Since May 2024, the legal basis for legal notices has changed. The SREN law has recodified the obligations for identifying website publishers, replacing the old article 6 III of the LCEN with new articles 1-1 and 1-2 of the LCEN. Most online guides have not yet integrated this overhaul. Understanding this new framework is a prerequisite for any website publisher, whether it is a personal blog or an e-commerce platform.
SREN Law and New Articles of the LCEN: What Changed in 2024
Article 48 of law n° 2024-449 of May 21, 2024 (known as the SREN law) introduced a clear distinction between two obligations that were previously grouped together. Article 1-1 of the LCEN now exclusively addresses the identification information that the publisher must make accessible. Article 1-2, on the other hand, sets the applicable criminal penalty in case of non-compliance.
This separation is not cosmetic. It clarifies the reading of the text for legal professionals as well as for non-legal publishers. The penalty regime, which came into effect on May 23, 2024, provides for 1 year of imprisonment and a fine of 75,000 euros for an individual who fails to comply with the identification obligation.
A site that still references the old article 6 III in its legal notice page is not in violation as long as the required information is present. However, citing an abrogated legal basis may pose a credibility issue, especially in front of a partner or an investor who would check the site’s compliance.
Consulting the legal notices of Mon Coach A Domicile provides a concrete overview of how this information can be structured on a professional site.
Mandatory Legal Notices: Specific Content According to the Publisher’s Status
The required content varies depending on whether the publisher is an individual or a legal entity. Confusions remain frequent, particularly for micro-entrepreneurs who omit certain elements.
Individual (sole proprietor, micro-entrepreneur)
- Name, surname, and address, accompanied by the mention “sole proprietor” or the initials “EI” for sole proprietors
- Email address and phone number allowing contact with the business
- Registration number with the RCS and VAT identification number
- Identity of the site’s host: name or company name, address, and phone number
- For regulated activities (pharmacy, beverage sales): name and address of the authority that issued the authorization
Legal Entity (company)
Companies must indicate their company name, legal form, and amount of share capital, in addition to the address of the registered office and contact details. The RCS number, intra-community VAT number, and information about the host remain the same.
The omission of the host’s identity is the most common oversight on small business websites. Many believe that this mention only concerns large sites, while it applies to all without exception.
Digital Accessibility and E-commerce Legal Notices Since June 2025
The European directive 2019/882, transposed into French law by law n° 2023-171 of March 9, 2023, has extended digital accessibility obligations to e-commerce sites aimed at consumers since June 28, 2025. This obligation, previously reserved for the public sector, now concerns private online shops.
The DGCCRF is responsible for monitoring these commercial sites. Sanctions take the form of 5th class fines that can reach 7,500 euros per violation for a company, and they are cumulative. An e-commerce site that does not comply with accessibility standards thus faces significant fines, in addition to sanctions related to the legal notices themselves.
For publishers of commercial sites, this means that the legal notice page must also include an accessibility statement. Field feedback varies on the level of detail expected in this statement, but the DGCCRF has begun to carry out targeted checks.
Personal Data and Cookies: Articulating Legal Notices and GDPR Compliance
Legal notices are not limited to the publisher’s identity. Any site that collects personal data must inform the user of the purpose of this collection, the legal basis for processing, the recipients of the data, and the rights they have (access, rectification, deletion).
This information can be included in a separate privacy policy or directly on the legal notices page. The key is that they are visible and accessible within two clicks maximum from any page of the site.
Regarding cookies, the publisher must specify the purposes of each category of cookies used and allow the user to accept or refuse them granularly. A simple banner stating “This site uses cookies” without an option to refuse has not been sufficient for several years.
- Strictly necessary cookies: no consent required, but information is mandatory
- Analytical and advertising cookies: explicit prior consent required
- Third-party cookies: identification of the recipient and purpose in the privacy policy
Intellectual property is also part of the mentions that should not be overlooked. If the site uses images, illustrations, or texts from third parties, the source and intellectual property must be indicated. The absence of credit can engage the publisher’s liability.
Sanctions and Controls: An Underestimated Risk by Small Publishers
Failure to comply with identification obligations exposes one to criminal prosecution. With the recodification resulting from the SREN law, the penalty is clearly defined: one year of imprisonment and a fine of 75,000 euros for individuals. Legal entities face fines that are five times higher according to the usual rules of criminal law.
In practice, prosecutions remain rare for low-traffic sites. The available data does not allow for conclusions about the actual frequency of targeted checks specifically focusing on legal notices. However, a commercial dispute or a conflict with a client may lead a judge to highlight the absence of legal notices as an aggravating factor.
The cost of compliance is, however, low. Drafting a complete legal notice page takes a few hours at most, and the required information is available in the company’s administrative documents. Delaying this formality exposes one to a disproportionate risk compared to the effort required.