Multi-year digital accessibility plan

BNP Paribas Personal Finance Corp 2026 – 2029 July 2026

1. Accessibility Policy

Article 47 of Law No. 2005-102 of February 11, 2005* for equal rights and opportunities, participation and citizenship of disabled persons, makes it mandatory for any online communication service of companies whose turnover exceeds a threshold defined by the Council of State decree to be accessible to all. This requirement stems from Directive (EU) 2019/882 of the European Parliament and of the Council of 17 April 2019 on accessibility requirements for products and services.

1.1. The commitment of BNP Paribas Personal Finance management

Digital accessibility is at the heart of the concerns related to the development or provision of websites and applications, both for the general public and for the internal staff of BNP Paribas Personal Finance Corp.

This commitment is demonstrated by the development of this multi-year digital accessibility roadmap associated with annual action plans, with the objective of supporting compliance with the RGAA (General Framework for Improving Accessibility) and the progressive improvement of the websites and applications concerned.

To inform the public and remain compliant with the law, the multi-year accessibility roadmap must be available to users. The document clearly states the degree of compliance with digital accessibility rules for disabilities.

The multi-year roadmap guarantees the compliance of BNP Paribas Personal Finance Corp’s websites and applications, specifically:

The development, monitoring, and updating of this multi-year roadmap are the responsibility of an accessibility referent for the BNP Paribas Personal Finance management.

1.2 The concept of Digital Accessibility

Disability is defined as any limitation of activity or restriction of participation in society experienced in one’s environment by a person due to a substantial, lasting or definitive impairment of one or more physical, sensory, mental, cognitive or psychological functions, a multiple disability or a disabling health disorder (Article L. 114 of the Code of Social Action and Families). Digital accessibility consists of making online public communication services accessible to people with disabilities, meaning making them perceivable, operable, understandable, and robust.

  • Perceivable: Content must be interpretable by all the users’ senses, whether visual, auditory, or tactile. For example: facilitating the visual and auditory perception of content by the user; providing text equivalents for all non-text content; creating content that can be presented in different ways without loss of information or structure (e.g., with a simplified layout).
  • Operable: A website or application must be easy to navigate. Its interactive components must be functional for everyone, regardless of the devices or tools used. People with motor limitations or dexterity disorders require easily navigable interfaces. For example: providing the user with orientation elements to navigate and find content; making all functionality accessible via keyboard; giving the user sufficient time to read and use the content; avoiding the design of content likely to cause epileptic seizures.
  • Understandable: Content must be clear and intuitive, and user interactions must be predictable and easy to understand. For example: ensuring pages operate in a predictable manner; helping the user correct input errors.
  • Robust: Content must be robust and therefore interpreted reliably by a wide range of browsers, devices, and assistive technologies, such as screen readers. For example: optimizing compatibility with current and future uses, including assistive technologies.

1.3 Content covered

Online public communication services are defined as any provision to the public or categories of the public, by an electronic communication process, of signs, signals, writings, images, sounds, or messages of any nature that do not have the character of private correspondence (Article 1 of Law No. 2004-575 of June 21, 2004, for confidence in the digital economy). In accordance with Part II of Article 47 of the aforementioned law of February 11, 2005, they notably include:

  • Internet, intranet, and extranet sites; software packages, provided they constitute applications used via a web browser or a mobile application.
  • Mobile applications, defined as any application software designed and developed for use on mobile devices, such as smartphones and tablets, excluding the operating system or hardware.

Certain contents are exempt from the accessibility obligation and fall outside the legal scope:

  • Intranet and extranet content published before September 23, 2019, until such sites undergo a thorough revision.
  • Files available in office formats published before September 23, 2018, unless they are necessary for an administrative process performed by the organization concerned.
  • Pre-recorded audio and video content, including those with interactive components, published before September 23, 2020.
  • Live-streamed audio and video content, including those with interactive components.
  • Maps and online mapping services, provided that for maps intended to provide a location or route, essential information is provided in an accessible digital form.
  • Third-party content that is neither funded nor developed by the organization concerned and is not under its control.
  • Reproductions of heritage collection items that cannot be made fully accessible due to:
    • The incompatibility of accessibility requirements with the preservation of the item concerned or the authenticity of the reproduction, particularly regarding contrast.
    • The unavailability of automated and economical solutions that would allow the text of manuscripts or other heritage collection items to be easily transcribed and restored in a form compatible with the accessibility obligation.
  • Content of websites and mobile applications that are neither necessary for the completion of an active administrative process nor updated or modified after September 23, 2019, specifically archives.

2. Human and financial resources allocated to Digital Accessibility

The accessibility referent’s mission will be to:

  • Define the actions that PFF commits to carry out as part of a continuous improvement process for digital accessibility.
  • Monitor the implementation of these actions.
  • Support project teams during the tender, design, validation, and acceptance phases.
  • Ensure the correct maintenance of accessibility declarations on various media.
  • Participate in awareness raising, the definition of a specific training catalog, and communication actions related to digital accessibility.
  • Conduct active monitoring (watch) on the subject.
  • Monitor regulatory changes and act as a liaison for communications from the legal department.
  • Act as a liaison for exchanges within the community of digital accessibility referents at the BNP Paribas Group level.

For every digital project managed by the BNP Paribas Personal Finance Corp teams, the allocated operating and evolution budget will take into account the specific digital accessibility needs of each project for the year.

Depending on the relevance, the following may be planned for each project, using a budget specific to the team in charge of its scope:

  • The purchase of services for a review and opinion on the functional specifications.
  • An audit of the graphic mock-ups before development begins.
  • An audit of the site or application at each stage of the project’s maturation.
  • A final audit to detect the last errors and to write or update the accessibility declaration.
  • The involvement of people with disabilities during design phases (where possible) and testing phases, and the use of associations defending the rights of people with disabilities to ensure a rapid response to requests formulated by internal teams.

3. Organization for accessibility implementation

Taking digital accessibility into account requires an adaptation of the internal production and management organization of the websites and applications concerned, staff support, a modification of tender procedures, and finally, the support of people with disabilities when they report difficulties.

The following points describe the key areas BNP Paribas Personal Finance Corp will rely on to improve the digital accessibility of all its websites and applications:

  • The implementation of steering around an organization and the adaptation of end-to-end processes to comply with the digital accessibility of websites and applications.
  • Supporting employees in upskilling on digital accessibility at every stage of a project.
  • The construction of an evolution backlog based on both audits via the frameworks and real testing campaigns carried out by people with disabilities, with the support of the BNP Paribas SA disability mission and external associations.

3.1. Training and awareness plan

Throughout the application period of this roadmap, training and awareness actions will be organized to enable staff working on the sites and applications to develop, edit, and publish accessible content.

Through RHG and the Disability Mission, e-learning created by the company ATALAN regarding digital accessibility at all stages of a project is assigned to all internal collaborators via the registration platform for training offered to BNP Paribas employees.

These trainings are intended for everyone, and particularly for people directly involved in the purchase of IT services, the creation, maintenance, and use of digital content: order givers, buyers, designers, developers, designers, testers, and editorial content writers.

An internal Teams community, where information relating to digital accessibility and disability is regularly shared, is available for BNP Paribas Personal Finance Corp teams.

Awareness sessions have already taken place and will be offered to BNP Paribas Personal Finance Corp collaborators to sensitize them to the challenges, regulations, and best practices of digital accessibility.

3.2. Use of external expertise

Whenever necessary, external consultants will be called upon to support BNP Paribas Personal Finance Corp in implementing accessibility.

This includes, for example, awareness and training actions, support actions, and specifically audit actions and the drafting of compliance declarations for the websites and applications concerned.

Specific awareness materials are available on our sites and internal distribution platforms.

Companies specializing in digital accessibility and associations defending the rights of people with disabilities are consulted to support our teams according to the type of need identified: support during scoping, design, development, or acceptance phases.

Internal resources and support are also available through Bivwak, the BNP Paribas transformation hub.

3.3. Integrating digital accessibility into projects

As part of a global redesign project, a design system meeting accessibility requirements will be systematically requested and integrated whenever possible to reinforce the graphic and functional consistency as well as the technical robustness required by the RGAA.

Regarding SaaS solutions, digital accessibility will be part of the requirements and will be considered in the final choice of the tool, provided that the latter meets other expected functional requirements.

3.4. User testing

If user tests are organized during the design, validation, or evolution phase of a website or application, the user panel constituted will, as far as possible, include people with disabilities.

To integrate a representative panel of users with disabilities, it may be planned to work in collaboration with associations defending the rights of people with disabilities and companies that offer a pool of users trained in performing accessibility tests.

3.5. Digital accessibility in tender procedures

Digital accessibility and RGAA compliance must constitute a binding clause and contribute to the evaluation of the quality of a provider’s offer, as well as that of its teams, when ordering work through tenders.

The procedures for developing contracts, as well as the rules for evaluating candidacies, have been adapted to take into account RGAA compliance requirements, but also to evaluate the provider’s knowledge and competence in implementing digital accessibility best practices.

Finally, in a logic of continuous improvement, the Group Communication Purchasing Department will deploy an information campaign to its providers to sensitize them to the applicable legal and regulatory requirements. This action complements general contractual provisions requiring compliance with all current regulations.

3.6. Recruitment

Particular attention will be paid to digital accessibility skills of personnel working on digital services (UX/UI, communicators, digital project managers, front-end developers, content managers) during the creation of job descriptions and recruitment procedures.

3.7. Handling User Feedback

In accordance with the provisions of the RGAA and the legitimate expectations of users, a means of contact will be implemented, as compliance work progresses, on each site or application, allowing users with disabilities to report their difficulties.

To respond to these requests, an information and assistance procedure will be implemented across all channels (telephone, web, and mobile).

3.8. Control and Validation Process

Each site or application will be subject, upon initial launch, substantial update, redesign, or at the end of standardization operations, to a control allowing the establishment of a compliance declaration in accordance with the terms of the law.

To guarantee its sincerity and independence, this control will be performed either externally by an accredited company or internally by a trained person who was not involved in the project.

These control operations intended for the establishment or updating of compliance declarations complement the usual acceptance operations and intermediate controls that will be organized, if necessary, throughout the life of the projects.

3.9. Mandatory mentions on the site and mobile application

The home page of all sites managed by BNP Paribas Personal Finance Corp and mobile applications must display one of the following mentions:

  • “Accessibility: fully compliant” if all RGAA control criteria are met;
  • “Accessibility: partially compliant” if at least 50% of the RGAA control criteria are met;
  • “Accessibility: non-compliant” if there is no valid audit result to measure the respect of the criteria or if less than 50% of the RGAA control criteria are met.

This mention is clickable and leads to the “Accessibility” page containing the accessibility declaration, as well as the link to the multi-year roadmap.

Websites and mobile applications will have a dedicated page (“accessibility”) accessible directly from the home page and from any page of the service, which will contain the following elements:

  • The accessibility declaration according to the model set by the RGAA framework;
  • The multi-year accessibility roadmap or a link to it;
  • The action plan for the current year or a link to it.

4. Technical and Functional Scope

4.1. Inventory

The teams in charge of corporate digital assets for BNP Paribas Personal Finance Corp manage all websites, intranets, and applications intended for the public or its staff.

4.2. Evaluation and Qualification

Each site or application has been qualified according to the following criteria:

  • Traffic/Attendance
  • Service provided
  • Criticality
  • Lifecycle

This qualification allows action plans to be oriented realistically, thus prioritizing assets with the greatest impact.

Some applications may not be made public for reasons of security or confidentiality, for example.

The accessibility analysis will take into account RGAA exemptions in situations where it is not possible to make content accessible:

  • Content provided by a third party: for example, content published by site users, uncontrolled content from external sources.
  • Archiving and provision of obsolete content (content falling under the mission of safeguarding the Internet as heritage by public actors designated by law may be subject to an exemption).
  • Large numbers of downloadable content: notably content older than two years.

Compliance will take into account the notion of “reasonable accommodation”: reasonable accommodation means the necessary and appropriate modifications and adjustments that do not impose a disproportionate or undue burden, provided based on needs in a given situation, to ensure that persons with disabilities enjoy or exercise, on an equal basis with others, all human rights and fundamental freedoms.

This requires the ability to arbitrate when a correction involves a volume of work or a budgetary burden that is too high compared to the actual impact on the user. In this case, the RGAA suggests exempting such content, if necessary, in favor of an alternative method that ultimately allows the user to access the content concerned.

Non-accessible content must be signaled to the user on the help page and in the compliance declaration so that they are informed of the proportion of pages concerned and their location within the site’s sections.

It is important to recall that under Article 11 of the February 2005 law, a person with a disability is entitled to compensation for the consequences of their disability regardless of the origin and nature of their impairment, their age, or their lifestyle. Classification: Internal.

Consequently, PFF management is obliged to take the necessary means to provide access, within a reasonable time, to the information and functionalities sought by the person with a disability, whether the content is subject to an exemption or not. The possibility of requesting an accessible alternative content must be offered to the user on the help page via an accessible means of contact (email address or contact form).

5. Annual Action Plans

This multi-year roadmap is accompanied by annual action plans that describe in detail the operations implemented to address all digital accessibility needs of the Communication Department of BNP Paribas Personal Finance Corp.

  • Annual Plan 2026, latest update 10/31/2026.
  • Annual Plan 2027: upcoming.
  • Annual Plan 2028: upcoming.

The multi-year roadmap and the current year’s action plan will be accessible online on the sites managed by BNP Paribas Personal Finance Corp.

Links to these documents appear within the accessibility declaration of the online public communication services depending on the entity and are published in an accessible format.

*Regulatory References