Arcom formally notifies publisher 3L to deposit its files

Arcom (the Regulatory Authority for Audiovisual and Digital Communication) has issued a formal notice to the company 3L to deposit the digital files of 80 works with the Bibliothèque nationale de France (BnF), intended to facilitate access for people with disabilities. The decision, signed on July 22, 2026, is published in the JORF No. 0205 of September 3, 2026, under the reference Decision No. 2026-430 (NOR RCAC2621213S). The publisher has a period of two months from the date of notification to comply, failing which sanctions may be imposed.

A Legal Framework Dedicated to Accessibility

The formal notice is based on the Intellectual Property Code (CPI). Pursuant to Part II of Article L. 331-31, Arcom participates in the mission of facilitating access for disabled persons to protected works and may issue formal notices to publishers to comply with their obligations. Paragraph 2° of Article L. 122-5-1 requires publishers to deposit the digital file of their works with the BnF in a format that facilitates the production of adapted documents, which the library then makes available to accredited organizations.

Article R. 122-19 of the CPI specifies that the publisher must transmit the file within forty-five days following the request. This obligation has been in effect since January 1, 2022, the date of application of Law No. 2021-1382 of October 25, 2021.

Requests Left Unanswered Since 2023

The BnF notified Arcom, via emails dated April 8, 2024, and May 27, 2025, of deposit requests made in 2023 and 2024 that remained unanswered. The Authority sent several regularization letters to the company 3L, notably on October 1, 2024, and July 25, 2025, all of which remained unanswered. A hearing, proposed by letter on February 11, 2026, did not take place.

According to data provided by the BnF (as of February 20, 2026), the company 3L has not responded to any of the deposit requests. The total number of unsatisfied requests thus amounts to 80 works since the obligation came into force:

• 16 requests made in 2023;
• 4 requests made in 2024;
• 60 requests made in 2025.

Titles from the “Les Liens qui libèrent” Collection

The works concerned, listed in the annex of the decision, belong notably to the “Les Liens qui libèrent” collection (identified by the initials “RL” in the titles). Examples include:

• Technofeudalism – Les nouveaux serfs de l’économie;
• Petites précisions sur la fin du monde;
• Les démantèlements qui viennent : appel au désarmement des mondes;
• La civilisation judéo-chrétienne : anatomie d’une imposture;
• Palestine : un peuple qui ne veut pas mourir.

The files must be deposited on the BnF’s PLATON platform. The decision will be notified to the company 3L and published in the Official Journal as well as on the Arcom website.

A procedure that may lead to sanctions

This formal notice constitutes the final step of a graduated procedure initiated in 2023. In the event of failure to comply within the two-month deadline, Arcom may impose sanctions against the publisher. For readers, the stakes are concrete: the deposit of these digital files is a prerequisite for the production of adapted versions (audio, braille, large print) allowing disabled people to access the works published by the publishing house.

Official source: Official Journal of the French Republic (JORF) No. 0205 of September 3, 2026 — Decision No. 2026-430 of July 22, 2026, issuing a formal notice to the company 3L (NOR RCAC2621213S).