What are the legal obligations for French regions?

In France, Regions are the designated leaders for multimodal passenger information through the Mobility Orientation Law (LOM). They are also subject the provisions of the European regulatory framework, particularly when it comes to opening their multimodal mobility data. Below, a short summary of their legal obligations.

Overview of the legal framerwork

Directive 2010/40/EU (https://eur-lex.europa.eu/legal-content/FR/TXT/PDF/?uri=CELEX:32010L0040) of the European Parliament and of the Council of 7 July 2010, known as the “ITS Directive”, establishes guidelines for the deployment of intelligent transport systems in order to achieve optimal use of infrastructure and thus limit the social and environmental externalities associated with its use. This directive serves as a framework for several delegated regulations, which are directly applicable in France.

For multimodal mobility data, it is the Commission Delegated Regulation (EU) 2017/1926 of 31 May 2017, known as the “MMTIS Delegated Regulation” (MultiModal Travel Information Services) and its amended version, Commission Delegated Regulation (EU) 2024/490 of 29 November 2023, which lists the categories of data to be published in open data and the formats for their publication. We recommend that you refer to the consolidated version of the two texts for a better overview.

These European obligations are specified and supplemented in French law by Articles 25 and 27 of Law No. 2019-1428 of 24 December 2019 on mobility orientation (LOM), codified in Articles L. 1115-1 to L. 1115-5 of the Transport Code for Article 25 of the LOM, and in Articles L. 1115-6 and L. 1115-7 of the same code for Article 27.

The right to passenger information is stated in the Transport Code

In general terms, the Transport Code states: “The right to mobility includes the right of users to be informed about the means of transport available to them and how to use them.” (Art. L.1111-4 of the Transport Code).

More specifically, Regions must ensure “the existence of an information service for users covering all modes of transport within their territory. Where applicable, they shall also ensure that their information service meets the accessibility requirements for persons with disabilities, under the conditions set out in Article 47 of Law No. 2005-102 of 11 February 2005 on equal rights and opportunities, participation and citizenship for persons with disabilities.” (Art. L.1115-8 of the Transport Code).

Said in other terms, Regions should have trip planners made available for all. And, these trip planners should showcase accessibility details.

The collection of accessibility data is subject to additional provisions

Local authorities are required to collect accessibility data for their territory in order to guarantee everyone’s right to mobility and to feed trip planners.

• For transport (Art. L. 1115-6 and D. 1115-9): collection of data on the accessibility of conventional public transport services to persons with disabilities or reduced mobility within a radius of 200 metres from priority stops
• For roads (Art. L.141-13 and R. 121-24 of the Urban Roads Code): collection of data on the accessibility of the main pedestrian routes within a 200-metre radius of main public transport stops for persons with disabilities or reduced mobility
• For both, a joint decree specifies the mandatory information to be collected: the decree of 28 May 2024 on provisions for collecting data on accessibility in transport and roads

Further details can be found in the decree of 28 May 2024 relating to provisions for the collection of “accessibility” data in transport and on public roads for the travel of persons with disabilities or reduced mobility, pursuant to Articles L. 1115-6, L. 1115-7, D. 1115-9 and D. 1115-10 of the Transport Code, Articles L. 141-13 and R. 121-24 of the Road Traffic Code.

For further information, we recommend that you explore the documentation made by the French National Access Point.

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