French municipal legal notice requirements: what decree 2021-1311 says

What the reform of 7 October 2021 changed, and for whom

Until 2022, French municipal legal notices were published on a noticeboard: the formality was discharged by posting the act at the town hall. Two instruments of 7 October 2021 shifted where that happens — ordonnance n° 2021-1310 and décret n° 2021-1311, which completes the ordonnance and spells out the practical arrangements. Since 1 July 2022, communes of 3,500 inhabitants or more publish electronically their regulatory acts and those that are neither regulatory nor individual, and that publication is what discharges the formality. Paper posting is no longer mandatory for them.

This is not a cosmetic simplification. The official channel changed in kind: from a physical medium, present in one place, readable during opening hours, to an online one that is permanent and downloadable. The obligations attached to it changed with it.

One thing the reform did not touch: access to paper. Per Maire-info, reporting on the text on 8 October 2021, the ordonnance pairs electronic publication with an obligation to supply the act on paper to any citizen who asks for it. The reform changed the default channel; it did not remove paper access. That point is carried by the ordonnance, not by the decree.

The commune's website is the only mandatory channel

The text names the local authority's own website, and nothing else. The Association des maires de France and the Centre de gestion du Lot describe the mechanism in the same terms: online publication, on the site of the authority concerned, is what discharges the formality. Neither the text nor those guides mentions a screen, a totem or a kiosk as an equivalent channel.

A second consequence, less often noticed: the obligation cannot be delegated to a third-party platform. Each commune publishes its own acts on its own website. The decree centralises nothing and provides for no shared portal.

The whole act, a fixed format, two months, and who issued it: four precise requirements

Publishing online does not mean putting a PDF somewhere. The decree sets concrete conditions, and they are what compliance actually consists of:

• The act in its entirety. A summary, an extract or a notice does not satisfy the obligation.
• A non-modifiable format, under conditions guaranteeing preservation, integrity and the ability to download the document. CDG46 recommends PDF for that reason.
• A minimum of two months online.
• Identifying details: the name of the authority that issued the act, and the publication date.

All four are corroborated by the primary text, by the national association of mayors (AMF) and by a departmental centre de gestion (CDG46). They are also where a commune is most easily caught out, because they are procedural: intending to comply is not enough, the file itself has to comply.

Under 3,500 inhabitants, syndicats, EPCI: three different situations

The 3,500-inhabitant threshold is not the only dividing line. Three cases are distinct, and they are regularly confused.

Communes under 3,500 inhabitants keep a real choice. They may keep paper publication — acts being kept available to the public at the town hall, permanently and free of charge — or opt into electronic publication. The choice is reversible.

Joint local-authority bodies — syndicats — fall under a conditional regime. Per the AMF briefing, they follow the smaller-commune rules only if their governing committee formally deliberated the choice before 1 July 2022. Absent that deliberation, electronic publication applied by operation of law.

EPCI with their own tax base publish on the EPCI's website — an EPCI being a body that groups several communes together — and not on the site of each member commune.

Where an interactive kiosk genuinely fits

If the website is mandatory, what is a screen in the town hall lobby for? For what the website does not do: reaching the residents who do not go to the website.

ATD13 — the departmental technical agency of the Bouches-du-Rhône, which provides free legal counsel to communes — writes it without ambiguity: a commune may use an interactive kiosk for digital legal-notice display, covering both regulatory acts and non-regulatory, non-individual ones. It adds two practical conditions:

1. Placement. Inside the town hall — entrance hall or reception — or outside, near the building's access point, chosen so that it is seen.
2. Digital accessibility of the content displayed. This is not a nice-to-have: see the next section.

The reasoning behind the kiosk is not a legal one, and it is not ATD13's either: it is ours. Some residents have no internet access at home. A freely accessible screen, during the hours the building is open — or from the square outside — gives them a way back in.

There is a second reason: an interactive kiosk does better than a board with sheets of paper pinned to it. For the town hall's staff, publication is centralised and handled remotely: an act is uploaded once and shows on screen, with no printing, no trip to the board and no drawing pin, and acts that have passed their end date stop appearing on their own rather than being taken down by hand. For the resident, acts are sorted into categories and can be searched, where a board means scanning a wall of paper; an older act stays consultable for as long as it has to be.

Digital accessibility is a condition, not a footnote

Here the subject is no longer decree 2021-1311 but the RGAA, France's general accessibility reference framework, grounded in Article 47 of loi n° 2005-102, France's law on equal rights and on the participation and citizenship of people with disabilities. It binds public bodies — a town hall is obviously one — but also organisations delegated a public-service mission, and some private ones (public-interest criteria, or annual turnover above €250M).

DINUM's official page on the RGAA's scope is precise on two points most commercial content leaves vague:

• Mobilier urbain numérique — digital street furniture, which covers interactive kiosks and self-service terminals — appears explicitly in the scope.
• The obligation covers the application or interactive layer of the kiosk, excluding the operating system and the hardware. In other words: the interface, not the enclosure.

And it names the standard: EN 301 549 V2.1.2 (2018-08), or equivalently WCAG 2.1 levels A and AA. A disproportionate-burden exemption exists, but it is assessed function by function rather than across the whole kiosk, and it assumes an accessible alternative is offered where that is feasible.

That is good news for a town hall writing a specification: "accessible" is an unverifiable promise; "conformant to EN 301 549 V2.1.2 / WCAG 2.1 AA on the interactive layer" is a requirement that can be checked.

RGAA or the European Accessibility Act? Do not conflate the two regimes

The confusion is common and it is costly, because it points people at the wrong obligation.

Temesis, a French digital-accessibility consultancy, draws the line: the RGAA binds public bodies — and, as above, public-service delegates and very large companies; the European Accessibility Act, which was transposed into the French Consumer Code and whose sanctions have applied since 28 June 2025, covers private business-to-consumer services. Two independent legal analyses set out which self-service terminals that second track has in mind: the international firm Covington & Burling names ATMs, and the French firm August Debouzy adds payment terminals.

For a legal-notice kiosk installed by a commune, the applicable regime is the RGAA. The EAA is a neighbouring regime worth knowing about, not the legal basis to cite.

What this means for a commune in practice

Three decisions follow from all of the above, and they are taken in this order:

1. Secure the online publication first: entirety, non-modifiable format, downloadable, two months minimum, identifying details. That is what constitutes compliance.
2. Then decide whether a physical channel is useful, given who is actually affected: residents without internet access, those who walk past the town hall without going in, those looking for one specific piece of information.
3. Write accessibility into the specification, for the website as much as for the kiosk, naming the standard rather than the intention.

That is the basis on which Touchify works with local authorities. The Affichage Légal application publishes documents to two places at once: the touch kiosk, where a citizen consults, searches and downloads without entering any personal information, and the authority's own website, which it integrates into directly. An import certificate is generated for every document uploaded. The website remains the channel that constitutes compliance — the advantage is that nobody has to feed two systems separately. The wider public-sector offer sits on the public sector solutions page.

On an adjacent question, the one-stop shop in a town hall frames the same trade-off from another angle: which service belongs at the counter, and which belongs online.

Frequently asked questions

Sources for this article

• Décret n° 2021-1311 of 7 October 2021, published in the Journal officiel of 8 October 2021 — text on Légifrance. Accessed 22 July 2026. (Ordonnance n° 2021-1310 of the same day, which this decree completes, is a separate instrument with its own identifier: this link points to the decree only.)
• Maire-info, a daily news outlet for French local elected officials, 8 October 2021 — the end of mandatory paper posting for communes over 3,500 inhabitants. Accessed 22 July 2026.
• Association des maires de France (AMF), briefing of 15 April 2022 — reform of the publicity and entry into force of local-authority acts. Accessed 23 July 2026.
• Centre de gestion de la fonction publique territoriale du Lot (CDG46) — the obligation to publish local-authority acts on their website. Page undated, accessed 23 July 2026.
• ATD13, departmental technical agency of the Bouches-du-Rhône, 11 December 2024 — is digital legal-notice display via interactive kiosks possible? Accessed 24 July 2026.
• DINUM, official page on the RGAA's scope — accessibilite.numerique.gouv.fr. Page undated, referencing RGAA v4.1.2; a version 5 was in preparation for the end of 2026. Accessed 27 July 2026.
• Temesis, digital-accessibility consultancy, published 23 October 2023 and updated 7 July 2025 — synthesis of the regulations governing digital accessibility in France. Accessed 27 July 2026.
• August Debouzy, French law firm, 11 July 2025 — entry into force of Directive (EU) 2019/882 on accessibility. Accessed 27 July 2026. (On the EAA's scope and the self-service terminals it covers.)
• Covington & Burling LLP, international law firm, 10 June 2025 — European Accessibility Act: the June 2025 deadline has arrived. Accessed 27 July 2026. (Same point, second independent source.)