public communication services shall provide easy and direct access to the accessibility statement, the multi-annual accessibility plan and the action plan for the current year, and shall enable users to easily report breaches of the accessibility rules for that service. […].”

  2. Secondly, Article 47-1 of Law No. 2005-102 of 11 February 2005 provides that: “I . —The French regulatory authority for audiovisual and digital communication may, under the conditions set out in paragraph 2 of section I of Article 19 of Law No. 86-1067 of 30 September 1986 on freedom of communication, initiate investigations and draw up statements of offence to establish: 1° Any breaches by the persons referred to in points 1° to 3° of I of Article 47 of the provisions of I, III and IV of that article […] .

    II.— The French regulatory authority for audiovisual and digital communication shall, on the one hand, issue a formal notice to the persons referred to in paragraph 1 of this Section I to comply with the obligations set out in Sections I, III and IV of Article 47 […] within a period it shall specify. It shall publish these formal notices […]. ’

  3. Thirdly, Article 1 of Decree No. 2019-2768 of 24 July 2019 provides that “The online public communication services of the persons referred to in points 1 to 4 of Section I of Article 47 of the aforementioned Act of 11 February 2005 shall be accessible to persons with disabilities in accordance with the harmonised norms published in the Official Journal of theEuropean Union under the conditions laid down in Article 6 of Directive (EU) 2016/2102 of the European Parliament and of the Council of 26 October 2016 on the accessibility of websites and mobile applications of public sector bodies. In the absence of such harmonised norms applicable to certain types of online public communication services, the aforementioned persons shall refer to international norms or, failing that, to the applicable international norms. […].’

  4. Fourthly, Article 5 of the same decree provides that “An accessibility framework, adopted jointly by the Minister responsible for people with disabilities and the Minister responsible for digital affairs, shall lay down the technical arrangements for ensuring accessibility for people with disabilities to online public communication services. It shall specify, in particular:

    1° The format and the information that must be contained in the documents referred to in Section III of Article 47 of the aforementioned Act of 11 February 2005, as well as the accessibility notice displayed on the home page as provided for in Section IV of the same article;

    2° The procedures for implementing the criteria relating to disproportionate burden as defined in Article 4 of this Decree;

    3° The technical methodology for verifying the compliance of services with the norms referred to in Article 1 of this Decree.”

  5. Fifthly, Article 6 of the same decree provides that “I. The persons referred to in points 1° to 4° of Section I of Article 47 of the aforementioned Act of 11 February 2005 shall certify the level ofaccessibility of their communication services by publishing online the accessibility statement provided for in III of that article, in accordance with the procedures set out in the accessibility guidelines referred to in Article 5 of this Decree.

    II. – The accessibility statement shall include, in particular, the following information:

    1° The contact details of the person responsible for the publication, the name of the online service, and the link to the multi-annual accessibility implementation plan made provision for in Article 47(III) referred to above;

    2° The status of the online public communication service in relation to the accessibility requirement set out in Article 1 of this Decree, the assessment findings of the body certifying compliance with accessibility requirements and a list of inaccessible content, accompanied by the reasons for non-compliance with accessibility requirements and, where appropriate, details of accessible alternatives;

    3° The means made available to users of the online public communication service to report any accessibility-related difficulties encountered to the person responsible for that service, as well as the applicable remedies .”

  6. Sixthly, the Order of 20 September 2019 establishing the General Framework for Improving Accessibility (RGAA) makes provision for Article 1 to state that “The accessibility framework, adopted jointly by the Minister responsible for people with disabilities and the Minister responsible for digital affairs, referred to in Article 5 of the aforementioned Decree of 24 July 2019, can be browsed on the website: https://www.numerique.gouv.fr/.”

  7. Seventhly, point 1.6.1 of the RGAA makes provision for the accessibility statement to be the result of an effective assessment of the compliance of the online public communication service with the reference standard. The accessibility statement comprises: a compliance status: Full compliance: if all the RGAA’s assessment criteria are met; Partial compliance: if at least 50 per cent of the RGAA’s assessment criteria are met; Non-compliance: if there is no valid audit result available to assess compliance with the criteria, or if fewer than 50 per cent of the RGAA’s assessment criteria are met […] ”. It is also made provision for in section 1.6.1 of the RGAA that ‘the declaration must be in [the] format’ set out in that same section 1.6.1.

  8. Eighthly, section 1.6.2 of the RGAA states that “The accessibility statement is valid as of its date of publication. It must be updated: on the date of any substantial modification or overhaul of the website concerned. three years after the date of publication of the statement, or 18 months after the date of publication of a new version of the guidelines, for those applying the technical method ”.

  9. Ninthly, section 2.1 of the RGAA states that “The RGAA’s technical method makes it possible to verify that a web page – that is to say, any HTML content (HTML4, XHTML1 and HTML5) – complies with the 50 success criteria for Levels A and AA of the international WCAG 2.1 norm, which have been adopted in the European reference norm to establish the level of legal requirements regarding digital accessibility. The RGAA’s technical method provides an operational framework for verifying compliance with accessibility requirements. It comprises 106 RGAA test criteria, each involving an average of 2.5 tests. Some tests list implementation techniques (HTML, CSS, JavaScript, etc.) to verify that the criterion is met, in order to reduce the scope for interpretation regarding compliance with accessibility norms.”

  10. Tenthly, criterion 5.7 of the RGAA makes provision for ‘for each data table, the appropriate technique for linking each cell to its headers is […] used (except in specific cases).’

  11. Eleventhly, criterion 10.8 of the RGAA requires verification that “For each web page, hidden content is […] intended to be ignored by assistive technologies ”.

  12. Twelfthly, criterion 12.11 of the RGAA states that “On every web page, additional content that appears on hover, when focus is gained or when an interface component is activated is […] accessible via the keyboard where necessary ”.

  13. Thirteenthly, criterion 13.3 of the RGAA makes provision for “on every web page, every document downloaded for downloading must have […] an accessible version ”. Test 13.3.1 made provision for in the RGAA, which is used to verify compliance with this criterion, requires that one of the following conditions be met: either ‘the document for downloading is accessible’, or ‘an alternative version for downloading that is accessible is available’, or ‘an alternative version in HTML format that is accessible is available ’.

Regarding correspondence

  1. In a letter dated 4 March 2024, the Authority drew the attention of the Directorate-General for Public Finances – in its capacity as a government department and an artificial person under public law – to its obligations regarding digital accessibility in relation to the online public communication service www.impots.gouv.fr. In a letter dated 16 July 2024, the Directorate-General for Public Finance outlined the corrective measures taken to bring the aforementioned service into compliance.

  1. On 19 November 2024, the Authority sent a letter to the Directorate-General for Public Finance highlighting, with regard to the authentication page for the professional section of the same service, the absence of a link to the page dedicated to digital accessibility and the presence of a CAPTCHA that did not offer a non-graphical alternative, demanding that it be informed, within two months, of the measures taken to remedy the identified shortcomings. By letter dated 7 March 2025, the Directorate-General for Public Finance informed the Authority of the corrective measures taken and a timetable for their implementation, namely, on the one hand, the introduction of an audio CAPTCHA in the third quarter of 2025, and, secondly, the addition of a link relating to digital accessibility between autumn 2025 and spring 2026. In a letter dated 28 March 2025, the Authority took note of the announced corrective measures and drew the Directorate-General for Public Finance’s attention to the very high expectations of the relevant public regarding the accessibility of its online public communication services.

  1. In a letter dated 21 October 2025, the Authority highlighted the following shortcomings: the continued absence of a non-graphical alternative to the CAPTCHA; the inability to enter the security code on the login page for the personal account using tab browsing; and the inaccessibility of the drop-down menu for the messaging service, downloadable documents and the online tax return process. The Authority warned the Directorate-General for Public Finance against allowing these issues to persist. By letter dated 11 December 2025, the Directorate-General for Public Finance informed the Authority of the corrective measures undertaken, as well as a timetable for implementing the remaining measures. By letter dated 19 January 2026, the Authority took note of the commitments made and demanded that the Directorate-General for Public Finance keep it informed of the compliance of its online public communication service and, finally, demanded that the online tax return process be brought into compliance, having regard in particular to thelong-standing nature of the legal obligations and the impact of the non-compliances in question on the public service remit. By letter dated 6 May 2026, the Directorate-General for Public Finance informed the Authority of the corrective measures undertaken, as well as a timetable for implementing certain measures still to be taken.

Compliance with Article 47(I) of the Act of 11 February 2005 concerning accessibility requirements

  1. It is apparent from the statements of offence of 30 April and 2 June 2026 that four breaches of Article 47(I) of the Act of 11 February 2005 were identified on the online public communication service www.impots.gouv.fr.

  1. Firstly, it is apparent from the statement of offence of 30 April 2026 that on the home page of the personal tax section, located on the online public information service www.impots.gouv.fr, the 2025 tax notice relating to 2024 income is available for download as a PDF document. It is noted that “the document is inaccessible, in particular due to the absence of a title, a specified language, and tags to structure the information”. It is also noted that “no other accessible alternative was available ”. The service therefore fails to comply with the accessibility requirements set out in Article 1 of the Decree of 24 July 2019 and specified in criterion 13.3 of the RGAA, which requires either that the downloadable document be accessible or that an accessible alternative version be available, which constitutes a breach of the accessibility obligation set out in Article 47(I) of the Act of 11 February 2005.

  1. On the same online public communication service www.impots.gouv.fr, at the address ‘https://cfspart.impots.gouv.fr/enp/messagerie.do’, it was noted in the same statement of offence of 30 April 2026, ‘it is impossible to access the “Write” section using the tab key, and the screen reader is unable to identify the information in this section and its sub-sections when the mouse pointer hovers over them.’ However, this information constitutes hidden content that is not intended to be ignored by assistive technologies, insofar as it enables the user to select the subject of the message sent to the tax office. The service therefore fails to comply with the accessibility requirements set out in Article 1 of the Decree of 24 July 2019 and specified in criterion 10.8 of the RGAA, which requires that hidden content not intended to be ignored must be accessible to assistive technologies; this constitutes a breach of the accessibility obligation set out in Article 47(I) of the Act of 11 February 2005.

  2. On the same page, ‘ https://cfspart.impots.gouv.fr/enp/messagerie.do ’, it is clear from the statement of offence of 30 April 2026 that it is impossible “to select the tax year while browsing using the keyboard, as a drop-down menu only appears when browsing with the mouse. When browsing by keyboard, once the first item in the drop-down menu is selected (the most recent tax year, in this case the 2025 financial year), the form refreshes automatically, preventing the selection of any other tax year. ’ The service therefore does not comply with the accessibility requirements set out in Article 1 of the Decree of 24 July 2019 and specified in criterion 12.11 of the RGAA, which requires that on every web page, additional content that appears on hover, when focus is gained or when an interface component is activated, must, where necessary, be accessible via the keyboard; this constitutes a breach of the accessibility obligation set out in Article 47(I) of the Act of 11 February 2005.

  1. It is apparent from the statement of offence of 2 June 2026 that at the address ‘https://cfspart.impots.gouv.fr/tdir/dec2042.html?_start=0’, when completing the tax return and attempting to fill in the sub-section ‘Income from non-commercial furnished lettings’, there is ‘no correlation enabling each cell in the table to be linked to the corresponding headings’. The service therefore fails to comply with the accessibility requirements set out in Article 1 of the Decree of 24 July 2019 and specified in criterion 5.7 of the RGAA, which makes provisionfor each data table, the appropriate technique must be used to link each cell to its headings; this constitutes a breach of the accessibility obligation set out in Article 47(I) of the Act of 11 February 2005.

Regarding compliance with Article 47(III) of the Act of 11 February 2005 concerning the requirement to publish an accessibility statement

  1. It appears from the statement of offence of 30 April 2026 that five breaches of Article 47(III) of the Act of 11 February 2005were identified on the online public communication service www.impots.gouv.fr.

Compliance with Article 47(III) of the Act of 11 February 2005 by the accessibility statement for the ‘Public Finances’ section

  1. It appears from the statement of offence of 30 April 2026 that in the accessibility statement for the ‘Public Finance’ section, whose address is ‘https://cfspart.impots.gouv.fr/enp/accessibilite.do’, ‘the sections “Feedback and contact” and “Appeals” are positioned before the accessibility statement. Furthermore, the headings required by the RGAA format are not strictly adhered to, as the declaration in question includes a section titled ‘Inaccessible content’ instead of ‘Non-accessible content’ as stipulated in the RGAA. Some sub-section headings are missing from the accessibility statement, such as the ‘Non-compliance’ section , whilst other sub-sections do not appear as separate headings and are incorporated into the main text; this is the case for the sub-section ‘Technologies used to create the website’. The service therefore does not comply with the mandatory format for the accessibility statement made provision for in point 1.6.1. of the RGAA pursuant to Article 5 of the Decree of 24 July 2019, which constitutes a breach of the obligation set out in Section III of Article 47 of the Act of 11 February 2005.

On compliance with Article 47(III) of the Act of 11 February 2005 by the accessibility statement for the ‘Online Property Service’

  1. It is noted in the statement of offence of 30 April 2026 that on the same page ‘https://cfspart.impots.gouv.fr/enp/accessibilite.do’, a second declaration concerning the ‘Biens immobiliers’ online service is present. However, the statement of offence notes that this second statement: “was drawn up on 16 January 2023”. The service therefore fails to comply with the obligation to update the accessibility statement within three years of its publication date, as provided for in point 1.6.1. of the RGAA pursuant to Article 6(I) of the Decree of 24 July 2019, which constitutes a breach of the obligation set out in Article 47(III) of the Act of 11 February 2005.

  2. Furthermore, according to the same statement of offence, the accessibility statement for the ‘Real Estate online service’ indicates a compliance rate of 42.11% with the RGAA criteria. The accessibility statement indicates that ‘the Property service is fully compliant with the General Framework for Improving Accessibility (RGAA), version 4.1 ’. However, point 1.6.1 of the RGAA makes provision for ‘a compliance report to be included in the accessibility statement’ and that ‘if fewer than 50 per cent of the RGAA’s assessment criteria are met’, the status is to be indicated as ‘partial compliance ’. The service therefore fails to comply with the obligation set out in section 1.6.1. of the RGAA pursuant to Article 6(II)(2) of the Decree of 24 July 2019, which constitutes a breach of Article 47(III) of the Act of 11 February 2005.

  1. Finally, the report of 30 April 2026 notes that in this statement, “the sections ‘Feedback and contact’ and ‘Means of redress’ are positioned before the accessibility statement. I have not identified any headings entitled ‘Inaccessible content’ or ‘Non-compliance ’. The sections ‘Technologies used to create the website’ and ‘Test environment’ are incorporated into the text. The service therefore does not comply with the mandatory format for the accessibility statement made provision for in point 1.6.1. of the RGAA pursuant to Article 5 of the Decree of 24 July 2019, which constitutes a breach of the obligation set out in Section III of Article 47 of the Act of 11 February 2005.

On compliance with Section III of Article 47 of the Act of 11 February 2005 by the accessibility statement for the ‘Online Income Tax Return’ service

  1. It is apparent from the statement of offence of 30 April 2026 that on the page ‘https://cfspart.impots.gouv.fr/tdir/accueil.html ’, access is provided to an accessibility statement ‘which does not specify a compliance rate with the criteria of the General Framework for Improving Accessibility due to the absence of an audit […] ’. The service therefore fails to comply with the obligation to publish a statement resulting from an ‘effective assessment of the online public communication service’s compliance with the reference standard’, as required under point 1.6.1. of the RGAA pursuant to Article 6(II)(2) of the Decree of 24 July 2019, which constitutes a breach of the obligation set out in Article 47(III) of the Act of 11 February 2005.

Regarding compliance with Article 47(IV) of the Act of 11 February 2005 concerning the requirement to publish an action plan for the current year

  1. It is apparent from the official report dated 30 April 2026 that the action plan published on the Directorate-General for Public Finance’s online public information service www.impots.gouv.fr relates to the year 2024. The service therefore fails to comply with the obligation to provide ‘easy and direct access’ to the ‘action plan for the current year’, which constitutes a breach of the obligation laid down in Article 47(IV) of the Act of 11 February 2005.

Having deliberated on the matter,

It is hereby decided:

Article 1. – The Ministry of Public Action and Public Accounts is hereby given formal notice to comply, in respect of the online public information service ‘www.impots.gouv.fr ’, to the obligations set out in paragraphs I, III and IV of Article 47 of the Act of 11 February 2005 and specified by the Decree of 24 July 2019 on the accessibility of online public communication services for people with disabilities, as well as thethe Order of 20 September 2019 establishing the general framework for improving accessibility.

Art. 2 – The deadlines set for the Ministry of Public Action and Public Accounts to achieve compliance are:

  • 9 months from the date of notification of this formal notice for the obligations set out in paragraph I of Article 47 of the Act of 11 February 2005;
  • 2 months from the date of notification of this formal notice for the obligations set out in paragraphs III and IV of Article 47 of the Act of 11 February 2005.

Art. 3 – This decision shall be notified to the Ministry of Public Action and Public Accounts and published in the Official Journal of the French Republic.

Done at Paris , on 24 June 2026.

For the French regulatory authority for audiovisual and digital communication:

The Chair,

Mr AJDARI

Decision of 24 June 2026 giving formal notice to the Ministry of Public Action and Accounts

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