Legal

RGAA: France's Accessibility Requirements

February 18, 20257 min read

The RGAA (Referentiel General d'Amelioration de l'Accessibilite) is France's national accessibility standard for digital services. Originally published in 2009 and updated to version 4.1 in 2021, the RGAA translates the international WCAG guidelines into a French regulatory framework with specific testing criteria, compliance obligations, and penalties. With the enforcement of the European Accessibility Act in June 2025, the RGAA has become more relevant than ever for businesses operating in France.

Who Must Comply with the RGAA?

The RGAA applies to a broad range of organizations operating in France:

  • Public sector — All government websites, public institutions, local authorities, and organizations carrying out a public service mission. This has been mandatory since 2012.
  • Large private companies— Companies with annual revenue above 250 million euros. This threshold was established by the 2019 law "pour une Republique numerique."
  • Private companies under the EAA — Since June 2025, the EAA extends accessibility obligations to all private companies providing digital services to EU consumers, with the exception of microenterprises.

RGAA and WCAG: The Relationship

The RGAA is not a separate standard from WCAG — it is a French interpretation and operationalization of WCAG 2.1 Level AA (with updates aligning toward WCAG 2.2). The RGAA translates WCAG's abstract success criteria into 106 concrete, testable criteria organized into 13 thematic areas:

  1. Images
  2. Frames
  3. Colors
  4. Multimedia
  5. Tables
  6. Links
  7. Scripts
  8. Mandatory elements (doctype, language, title, etc.)
  9. Information structure (headings, lists, landmarks)
  10. Presentation of information (CSS, layout)
  11. Forms
  12. Navigation
  13. Consultation (documents, downloads, time limits)

Each criterion includes specific testing methodology — exactly which elements to check, which tools to use, and what constitutes a pass or fail. This makes the RGAA more prescriptive than WCAG itself, which can be an advantage for development teams that need clear, unambiguous testing instructions.

Compliance Obligations

French law requires organizations subject to the RGAA to fulfill several specific obligations beyond simply making their website accessible:

Accessibility Statement

Every covered website must display a publicly accessible accessibility statement ("declaration d'accessibilite"). This statement must include the compliance status (fully compliant, partially compliant, or non-compliant), a list of non-accessible content with explanations, the date of the last audit, and contact information for accessibility feedback. The statement must be linked from every page, typically in the footer.

Multi-Year Accessibility Plan

Public sector organizations must publish a multi-year accessibility plan ("schema pluriannuel") describing their strategy for achieving and maintaining compliance. This plan must be updated annually.

Compliance Rate Display

Websites must display their RGAA compliance rate on the homepage. The rate is calculated as the percentage of RGAA criteria that are met. A site is considered fully compliant at 100%, partially compliant between 50% and 99%, and non-compliant below 50%.

Penalties

France has some of the most concrete accessibility penalties in Europe. The 2023 decree strengthened enforcement:

  • Failure to display an accessibility statement: fine of 20,000 euros per year per site.
  • Failure to publish a multi-year plan (public sector): fine of 50,000 euros.
  • Non-compliance with RGAA criteria: fines up to 50,000 euros per violation, with the ARCOM (France's digital regulator) empowered to conduct audits and issue penalties.

Beyond direct fines, non-compliance creates legal liability. French case law has seen increasing discrimination claims filed against organizations with inaccessible digital services.

How to Achieve RGAA Compliance

The path to RGAA compliance follows a clear process:

  1. Conduct an RGAA audit — Test your website against all 106 criteria. This can be done internally if you have trained accessibility specialists, or by engaging a certified third-party auditor.
  2. Deploy immediate fixes — Address the most impactful violations first. Automated tools and accessibility widgets can fix common issues like missing alt text, low contrast, and missing form labels immediately.
  3. Publish your accessibility statement — Even if your compliance rate is low, publishing a transparent statement is legally required and demonstrates good faith.
  4. Remediate remaining issues — Work through structural violations that require code changes. Prioritize by impact on users with disabilities.
  5. Monitor and maintain — Every content update, design change, or new feature can introduce accessibility regressions. Continuous monitoring is essential.

RGAA in the Context of the EAA

With the EAA now in force, the RGAA is no longer just a French public sector concern. Any company serving French consumers must meet WCAG 2.2 AA, and the RGAA provides the most detailed testing methodology available in the French legal context. Organizations that achieve RGAA compliance can be confident they meet both French national requirements and EU EAA obligations.

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