Multi-Year Digital Accessibility Plan
1. Accessibility strategy and policy
Matawan’s core purpose is to work toward public-interest mobility that is free, inclusive, and sustainable. Digital accessibility is a fundamental lever to guarantee this free mobility by eliminating barriers for all users.
This plan is established pursuant to Act No. 2023-171 of March 9, 2023 (the DDADUE Act) and Section L412-13 of the Consumer Code, transposing the European Accessibility Act. It aims to bring our products and services into compliance with the requirements of the Ministerial Order of October 9, 2023.
The strategy for the 2026–2029 period prioritizes a risk-managed and user-impact approach:
Priority given to B2C interfaces: efforts are focused primarily on products in direct contact with the general public (Online Store, Ticket Vending Machines).
Accessibility by design approach: accessibility is integrated from the initial design mockups and functional specifications to prevent technical debt.
2. Position and duties of the accessibility officer
The governance of digital accessibility is the responsibility of the Design Department.
Organizational Positioning
The role of Digital Accessibility Officer is held by Léna Carmellino (Design Manager). She acts cross-functionally across the Product, Engineering, QA, HR, Procurement, Marketing, and CSR teams.
Core Duties
Strategic governance: Development and monitoring of the Multi-Year Digital Accessibility Plan and annual action plans.
Technical expertise: Supporting teams in applying the RGAA and coordinating compliance audits.
Awareness and training: Leading internal training sessions and promoting an inclusive corporate culture.
Mediation: Serving as the point of contact for users experiencing accessibility challenges.
3. Human and financial resources
Matawan allocates specific resources to support this initiative over the 2026–2029 period.
Financial Resources
A global estimated budget is planned for the cycle, with an investment peak at launch in 2026.
External budget: Primarily dedicated to compliance audits by third parties (certification) and expert support.
Internal budget: Allocation of time for governance, coordination, internal audits, and internal training.
Human resources
In addition to the officer, operational liaisons are identified within the technical teams (trained Front-End/Back-End developers and QA) to ensure operational implementation.
4. Skills and recruitment
The company integrates accessibility requirements into its HR policy:
Job Descriptions: Proficiency in digital accessibility (RGAA, WCAG) is integrated as a required or preferred skill for technical profiles (Designers, Front-End Developers, QA, Product Owners).
Recruitment Process: Recruiters and technical managers are encouraged to evaluate candidates’ knowledge of accessibility standards during interviews.
5. Training, awareness, and tooling
Internal training and awareness plans
The training and awareness plan aims to develop the skills of all employees and maintain internal expertise throughout the Multi-Year Plan.
Onboarding: Systematic integration of an digital accessibility awareness module for all new hires.
Role-Specific Professional Training:
Targeted training sessions for Design, Product, and QA teams.
Technical training on accessible development practices for Engineering teams.
Specialized training for Procurement and Legal teams regarding accessibility compliance requirements in contract drafting and procurement processes.
Ongoing Awareness: Internal communications, experience sharing, and dedicated workshops during international accessibility days.
Evaluation and deployment of specialized tools
To support teams in their day-to-day operations and automate a portion of the quality control processes, specialized tools are provided:
Design and wireframing: Use of accessibility compliance checking plugins integrated directly into design software (e.g., contrast checkers, reading order tools).
Development and automated testing: Integration of automated accessibility testing libraries into continuous integration (CI) pipelines and browser development tools.
Manual auditing and verification: Provision of screen readers, keyboard-only navigation testing procedures, and color blindness simulators for QA and validation teams.
6. Internal organization and quality control
To guarantee long-term compliance, digital accessibility checkpoints are systematically integrated into our internal production and validation workflows:
Design validation: Mockups must be validated by the Design team using contrast and typography checking tools before being handed over to development teams.
Continuous testing: Accessibility verification tests are incorporated directly into the development phases (code reviews, static code analysis) and regular QA validation processes.
Go-live readiness (Go/No-Go): Accessibility compliance criteria are included in the definition of done (DoD) and final release checklists before any product or feature is deployed to production.
Internal and external compliance control processes
Internal Audits: Regular, targeted verifications conducted internally by trained QA and accessibility liaisons to monitor the progress of remediation plans.
External Certifications: Engagement of independent, specialized third-party experts to perform formal conformity audits and issue official compliance statements.
Reporting: Periodic progress reports submitted to executive management to track the compliance rate across all product lines and dynamically adjust resources if needed.
7. Contracts, procurement and partnerships
Integration into Procurement Processes
Digital accessibility criteria are systematically incorporated into our vendor selection and purchasing workflows for all software, digital solutions, and services:
Request for proposals (RFPs): Accessibility requirements (such as compliance with WCAG or Section 508 / EN 301 549 standards) are included in technical specifications and evaluation grids for prospective vendors.
Vendor assessment: Evaluation of vendor-provided documentation, such as Accessibility Conformance Reports (ACRs) or Voluntary Product Accessibility Templates (VPATs), during the procurement review phase.
Contractual clauses and partnerships
To ensure third-party accountability, specific legal and operational safeguards are integrated into our business relationships:
Contractual requirements: Inclusion of dedicated accessibility compliance clauses in Master Services Agreements (MSAs) and statements of work with IT suppliers, contractors, and agency partners.
Service level objectives: Defining expectations for the prompt remediation of any accessibility barriers identified in third-party deliverables.
Strategic partnerships: Collaborating with technology partners and ecosystem stakeholders to promote inclusive design principles and shared accessibility standards across public mobility solutions.
8. Compliance and remediation work (2026–2029)
Scheduled remediation and development work
Over the 2026–2029 cycle, remediation efforts will be executed through structured development phases to systematically resolve identified accessibility gaps:
Core product remediation: Prioritizing high-impact user interfaces to fix critical accessibility barriers, such as keyboard navigation, missing alternative text, and improper heading hierarchies.
Component library standardization: Upgrading and standardizing the internal design system and shared component libraries to ensure that all future user interface elements are accessible by default.
Incremental implementation: Deploying accessibility patches and code optimizations continuously through regularly scheduled product release cycles.
Handling of Third-Party Extensions and Non-Compliant Elements
When digital products rely on external dependencies or third-party components, specific mitigation strategies are applied:
Vendor accountability: Actively engaging with third-party providers to request accessibility roadmaps and prompt remediation of non-compliant widgets, plugins, or embedded tools.
Alternative solutions: Evaluating and, if necessary, replacing third-party dependencies that fail to meet required accessibility standards with compliant alternatives.
Accessible workarounds: Implementing accessible alternative paths or fallback mechanisms wherever a third-party element cannot be immediately modified, ensuring no user is left without a solution.
Exception management and justifications
In exceptional circumstances where full compliance cannot be achieved, deviations are strictly managed and documented:
Disproportionate burden assessment: Formally documenting cases where achieving full compliance would impose an administrative, financial, or technical burden that is genuinely disproportionate to the benefit provided, in accordance with applicable regulatory frameworks.
Scope exclusions: Clearly identifying and justifying legal or technical exclusions, such as legacy archived data, third-party content out of corporate control, or specific complex map interfaces.
Alternative access channels: Establishing and publishing clear, alternative communication channels to assist users who encounter an authorized exception, ensuring they can obtain the required information or service through other means.
9. Review of action plans
Annual review and status update
At the end of each calendar year, a formal evaluation is conducted to measure the progress of the annual action plan:
Performance metric tracking: Assessing the actual completion rate of scheduled remediation tasks against the objectives set at the beginning of the year.
Compliance level evolution: Updating the accessibility score of each digital interface based on internal verifications and post-remediation audits.
Reporting: Documenting the achievements, identifying any delays, and publishing the mandatory annual update as required by regulatory frameworks.
Ongoing risk and impact management
To ensure the multi-year strategy remains effective, operational risks are continually assessed and managed:
Prioritization adjustments: Dynamically reallocating development resources based on user feedback and the real-world impact of remaining accessibility barriers.
Technical debt monitoring: Tracking new feature deployments to ensure no new accessibility issues are introduced into the codebase.
Strategic alignment: Adapting the upcoming annual action plans to account for organizational changes, technological shifts, or updated regulatory guidelines.
10. Contact and accessibility officer
Contact information
For any inquiries regarding this Multi-Year Plan, to report an accessibility barrier, or to request an accessible alternative for content that is currently unavailable, users may contact Matawan through the following channels:
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Contact person: Léna Carmellino
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Title: Digital Accessibility Officer / Design Manager
Feedback and alternative access channels
Matawan is committed to ensuring that all users have equal access to our digital services. If you encounter an accessibility issue, we pledge to provide assistance and direct you to an alternative method for obtaining the information or service you require.
