Multi-year digital accessibility plan

BNP Paribas Communications Department - Multi-year digital accessibility plan

1. Accessibility policy

Article 47 of Law No. 2005-102 of 11 February 2005 on equal rights and opportunities, participation and citizenship of persons makes it mandatory for any online communication service of companies whose turnover exceeds a threshold defined by the decree of the Council of State mentioned in V to be accessible to all.


1.1. The will of BNP Paribas' Group Communications Department

Digital accessibility is at the heart of concerns related to the development or provision of websites or applications to both the public and internal staff in BNP Paribas' Group Communications Department.

This desire is illustrated by the development of this multi-year digital accessibility plan associated with annual action plans, with the aim of supporting the compliance with the RGAA (General Accessibility Improvement Framework) and the gradual improvement of the websites and applications concerned.

To inform the public and comply with the law, the multi-year accessibility plan must be within the reach of users. The document clearly mentions the degree of compliance with the rules of digital accessibility of disability.

The multi-year plan guarantees the compliance of the websites or applications of the BNP Paribas Group Communications Department.

The development, monitoring and updating of this multi-year plan is the responsibility of an accessibility referent for the BNP Paribas Group Communications Department.

Its mission is to promote accessibility through the dissemination of standards and good practices, to support internal teams through training actions in particular, to control and ensure the application of Law No. 2005-102 of 11 February 2005 by carrying out regular audits, to ensure that user requests are taken care of and in general the quality of the service provided to users with disabilities.

This referent has the responsibility and authority in particular for :

  • Ensure that the processes necessary to take accessibility into account are established, implemented and maintained;
  • report to BNP Paribas' Communications Department on the level of accessibility and any need for improvement;
  • Ensure that awareness of accessibility requirements throughout the organization is encouraged;
  • To be the single point of entry on digital accessibility topics.
1.2. Accessibility Referent

The development, monitoring and updating of this multi-year plan is the responsibility of the accessibility referent.

Its mission is to promote accessibility through the dissemination of standards and best practices, to support the Group's internal teams through training activities, in particular, to monitor and ensure the application of Law No. 2005-102 of February 11, 2005 by carrying out, directly or through specialized stakeholders, regular audits,  to ensure that user requests are handled and, in general, the quality of the service provided to users with disabilities.

1.3. The notion of digital accessibility

Disability is defined as any limitation of activity or restriction of participation in life in society suffered by a person in his or her environment due to a substantial, lasting or permanent alteration 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 is the process of making online public communication services accessible to people with disabilities, by:

  • Perceivable : for example, to facilitate the visual and auditory perception of content by the user; to provide text equivalents to any non-text content; to create content that can be presented in different ways without loss of information or structure (for example, with a simplified layout);
  • Usable : for example, providing the user with guidance to navigate, finding content; making all features accessible to the keyboard; allowing the user sufficient time to read and use the content; not designing content that may cause epileptic seizures;
  • Understandable : e.g., making pages work in a predictable way; helping the user correct input errors.
  • Robust : For example, optimize compatibility with current and future uses, including assistive technologies.

1.4. Relevant Content

Online public communication services are defined as any making available to the public or categories of the public, by a means of electronic communication, signs, signals, writings, images, sounds or messages of any kind that do not have the character of private correspondence (Article 1 of Law No. 2004-575 of 21 June 2004 on confidence in the digital economy). In accordance with II of Article 47 of the aforementioned Law of 11 February 2005, they include, in particular:

  • Websites, intranets, extranets; software packages, insofar as they constitute applications used through a web browser or a mobile application;
  • Mobile applications which are defined as any application software designed and developed for use on mobile devices, such as smartphones and tablets, outside of operating systems or hardware;
  • Digital street furniture, for its application or interactive part, excluding operating systems or hardware.

Some content is exempt from the obligation of accessibility and is outside the scope of the legal obligation:

  • Files available in office formats published before 23 September 2018, unless they are necessary for the completion of an administrative procedure relating to the tasks carried out by the organisation concerned;
  • Pre-recorded audio and video content, including those with interactive components, released before September 23, 2020;
  • Live audio and video content, including those with interactive components;
  • Maps and online mapping services, provided that, in the case of maps intended to provide a location or route, essential information is provided in an accessible digital form;
  • Third-party content that is not funded or developed by the relevant organization and is not under its control;
  • Reproductions of pieces from heritage collections that cannot be made fully accessible due to:
    • Either the incompatibility of the accessibility requirements with the preservation of the piece concerned or the authenticity of the reproduction, particularly in terms of contrast;
    • Either the unavailability of automated and cost-effective solutions that would make it possible to easily transcribe the text of manuscripts or other pieces of heritage collections and to restore it in the form of content compatible with the obligation of accessibility;
  • Intranet and extranet content published before September 23, 2019, until these sites are substantially revised;
  • The content of websites and mobile applications that is neither necessary for the completion of an active administrative procedure nor updated or modified after 23 September 2019, in particular archives.

2. Human and financial resources dedicated to digital accessibility 

A digital accessibility referent has been appointed for Communication Groupe. Its mission is to:

  • Define the actions that the Group's communication department is committed to carrying out as part of a process of continuous improvement of digital accessibility.
  • Monitor the implementation of actions.
  • Support the project teams in the tendering, design, validation and acceptance phases.
  • Ensure that the accessibility declarations that will be made on the various media are properly maintained
  • Participate in raising awareness, defining the specific training catalog and communication actions related to digital accessibility.
  • Actively monitor the subject.
  • Monitor changes in regulations and be the relay for communications that may be made by the legal authorities.
  • To be the relay for exchanges within the community of digital accessibility referents when it is in place at the level of the BNP Paribas Group.

For each digital project managed by the teams of the Group Communication Department, the operating and development budget that will be allocated will take into account the specific needs of each of them in terms of digital accessibility over the year.

It may be provided for each project, on a budget specific to the team in charge of its scope, when relevant:

  • The purchase of services for a review and an opinion on the functional specifications
  • An audit of the graphic mock-ups before the start of development
  • An audit of the site or application at each stage of the project's maturation
  • A final audit to detect the latest errors and to draft or update the accessibility statement.
  • The use of people with disabilities during the design phases, where possible, and during the testing phases. To this end, partnerships with companies specialising in the subject will be studied, in order to ensure that the requests made by the internal teams are quickly taken into account.

3. Organization of digital accessibility consideration

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

The following elements describe the important points on which BNP Paribas' Communications Department will rely to improve the digital accessibility of all its websites and applications:

  • The internal organization program to comply with the digital accessibility of websites and applications.
  • Supporting employees in increasing their skills in digital accessibility at each stage of a project.
  • The methods used to overcome the difficulties encountered by people with disabilities with the support of the disability mission of BNP Paribas SA

3.1. Training and awereness plan

Throughout the period of application of this scheme, training and awareness-raising actions will be organized to enable staff working on the sites and applications to develop, edit and put accessible content online.

Through RHG and the Disability Mission, an e-learning course produced by ATALAN on digital accessibility at all stages of a project is available to all internal and external employees, via the registration platform for the training courses offered to BNP Paribas employees.

These training courses are intended for everyone and in particular for people directly involved in the purchase of IT services, the creation, maintenance and use of digital content: clients, buyers, designers, developers, designers, testers, editorial content writers.

The editorial teams will also be made aware of the subject of digital accessibility during internal events organized for the communication department, the Group's human resources and the BNP Paribas Disability Mission. An editorial notice presenting good accessibility practices for writing and creating content will be made available to editorial teams.

An internal Teams community where information related to digital accessibility and disability is regularly shared is available to Group Communication teams.

Digital accessibility fresco sessions will be offered to Communication Groupe employees, in order to raise their awareness of the issues, regulations and best practices of digital accessibility.

3.2. Use of external expertise

Whenever necessary, external stakeholders will be called upon to support BNP Paribas' Communications Department in taking accessibility into account.

This covers, for example, awareness-raising and training actions, support actions and more particularly audit actions and drafting of compliance declarations for the websites and applications concerned.

Specific awareness-raising materials are available on our websites and internal distribution platforms

Companies specialising in digital accessibility such as URBILOG, ATALAN, NUMERIK-EA or IPEDIS are regularly called upon to support our teams according to the type of need identified: support during the scoping, design, development or acceptance phases.

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

3.3. Consideration of digital accessibility in projects

The objectives of accessibility and compliance with the RGAA will be included and recalled from the beginning of the projects, of which they will constitute an essential axis and a basic requirement. In the same way, these objectives and requirements will be recalled in any agreements established with the partners.

As part of the global redesign project, a design system that meets accessibility requirements will be systematically requested and integrated when possible, in order to strengthen the graphic and functional coherence as well as the technical robustness required by the RGAA.

Regarding SaaS solutions, digital accessibility will be one of the requirements and will be taken into account in the final choice of the tool, as long as it meets the other expected functional requirements.

3.4. User testing

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

In order to integrate a representative panel of users with disabilities, it may be planned to work in collaboration with companies that offer a pool of users trained to carry out accessibility tests.

This approach will be systematized for future projects and complete functional overhaul operations.

3.5. Consideration of accessibility in tendering procedures

Digital accessibility and compliance with the RGAA must constitute a binding clause and participate in the evaluation of the quality of a service provider's offer, as well as that of its teams, when ordering work through calls for tenders in particular.

The procedures for drawing up contracts, as well as the rules for evaluating applications, have been adapted to take into account the requirements of compliance with the RGAA, but also to assess the knowledge and competence of the service provider on the consideration and application of good digital accessibility practices.

Finally, in order to continue to gradually take digital accessibility into account by service providers through a specific clause in contract templates, the Group Communication Purchasing Department will set up an information campaign for its subcontractors to inform them of their obligations.

3.6. Recruitment 

Particular attention will be paid to the digital accessibility skills of staff 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 set up, as the work to comply is carried out, on each site or application allowing users with disabilities to report their difficulties.

In order to respond to its requests, the implementation of a specific assistance procedure will be studied with all the services and staff involved.

Requests can be sent to the generic "comgpe.accessibilite.numerique [at] bnpparibas (dot) com" mailbox which is administered by the Communication Groupe accessibility referent. The latter will be responsible for distributing messages to the project managers and will ensure that the processing of requests is followed.

3.8. Control and validation process

Each site or application will be subject to a control at the time of initial uploading, during a substantial update, a redesign or at the end of the compliance operations, in order to establish a declaration of conformity in accordance with the terms of the law.

To guarantee the sincerity and independence, this control will be carried out internally by a trained person who has not been involved in the project or through a specialized external speaker.

These control operations, intended for the establishment or updating of declarations of conformity, are carried out in addition to the usual acceptance and intermediate control operations which will be organised, if necessary, throughout the life of the projects.

3.9. Planned agenda of interventions

Taking into account the information gathered during the development of this scheme, the complexity of the sites and applications, their prioritization and their assessment in terms of feasibility, the compliance operations that began in 2019, have continued to date and will continue in 2024.

The scheme will list through the annual action plans the corrective measures that will be taken to address non-accessible content, including a timetable for the implementation of these measures, taking into account the priority nature of the most viewed content and the most used services.

3.10. Mandatory information on the website

The home page of the BNP Paribas Communications Department's website, i.e. the Corporate website, as well as all the home pages of the sites managed by Group Communications, will display one of the following information:

  •  "Accessibility: fully compliant" if all the RGAA control criteria are met;
  • "Accessibility: partially compliant" if at least 50% of the RGAA control criteria are met;
  • "Accessibility: non-compliant" if there are no valid audit results to measure compliance with 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 statement, as well as the link to the multi-year plan.

The Websites will have a dedicated page ("accessibility") accessible directly from the home page and from any page of the Service and which will contain the following elements:

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

The use of a standardised internet address (or URL) such as  www.sitename.extension/accessibility  will in all cases be applied.

4. Technical and functional scope

4.1. Inventory

The teams in charge of Digital Media for Group Communication manage 16 websites, intranets and applications for the public or its staff.

4.2. Evaluation and qualification

Each site or application was qualified according to the following criteria:

  • Attendance
  • The service provided
  • Criticality
  • The Life Cycle

Rapid accessibility assessments, which serve as a basis for the development of audit interventions, have been or will be carried out on all the sites and applications concerned.

These evaluations relate to a number of criteria chosen for their relevance in terms of assessing the complexity and feasibility of bringing the RGAA standards into compliance.

Appendix 1 (below: "Appendix 1: public technical and functional perimeter") describes the elements that can be made public of the technical and functional perimeter. Indeed, some applications may not be made public for security or privacy reasons for example.

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

  • Content provided by a third party: for example, content published by users of the site, uncontrolled content from external sources;
  • Archiving and making available obsolete content (content falling within the mission of safeguarding the Internet as a heritage by public actors designated by law may be subject to an exemption);
  • Downloadable content in large numbers: content that is more than two years old in particular.

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

This requires the ability to arbitrate when a correction involves too much work or a budgetary burden compared to the real impact on the user. In this case, the RGAA proposes to derogate from this content, if necessary in favor of an alternative method that ultimately allows the user to access the content concerned.

Non-accessible content must be reported to the user on the help page and in the declaration of conformity so that he or she is informed of the proportion of the pages concerned and their location in the sections of the site.

It is important to remember that under Article 11 of the Law of February 2005, the disabled person is entitled to compensation for the consequences of his disability regardless of the origin and nature of his impairment, his age or his lifestyle.

As a result, BNP Paribas' Communications Department is obliged to take the necessary measures to provide access, within a reasonable time, to the information and functionalities sought by the disabled person, whether or not the content is subject to an exemption. The possibility to request 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 plan is accompanied by annual action plans that describe in detail the operations implemented to meet all the digital accessibility needs of BNP Paribas' Communications Department.

As a reminder:

  • Sites created from 1 October 2019 onwards must meet the requirements of the reference framework as of this date.
  • From 1 October 2020, for those conceived before 1 October 2019.
  • Extended deadline for mobile applications, software packages and digital street furniture, until July 1, 2021.

The multi-year plan and the action plan for the current year will be available online on the websites managed by Communication Groupe.

Links to these documents are included in the entity's online public communication accessibility statement and are published in an accessible format.