Groupe BPCE’s multi-year accessibility plan 2025-2027

November 2024

Pursuant to Article 47 of the French Law dated February 11, 2005 on the Equality of Rights and Opportunities, the Participation and Citizenship of Individuals with Disabilities, this multi-year plan – whose duration shall not exceed a maximum of three years – presents the digital accessibility policy adopted by Groupe BPCE. As such, it contains information about the incorporation of digital accessibility into the digital strategy of Groupe BPCE entities and how account is taken of this question in their policy for the inclusion of people with disabilities.

Introduction

Digital accessibility, a societal and regulatory challenge

Tim Berners-Lee, founder and inventor of the World Wide Web, wanted to make the Web and the services it provides available to all individuals, regardless of their hardware or software, their network infrastructure, their mother tongue, their culture, their geographical location, or their physical or mental aptitudes.

Digital accessibility is essential to meeting this goal of universality, since it aims to ensure that the information and functionalities of a digital service or content are accessible to all, irrespective of the person’s disability or the way in which they access the information.

This implies that everyone should be able to:

Perceive and understand the information and functionalities of a digital service,
Browse and interact with it,
And, in so doing, contribute to the web.

Digital accessibility is therefore a prerequisite to ensuring that any digital service or content serves as a vector of inclusion and autonomy for all. In this respect, accessibility is part of the same approach as inclusion to ensure that every individual enjoys full access to the digital world.

In this respect, digital accessibility is a fundamental right as recognized by the United Nations in the Convention on the Rights of Persons with Disabilities.

To ensure compliance with this convention, France has adopted a regulatory framework based on the Law dated February 11, 2005 on the Equality of Rights and Opportunities, the Participation and Citizenship of Individuals with Disabilities, in accordance with European directives.

More specifically, Article 47 of the French law makes it mandatory to ensure that all online communication services provided to the general public by public bodies, as well as by certain private entities, are accessible to all. ‘Private entities’ include those with annual sales in France of at least 250 million euros, calculated on the basis of average annual sales in France over the last three financial years prior to the year in question.

To complete this regulatory framework and define the technical requirements resulting from it, a dedicated reference framework has been drawn up: the RGAA (Référentiel Général d’Amélioration de l’Accessibilité, or “General Reference Framework for Improving Accessibility”).

It is within this framework that Groupe BPCE entities are required ensure that their digital content and services are accessible to all their clients and employees, as well as to the general public.

It should be noted that, in accordance with the latest developments in European regulations, French accessibility obligations have also been extended to include certain categories of products and services. These include self-service terminals, banking contracts and services, certain investment and related services, and services related to current accounts. The present multi-year plan will not cover these new obligations, which will be the subject of specific dedicated actions.

Digital accessibility, a strategic priority for Groupe BPCE

For many years, Groupe BPCE has been committed to a disability policy for the benefit of its employees consistent with its values of promoting diversity and corporate social responsibility.

In line with this policy, the challenges of digital accessibility have been taken up by the various Groupe BPCE entities on their own initiative. Recent developments in the wider context, however, have given them a new resonance (see below), calling for action at the highest level through this first multi-year plan common to all Groupe BPCE entities.

Beyond the regulatory developments mentioned above, the momentum generated notably by the 2024 Paralympic Games has driven far-reaching awareness about the question of disability and inclusion. Even more so within Groupe BPCE in its capacity as Premium Partner of the event and which also sponsors several para athletes.

In this respect, the 2024 Paralympic Games inspired a collective awareness encouraging the implementation of concrete actions and, as such, constituted a real catalyst for digital accessibility with the launch of the dedicated BPCE Program.

In addition, Groupe BPCE has drawn up a strategic project, “VISION 2030”, outlining the major strategic priorities to be pursued by the Group and its business lines between now and 2030, including “improving the accessibility of digital products and services”. Based in particular on the notion of generating a positive global impact through the strength of local solutions accessible to all, this project translates the desire for an ethical approach to digital technology, in line with the Group’s cooperative values.

In conclusion, Groupe BPCE’s Accessibility Program provides it with an opportunity to reinforce its commitment to an inclusive bank accessible to all in terms of digital services. The launch of this program reflects the Group’s determination to make the inclusion of people with disabilities or experiencing challenges with digital technology one of its long-term strategic priorities.

Scope of Groupe BPCE’s multi-year plan

Group entities concerned by the approach

This multi-year plan applies to all Groupe BPCE entities. Each entity, however, remains individually responsible for its own digital accessibility, in line with the Group’s ambitions and commitments.

Publics concerned by the approach

Accessibility concerns digital services intended for the general public, employees and customers (both individual and professional clients) of Groupe BPCE. In particular, it concerns people with long-term or permanent sensory, motor or cognitive impairments, as well as those with temporary disabilities.

With a view to digital inclusion, Groupe BPCE wanted to extend its actions in this area to people with limited digital skills while simultaneously taking account of the ageing of the population.

In view of the very large number of digital services provided by all its entities, Groupe BPCE has identified a priority target audience for the planning and prioritization of digital accessibility actions arising from the present 2025-2027 multi-year plan.

Initially, the general public, individual clients and prospects, and Group employees will consequently benefit from these actions.

The demographics of this priority target audience may be broadened as progress is made. Ultimately, the actions carried out will benefit all the audiences addressed by Groupe BPCE’s digital services, whether over the next three years, or as part of a future multi-year plan.

Digital services concerned by the approach

Digital services as defined by accessibility regulations notably include the following:

Internet, intranet and extranet sites,
Software packages, insofar as they constitute applications used via a web browser or mobile application,
Mobile applications, which are defined as any application software designed and developed for use on mobile devices such as smartphones and tablets, regardless of the operating system or hardware used,
Digital street furniture, for its applicative or interactive part, excluding the type of operating system or hardware,
Digital documents distributed on all the tools mentioned above.

Among the latter, Groupe BPCE has decided initially to prioritize websites and mobile applications developed in-house. This represents more than 1,000 digital services identified to date, including around 350 dedicated to the defined priority target audience. In line with this target audience, Groupe BPCE has defined a corresponding perimeter for its ambitions up to 2025, namely :

General public: institutional sites and social networks,
Individual clients: web and mobile customer sites and spaces, contracts and digital documents,
Employee perimeter: common base for all employees, starting with day-to-day HR, Workplace and Communication tools.

As in the case of the priority target audience, this perimeter may be extended at a later date.

Status of actions undertaken as of 2024, prior to publication of the 2025-2027 multi-year plan

On their own level, certain Groupe BPCE entities have already been able to launch a digital accessibility process by carrying out RGAA compliance audits and improving the accessibility of their digital services, providing support from specialized consultancies, or drawing up their own multi-year plans.

However, owing to the many synergies and co-responsibilities existing between its entities, Groupe BPCE decided to synchronize and harmonize the approach by setting up a dedicated governance structure, known as the ‘Accessibility Unit’, and by launching a program to strengthen digital accessibility.

As soon as it was created, the Accessibility Unit focused on highlighting the challenges and sharing the best practices of digital accessibility with the Group’s different entities as well as with the business line and IT departments of BPCE-SA.

In order to define the ambitions for 2024-2025 and to lay the foundations for the program, the unit began with a scoping phase involving the launch of the following projects:

Regulations and control systems:
- Development of the associated control system,
- Definition of digital accessibility management indicators prior to their implementation,
- Adoption and distribution of a Group-wide Norm to provide a framework for the accessibility of Groupe BPCE’s digital services.
Target ambitions, organization and budget:
- Survey and analysis of existing Groupe BPCE digital services,
- Definition of target ambitions for the business lines up to 2030,
- Quantification of the resources required for the remedial measures needed to achieve the 2025 ambitions.
Tools, methods and change management:
- Provision of an accessibility declaration template, this multi-year plan, and an annual action plan template,
- Definition of target IT project methodologies, accompanied by a toolkit for the production of “by design” accessible digital content and services,
- Reflection on the conduct and industrialization of RGAA compliance audits,
- Introduction of accessibility requirements into the Group’s purchasing policy,
- Assessment of the digital accessibility maturity level of Groupe BPCE’s major publishers, with a view to implementing remediation plans,
- Provision of a training program dedicated to digital accessibility within Groupe BPCE,
- Development of a change management plan for the Accessibility Program.

Gouvernance

Creation of an Accessibility Unit

The governance of Groupe BPCE’s accessibility program is provided by an Accessibility Unit created with a view to:

Ensuring regulatory compliance: Groupe BPCE’s Accessibility Unit ensures compliance with legal and regulatory requirements in terms of digital accessibility, in particular those of the Law of February 11, 2005 and the European Directive of April 17, 2019,
Defining the Group’s ambitions and the priority actions to be taken, monitoring and supervising the application of accessibility standards by all Group entities,
Improving the user experience for Groupe BPCE customers and employees: by making digital services accessible, the Unit contributes to improving the user experience for all Groupe BPCE clients and employees, regardless of their abilities,
Enabling greater operational efficiency: setting up an Accessibility Unit makes it possible to centralize and structure efforts made to enhance accessibility, which can improve operational efficiency and facilitate coordination between the various stakeholders.

Organization of the Accessibility Unit

The Accessibility Unit is organized in a structured way to ensure optimal coordination and effective implementation of digital accessibility initiatives. It is comprised of the Group Accessibility Coordinator, a core team, local Accessibility Coordinators, and the IT liaison officers in the various entities concerned.

Roles and responsibilities of the core team

The Group Accessibility Coordinator

The Group Accessibility Coordinator has three main roles:

Supporting Group entities, through the network of local accessibility coordinators, in bringing digital services up to standard: regulatory watch, definition and communication of ambitions (prioritization, remediation, audits, etc.),
Awareness-building and training activities: promoting awareness of the challenges of digital accessibility and increasing the skills of stakeholders,
Monitoring and steering: the Group Accessibility Coordinator is responsible for monitoring and steering measures taken to enhance the accessibility of the Group’s customer services and employee tools.

Cross-functional roles of the core team

The core team is comprised of representatives from different key functions within Groupe BPCE whose main missions are to:

Act as intermediaries between the various BPCE entities (promotion, information sharing, etc.) and internal and external regulators.
Supervise the implementation of the Group’s ambitions in terms of accessibility (setting up and industrializing monitoring KPIs, etc.).
Centralize best practices and share information about local initiatives.

Local accessibility coordinator

The local accessibility coordinator is the point of entry for his or her entity to guarantee compliance and continuous improvement of digital accessibility. Their main tasks are to:

Ensure compliance with accessibility standards:
- Ensure level 1 control of the accessibility of their entity’s websites, applications and digital services:
  - Ensure the presence of mandatory documents (accessibility declaration, multi-year plan, action plan),
  - Check the validity of compliance audits,
  - Ensure that all private projects comply with accessibility standards,
  - Ensure that responses to accessibility complaints meet regulatory deadlines.
- Ensure minimum level 2 support for response to user accessibility complaints,
- Identify areas for improvement (regulations, user complaints, technical watch, etc.) and propose corrective measures in line with their entity’s action plan.
Manage accessibility enhancement measures:
- Define the entity’s accessibility ambitions in line with Group guidelines,
- Monitor the progress of work carried out within their entity,
- Act as an intermediary between the core team and their entity:
  - Communicate the Group’s decisions and ambitions,
  - Provide the core team with regular indicators and reports concerning their entity,
  - Share the successes of their entity liable to be extended to the entire Group.
Raise awareness of digital accessibility requirements among the different audiences (purchasing, IT, communications, HR, etc.):
- Contribute to drawing up a training plan on digital accessibility, in agreement with the training officers.

Human and financial resources allocated to digital accessibility

Human resources currently comprise the different members of the Accessibility Unit, who are working to achieve Groupe BPCE’s ambitions in this area, with contributions made by over 50 people working on a part-time basis.

The Group’s entities were asked to estimate the amount of manpower dedicated to making their digital services more accessible. Regular reporting of data in this area should eventually enable optimum management of human and financial resources linked to digital accessibility.

As far as financial resources are concerned, with the help of the Group’s entities, an initial budget estimate has been produced to achieve our 2025 ambitions. At the date of writing of this multi-year plan, the estimated budget amounts to approximately 3 million euros for carrying out compliance audits and implementing remedies to accessibility problems identified in this context.

At the same time, the operating budget for the Accessibility Program has been included in Groupe BPCE’s Vision 2030 strategic project, for a total of 260,000 euros.

These budgets will be assessed and reviewed annually in the light of progress made in implementing the present multi-year plan and achieving the Group’s ambitions.

It should be noted that the human and financial resources allocated to digital accessibility are specific to each entity falling within the scope of this multi-year plan. Each entity defines these resources according to its own particularities and requirements, in line with Groupe BPCE’s ambitions in terms of digital accessibility.

Control system

A control system will be rolled out in the Group’s entities to monitor compliance with regulations and success in ensuring the accessibility of digital services.

The system will be based on a set of KPIs produced by local accessibility coordinators (first-level control), and supervised by the core team (second-level control).

Areas of continuous improvement under Groupe BPCE’s Accessibility Program

The areas for continuous improvement detailed below form the common basis for work to be carried out by Groupe BPCE entities over the 2025-2027 period.

Each entity, depending on its level of maturity, will include in its annual action plans the measures required to implement this multi-year plan. They are free to decide whether to take further action to promote accessibility and digital inclusion.

Pending the definition of an internal roadmap for 2026-2030, the objectives focus for the moment on the year 2025. This section will be revised at a later date to cover the entire period of validity of this multi-year plan.

Making digital services more accessible

Within the framework of the launch of the Accessibility Program, Groupe BPCE’s ambitions for 2025 include a dual objective:

On the scope for priority action, to remedy accessibility problems related to digital services to ensure at least partial accessibility (i.e. an RGAA compliance rate of over 50%).
To achieve this, entities will have to carry out RGAA compliance audits and plan the necessary remedial action to reach this objective via their own annual action plans, taking account of any user complaints.
For new digital services, the development of project methodologies to take account of digital accessibility from the initial design stage, in order to ensure an optimum level of accessibility when the services in question go into production.
To this end, Group entities will be provided with target processes, accompanied by a toolbox to assist them throughout the scoping, design, development, and deployment stages of a digital project.

The Accessibility Unit is studying the possibility of including user tests for digital services conducted with disabled people within the scope of the priority or extended audiences. In order to reap the full benefits, these tests will only be considered once the services concerned have reached a sufficient level of accessibility and the teams have reached a sufficient level of maturity.

Purchasing and service provider relations

We have also defined a two-pronged objective when it comes to taking digital accessibility into account in purchasing and service provider relations:

For well-established service provider relationships, the aim is to support the improvement of their level of maturity in this area, based on the agreed remediation plan,
For new purchases, the aim is to translate Groupe BPCE’s requirements in terms of digital accessibility into standard clauses and to define the criteria for rating and selecting a service provider.

Skills base

Recruitment

Groupe BPCE wants to include technical skills related to digital accessibility in eligible job descriptions, as well as in the recruitment process for the corresponding profiles (in particular via dedicated criteria).

Awareness-raising, training and change management

In the course of 2025, Groupe BPCE will provide its entities with an in-house training opportunities to disseminate the skills needed to make digital products and services more accessible. This training will include, among other things:

Accessibility awareness sessions for all employees,
Technical training for a more specialized audience (developers, UI/UX designers, content creators, etc.).

In addition, the Accessibility Unit will be developing a range of measures designed to raise awareness of disability and inclusion-related issues among Group employees.

In parallel with steps taken to improve the employee skills base, a change management plan is currently being drawn up to ensure the long-term accessibility of our entities’ digital content and services.

Diagnostics and audits

The procedures for carrying out RGAA compliance diagnostics and audits have not yet been defined. These will be detailed in this section during a subsequent revision of the present multi-year plan.

In the meantime, Group entities will carry out diagnostics and audits according to the methods they deem most appropriate to their situation and level of maturity.

Recrutements

Le Groupe BPCE souhaite intégrer les compétences techniques en lien avec l’accessibilité numérique dans les fiches de postes éligibles, ainsi que dans le processus de recrutement des profils correspondants (notamment via des critères dédiés).

Conclusion

Groupe BPCE’s 2025-2027 multi-year plan is intended to reflect the Group’s ambitions in terms of the inclusion of people with disabilities or facing difficulties with digital technology.

Each Group entity is responsible for translating this into annual action plans, which will be reviewed at the end of the corresponding year.

As indicated on several occasions, as this multi-year plan was drawn up during the scoping phase of the Accessibility Program, it is liable to evolve over time to take account of future progress and decisions.