The multi-year plan: the document (almost) nobody publishes
I'll be honest: the multi-year accessibility plan is one of the most neglected legal requirements in French digital accessibility. It's mandatory for all RGAA-subject entities, required by decree n. 2019-768, covering a maximum 3-year period. And yet most organisations simply don't have one.
Here's the catch: not having this document is a sanctionable offence on its own -- EUR 20,000 per year fine. Even if your website is perfectly accessible otherwise. The plan is a separate legal obligation.
What it must contain
The decree is pretty specific. You need: an accessibility policy (real management commitment, not just a vague sentence), objectives and scope, an inventory of your sites and apps with audit results and compliance rates, an identified accessibility officer with contact details, governance structure, and a 3-year action plan broken down year by year with priorities, audit schedules, training programs, and measurable indicators.
On top of that, you need a detailed annual action plan for the current year: who does what, by when, and how you'll measure success.
Template structure
- Introduction and commitment
- Scope of digital services
- Current assessment with audit results
- Accessibility policy and governance
- Year 1-3 action plans
- Training plan
- Procurement integration
- Monitoring indicators
Publication rules
The plan must be published online. It must be accessible itself (I know, sounds obvious, but I've seen accessibility plans published as untagged PDFs -- the irony). Updated annually, renewed every 3 years, and linked from your accessibility statement.
Common mistakes I keep seeing
Plans that are too vague ("we commit to accessibility" with zero specifics). Missing annual action plans. Outdated plans from 2020 never renewed. Published only as inaccessible PDFs. No named accessibility officer. Sound familiar?
A good plan with modest objectives beats an ambitious plan that never gets implemented. Make it realistic, keep it updated, and above all: actually follow through.