PMR Accessibility Verification in Design Phase: A 2026 Guide

French accessibility regulation for new residential buildings is not a single rule. It is a stack of texts — the Code de la Construction et de l'Habitation, the arrêté du 24 décembre 2015, the décret 2015-1770, the Loi ELAN of 2018, the décret 2019-305 of 11 April 2019, and the arrêté du 11 octobre 2019 modifying the 2015 arrêté — that together define what an accessible residential building must do, room by room, dimension by dimension. Verifying compliance against that stack on a real set of plans is not a matter of running a checklist. It is the work of resolving each dimension on the drawing against the specific clause of the specific text that governs it, in the right sequence, before the permis de construire is filed.

This article walks through how that verification actually works in design phase on a French residential project. What gets checked, against which regulation, and where the recurring errors hide. It is written from the verification side of the table — what we look for, how we trace each finding back to its regulatory anchor, and what a Director of Projects can do with the report before the permit is submitted.

The regulatory stack that governs PMR accessibility

For residential buildings (bâtiments d'habitation collectifs neufs and maisons individuelles neuves), the relevant texts are organised in layers. The CCH provides the framework. The arrêté du 24 décembre 2015 provides the operational requirements — door widths, rotation circles, kitchen passages, outdoor paths. The décret 2015-1770 of the same date reorganised the regulatory architecture in the CCH. The Loi ELAN, adopted 23 November 2018 as loi n° 2018-1021, introduced the concept of logement évolutif, recalibrating which apartments must be fully accessible from day one and which must be designed to be made accessible later through simple works. The décret 2019-305 of 11 April 2019 operationalised that recalibration and applies to all building permits filed from 1 October 2019. The arrêté du 11 octobre 2019 modified the 2015 arrêté to match.

For verification purposes, this means every accessibility finding on a residential plan has to be tied back to one of these texts, with the article number cited. A finding without a regulatory anchor is not actionable. A regulatory citation without a corresponding plan reference is not auditable. The verification report has to do both.

What actually gets checked in design phase

The work proceeds in roughly the order a wheelchair user would encounter the building, from the property line inward. Five zones do most of the work.

1. Cheminement extérieur — the outdoor accessible path

From the property entrance to the building entrance, and from the building entrance to common parking, bin storage, bike storage, and any collective equipment. The arrêté du 24 décembre 2015 sets a minimum width of 1.20 m free of any obstacle. The path must be horizontal and without ressaut where possible; where a level change is unavoidable, the slope cannot exceed 5%, with exceptional tolerance up to 8% over 2 m or 10% over 0.50 m. Any ressaut over 2 cm requires treatment — a chanfrein for ressauts up to 4 cm where the chanfrein slope does not exceed 33%, a ramp above that; ressauts in series ("pas d'âne") are prohibited.

On the plan, this is checked against the site plan and the ground floor plan together. The two most common errors we see are slopes drawn at 5% nominal that exceed it on grade calculation, and pinch points (a planter, a column, a step) reducing the effective width below 1.20 m at a critical pass.

2. Entrée du bâtiment — the building entrance

The door itself, the door's clear approach, the maneuvering space inside and out. The entrance door has a nominal width of 0.90 m and must offer a passage utile (clear opening with the door swung to 90°) of 0.83 m minimum. A maneuvering space is required immediately inside and outside the door, with the dimensions defined in annexe 2 of the 2015 arrêté.

This is where two-dimensional CAD drawings hide three-dimensional problems. A door drawn at 0.90 m on plan does not guarantee a 0.83 m passage utile once frame, hinges, and door hardware are accounted for. We measure the modelled passage, not the labelled dimension.

3. Circulations intérieures and porte palière — interior circulation

Common circulation in collective housing must be 1.20 m wide minimum. Inside the apartment, interior circulation is 0.90 m minimum, interior doors are 0.80 m nominal (0.77 m passage utile). The apartment entrance door requires a maneuvering space on the interior side.

The recurring error here is interior doors drawn at 0.80 m that produce a passage utile below 0.77 m because of door thickness or hinge offset, particularly on pre-hung doors where the manufacturer specification reduces the clear opening below the nominal frame width.

4. Sanitaires PMR, salle d'eau, chambre — rotation areas inside the unit

For apartments designated accessible from day one (ground floor units and units served by lift, per the post-ELAN rules), the salle d'eau must offer a clear rotation space of 1.50 m diameter. At least one chambre must offer the same — outside the door's débattement and outside the lit's emprise (with the lit dimensioned at a minimum 0.90 m × 1.90 m for a single, 1.40 m × 1.90 m otherwise). The cuisine must offer a 1.50 m clear passage between appliances, fixed furniture, and walls. Partial overlap with the door's débattement is allowed up to 25 cm; partial overlap with the space under a sink is allowed up to 15 cm.

The dominant error category in this zone is rotation circles that fit on plan only because the door is drawn closed. Open the door in the model, and the circle is gone. We test every rotation circle with the door at full débattement.

5. Balcons, terrasses, loggias

Where the balcon, terrasse, or loggia has a depth over 60 cm and serves an accessible apartment, the access must be at least 0.80 m wide, the threshold height must be ≤ 2 cm, and an installation reserve must be provided for a future ramp or vertical lift where the level difference exceeds 4 cm. The reserve has its own geometry — 0.80 m wide, length sufficient for a ramp at 10% over 2 m maximum or 12% over 50 cm maximum.

This is the zone where verification most often produces findings that surprise the design team. Threshold heights are a finish-level item, often not resolved until later phases, but the arrêté governs them.

How the verification stack compares to alternative approaches

French residential plans are typically checked through three approaches, with different coverage, sequencing, and intent. Below is the comparison treated honestly. Freeda appears as one option.

The three approaches are complementary more than competitive. The bureau de contrôle still attests for the permit and the insurance regime. The in-house team still owns design quality. Full-coverage verification compresses the design-phase error-catching loop from weeks to hours, which is where the financial asymmetry lives.

Why design phase is the only phase that matters for errors

An accessibility error caught on a drawing is a redraw. The same error caught on site is a saw cut, a relocated door, a reconfigured bathroom, sometimes a redesigned floor plate. The cost ratio between the two is not 10x; it is closer to 100x or worse, and the time loss is measured in months. Full-coverage design-phase verification exists for that asymmetry — to catch the corridor 12 cm too narrow, the rotation circle that fails with the door open, the threshold drawn at 3 cm instead of 2 cm, before any of it reaches grade.

Accessibility is consistently among the most common error categories we surface on French residential plans, and most errors we find are structural to the plan rather than isolated — when a corridor is too narrow at one floor, it is typically too narrow at every floor of that stack, and a rotation circle that fails in one accessible unit typically fails in the others of the same typology. The verification report's job is to identify the pattern and locate every instance.

What a clean accessibility verification report looks like

Each finding cites the regulation (which article of the 2015 arrêté, modified where applicable by the 2019 arrêté), locates the non-conformity on the plan (which sheet, which axis, which room), states the measured value against the required value, ranks the impact (blocking for the permit, blocking for the accessibility attestation, blocking only for the future logement évolutif adaptation), and proposes the remediation. The report is the document the design team uses to redraw, and the document the bureau de contrôle reads alongside the plans at attestation time.

For a Director of Projects, the deliverable is two things. A list of what to fix before the permit is filed. And a register of what was checked, against what text, with what result — auditable later, when the project moves to construction and the same plans become the basis for site verification.