Where localization is legally required, and where it only looks that way
Vendor pages say the law forces you to localize in named markets. Read the statutes and the regulated object is almost always the commercial material around the product: the advertising, the instructions, the warranty, the contract. Two rules reach the interface itself, and neither is about selling to consumers.
Four questions that get asked as one
The claim turns up on every localization vendor’s site. France requires French. Quebec requires French. Spain requires Spanish. It is presented as the argument that ends the debate, because a statute is not a growth projection you can haggle over.
The claim is true and it is almost never the claim being made. Read the statutes and they are precise about what has to be in the local language, and the software interface is usually not on the list.
Four different questions get compressed into one sentence, and they have four different answers in every jurisdiction:
| Regulated object | Typical example |
|---|---|
| Advertising and marketing | A campaign, a landing page, a spot |
| Packaging and documentation | Instructions, warranty terms, an invoice |
| The software interface | Menus, buttons, dialogs, error text |
| Contracts and terms | Terms of service, an employment contract |
France’s Loi Toubon is the case worth working through, because it is the statute cited most often and it is genuinely broad. Article 2 makes French mandatory “dans la désignation, l’offre, la présentation, le mode d’emploi ou d’utilisation, la description de l’étendue et des conditions de garantie d’un bien, d’un produit ou d’un service, ainsi que dans les factures et quittances”, and the same for written, spoken and audiovisual advertising 1.
That is enforceable, not decorative. The implementing decree makes a breach a fourth-class contravention, and it separately penalises presenting the French version in a way that is not as legible, audible or intelligible as the foreign-language one 2. A bilingual page with the French in grey six-point type is its own offence.
Now the part nobody quotes. The word logiciel does not appear anywhere in the law 1. Neither does interface, menu or screen. The regulated object is the commercial material wrapped around the thing you sell. You can read “mode d’emploi” as reaching software instructions, and it plainly does. Reading it as a rule that every string in a product must be French is a different move, and the statute does not make it.
The one court that ordered a translated interface
There is a French rule that has produced an order to translate software, and it is not in consumer law at all.
Article L1321-6 of the Code du travail says the internal regulations are written in French, and then extends that: “Il en va de même pour tout document comportant des obligations pour le salarié ou des dispositions dont la connaissance est nécessaire pour l’exécution de son travail.” A translation may accompany the French. The exception is narrow: documents received from abroad or intended for foreigners 3.
The article does not say software either. A court applied it to software anyway.
In 2004 the works council, the health and safety committees and a union brought GE Medical Systems before the Versailles court over English-only material at its Buc site. On 11 January 2005 the tribunal ordered the company to make available to its employees in France, without delay, “une version française des logiciels informatiques”, along with French training and health and safety documentation, under a penalty of 20,000 euros per day of delay per non-compliant document. The Cour d’appel de Versailles upheld it on 2 March 2006 and liquidated the accrued penalty at 580,000 euros 4.
The company’s defence was the statutory exception: the material came from abroad and served an international market. The court read the exception narrowly. Documents produced at the French site and used by employees working in France are covered, and the fact that the products are also exported does not move them into the exception 4.
The rule has limits, and the Cour de cassation drew one in 2012. Air France was not required to translate technical material, including e-learning software and manuals, because the international character of the activity requires a common language, under the Chicago Convention and the applicable EU aviation regulation, and because reading English technical documentation is a licensing condition for the job. The court quashed the order to translate without remand 5.
Read those two together and the shape is clear. Working in an international group is not an exemption. A regulated international activity with English written into the licence is. Between them sits most enterprise software sold into France.
The only statute that says the word software
One statute in the set says the word out loud. Quebec’s Charter of the French language, article 52.1: “Tout logiciel, y compris tout ludiciel ou système d’exploitation, qu’il soit installé ou non, doit être disponible en français, à moins qu’il n’en existe aucune version française.” 6
Software, game software, operating systems, installed or not. After two sections of statutes that regulate the packaging, this one regulates the product.
Then read the last clause again. Unless no French version exists. The obligation is to make the French version available, not to create one. A vendor who has never built a French build is outside the rule by its own terms.
What the article actually polices is the gap between versions. Other languages are allowed provided the French version is obtainable on conditions at least as favourable, subject to price where the difference results from a higher production or distribution cost, and provided it has at least equivalent technical characteristics 6.
That is a parity rule, and parity is a distribution question before it is a translation one. Shipping the French build a release behind, putting it on a worse tier, making it harder to get, giving it fewer features: those are the failures the text describes. A company with no French version has nothing to be unfair about. A company with one acquires an obligation the moment it exists.
Public buyers close part of the gap. Article 21.10 requires a public body obtaining a product under a supply contract to ensure the product complies with article 52.1 6. It is a real procurement gate, and it inherits the same proviso: it obliges the buyer to respect 52.1, and 52.1 still excuses the vendor who has no French version. What it stops is selling Quebec the English SKU while a French one exists.
What EU law actually authorises, and what it does not
At EU level the thing people reach for is the Consumer Rights Directive, and it is worth quoting because it is short and it settles the question. Article 6(7): “Member States may maintain or introduce in their national law language requirements regarding the contractual information, so as to ensure that such information is easily understood by the consumer.” 7
Recital 15 says the same thing from the other side: the Directive should not harmonise language requirements applicable to consumer contracts, so Member States may keep or introduce their own for contractual information and contractual terms 7.
Two things follow. The Directive does not itself require any language anywhere; it authorises Member States to. And the object it authorises them to regulate is the contractual information, the Article 6(1) list: main characteristics, trader identity, total price, delivery and payment arrangements, withdrawal rights, guarantees, duration and termination, and, for digital content, functionality and interoperability 7. Every item on that list is something you write about the product. None of them is the product.
Spain is the clean example of a state using the option. Article 60(4) of the consumer code requires that pre-contractual information be supplied free of charge “al menos en castellano”, and in the other official language of the place of contracting if either party asks 8. Mandatory, specific, and about the information rather than the interface.
The pattern holds across the statutes that get cited in this argument. The label, the manual, the warranty, the invoice, the advertisement, the contract. The regulated object is the paperwork.
What this changes about a localization plan
None of this says the law is irrelevant to localization. It says the law is aimed somewhere other than where localization plans point.
Three consequences worth acting on.
The regulated artifacts are mostly not in your app repository. Warranty terms, invoices, the pre-contract information on a pricing page, instructions, the terms of service. Those are owned by legal, finance, support and marketing, and they are usually outside the pipeline that translates the product. A localization programme that ships a perfect French interface and an English invoice has translated the unregulated half.
Interface risk is shaped by who works in the software, not by where it is sold. The French exposure lands on tools used by employees in France, and it arrives through a works council rather than a market. If you sell enterprise software into France, that is a contractual conversation your buyer may have to start, and it is not answered by anything on your pricing page.
A parity rule turns your release process into a compliance surface. Once a French build exists, Quebec’s question is not whether you translated but whether the French version is as available, as current and as capable as the English one. That is a question about release trains and SKUs, and it is one more reason the real cost of a locale is what it costs to keep rather than what it cost to start.
There is a cleaner way to say the whole thing. The statutes regulate the promises you make about a product, and they mostly leave the product alone. The exception is the workplace, where the software stops being a thing sold and becomes the thing someone is required to use.
So the honest version of the legal argument is narrower than the slide and it is sharper. It does not tell you which markets to enter. It tells you which artifacts cannot ship in English once you are there, and, unlike the return figures usually quoted beside it, it can be checked by reading the text.
References
- 1.République française, 1994 Loi n° 94-665 du 4 août 1994 relative à l'emploi de la langue française Article 2 and Article 5, Légifrance
- 2.République française, 1995 Décret n° 95-240 du 3 mars 1995 pris pour l'application de la loi n° 94-665 Article 1, Légifrance
- 3.République française Code du travail, article L1321-6 Version in force since 1 May 2008, Légifrance
- 4.Cour d'appel de Versailles, 2 March 2006 GE Medical Systems SCS c/ Comité d'établissement, RG 05/01344 Légifrance, JURITEXT000006948282
- 5.Cour de cassation, chambre sociale, 12 June 2012 Pourvoi n° 10-25.822, publié au bulletin Légifrance, JURITEXT000026028395
- 6.Gouvernement du Québec Charte de la langue française, articles 52.1 and 21.10, version administrative Ministère de la Langue française, consolidation of 1 June 2022
- 7.European Parliament and Council, 2011 Directive 2011/83/EU on consumer rights Article 6(7) and Recital 15, EUR-Lex
- 8.Reino de España, 2007 Real Decreto Legislativo 1/2007, texto refundido de la Ley General para la Defensa de los Consumidores y Usuarios Article 60(4), BOE-A-2007-20555