French Residential Accessibility Regulation Explained (2026)

French residential accessibility regulation is governed by three texts that stack together: the arrêté of 24 December 2015, which sets the technical specifications; Loi ELAN of 23 November 2018, which changed who has to meet those specifications; and décret n° 2019-305 of 11 April 2019, which translated ELAN into the Code de la construction et de l'habitation. A fourth text — the arrêté of 11 October 2019 — closes the loop by defining what "travaux simples" means. To verify a residential plan for accessibility compliance in France, you have to read all four, in the right order, and understand how each one limits or extends the others.

This is the order to read them in, what each one actually requires, and where the regulatory stack tends to break down in practice.

The four texts at a glance

The arrêté of 24 December 2015: the technical baseline

The arrêté of 24 December 2015 is the technical reference for residential accessibility in France. It applies to bâtiments d'habitation collectifs (BHC) and to maisons individuelles, and it sets the dimensional and equipment specifications that an accessible apartment has to meet — circulation widths, door widths, turning circles, bathroom layouts, staircase configurations, balcony thresholds, lift specifications, mailbox heights.

The arrêté is structured into articles that each address one aspect of the building: cheminement extérieur, stationnement, accès au bâtiment, circulations communes intérieures (articles 5 and 6), characteristics of the apartments themselves (articles 11 to 15), and the lift and stair specifications inside the common parts. It is the text that says, in effect, "this is what 'accessible' means in numbers".

It applies to permis de construire filed from 1 April 2016 onward (article 16 of the arrêté entered into force the day after publication; the rest, on 1 April 2016). For four years, it was paired with a regulatory regime that required 100% of the apartments in any BHC at ground floor or served by a lift to meet its specifications. That part changed in 2018.

Loi ELAN, article 64: the rule it changed

Loi ELAN of 23 November 2018 is the text most non-specialists associate with the change in residential accessibility regulation. It is not a technical text — it is a primary law that modified article L. 111-7-1 of the Code de la construction et de l'habitation. Specifically, article 64 of ELAN replaced the principle of universal accessibility for BHC apartments with a quota system: 20% of apartments located on the ground floor or served by a lift, and at least one apartment, must be accessible. The other 80% may be "evolutive".

An evolutive apartment, as defined by ELAN and refined in the arrêté of 11 October 2019, is one that a person with a disability can enter, reach the living room and toilet, and exit — and where the rest of the apartment can be made fully accessible through travaux simples carried out later. The principle is visitability at delivery, with full accessibility achievable through a defined set of works.

This part of ELAN entered into force for permis de construire filed from 1 October 2019 — but ELAN itself didn't change the CCH. The CCH was changed by a décret six months later.

Décret 2019-305: how ELAN entered the CCH

Décret n° 2019-305 of 11 April 2019 is the regulatory text that did three things at once. First, it codified the 20%/80% split into article R. 111-18-2 of the CCH — the article a verification team actually reads when checking a residential plan. Second, it lowered the lift installation threshold from R+4 to R+3: for new BHC, a lift is now mandatory when there are more than two storeys above or below the ground floor, with no minimum apartment count. Third, it suppressed the previous obligation, in buildings of more than 15 apartments served only by stairs, to design the building so a lift could be retrofitted without structural modification.

All three changes apply to permis de construire filed from 1 October 2019. The R+3 threshold is the operational consequence that matters most on the floor plate: it mechanically increases the share of apartments that have to be either accessible or evolutive, because more buildings now have a lift, and the 20%/80% rule applies to apartments at ground floor or served by a lift.

The arrêté of 11 October 2019: defining "travaux simples"

The arrêté of 11 October 2019 modifies the arrêté of 24 December 2015 to make it consistent with the new ELAN regime. Its most consequential addition is a definition of "travaux simples" — the works that have to be possible later, in an evolutive apartment, to bring it to full accessibility.

Works qualify as simple, according to the arrêté, when they: have no impact on structural elements; do not require intervention on water drops, fluid supply, or air handling located inside the technical shafts of the building's common parts; do not require modifications to water supply, water evacuation, or gas supply pipes that would themselves require intervention on structural elements; do not affect air intakes; and do not require relocating the apartment's electrical board.

This is the constraint that designers of evolutive apartments have to anticipate at plan stage. The plumbing and structural choices made on day one determine whether the apartment is actually evolutive — or only evolutive on paper.

The 20% / 80% split in practice

For a residential project subject to the post-ELAN regime, the verification questions on the plan are sequenced. First: which apartments are subject to R. 111-18-2 at all? Answer: those at ground floor, and those served by a lift. With the R+3 threshold from décret 2019-305, this captures more apartments than it did before. Second: of those apartments, which 20% (and at least one) are designated as accessible? Third: of the 20%, do each of them meet the full technical specifications of articles 11 to 15 of the arrêté of 24 December 2015 — door widths, circulation widths, turning areas, accessible bathroom, etc.? Fourth: of the remaining 80%, do they meet the evolutive baseline — accessible entry, accessible cheminement to the living room and toilet, accessible toilet, and a design that permits the listed travaux simples later?

The split is not free. The 20% accessible apartments have to be distributed across the building rather than clustered in one corner; the rapport d'évaluation of article 64 noted that distribution practice in the field has been uneven. And the 80% evolutive apartments only count as evolutive if the structural and technical choices on the plan actually leave room for the later works. A plumbing stack placed in the wrong wall, an air shaft running through the apartment, or an electrical board on a wall that would have to move — any one of these can disqualify an apartment from the evolutive category at the verification stage.

Where projects most often go wrong

Across the residential plans we verify in France, the recurring failures tend to cluster in a few places. Several of the most common ones:

Under-counting which apartments fall under R. 111-18-2. Designers sometimes treat the 20%/80% rule as applying to the entire building, when it applies specifically to apartments at ground floor or served by a lift. With the R+3 threshold, many more apartments are in scope than under the pre-2019 regime.

Distributing the 20% poorly. Clustering accessible apartments on one floor or in one wing satisfies the numerical quota but defeats the legislative intent and triggers questions from the bureau de contrôle.

Evolutive apartments that aren't actually evolutive. The travaux simples definition is restrictive. An apartment that requires touching the structure, the technical shafts, or the electrical board to be made accessible later is not evolutive, regardless of what the marketing brochure says.

Dimensional non-conformities in the 20%. Corridor widths, door widths, and turning areas in the accessible apartments still have to meet the arrêté of 24 December 2015. Catching a corridor a few centimetres too narrow on each floor is one of the most common findings on residential plans.

Missing or non-compliant accessible parking and access routes. The arrêté covers more than the apartments themselves. The cheminement from the parking to the entrance, the entrance hall, the lift lobby, the common circulations — all are in scope.

How verification has to be sequenced

Our team verifies residential plans against this stack in the order the texts apply: the legislative framework (CCH L. 111-7-1 as modified by ELAN art. 64), then the regulatory framework (CCH R. 111-5 and R. 111-18-2 as modified by décret 2019-305), then the technical specifications (arrêté of 24 December 2015, as modified by the arrêté of 11 October 2019). Each layer constrains the next. A plan that complies with the technical specifications but misclassifies which apartments are in scope, or that meets the 20% quota with apartments that don't actually satisfy articles 11 to 15, will not pass.

Compliance with French residential accessibility regulation is not a single check against a single text. It is a sequenced verification across four texts that have to be read together.