The RGAA Compliance Explained: France's Web Accessibility Framework

Last reviewed: 17 September 2026

Legal review: Cecilia Pirchio

Accessibility review: Jacopo Deyla, accessibility expert

The RGAA is the French framework for evaluating whether a digital service can be used by people with disabilities. It turns accessibility requirements into 106 testable criteria for web content, a defined method, and a set of documents you publish. This page explains what it covers, who it applies to, how compliance is measured, and what changed in August 2026.

RGAA at a glance

What the RGAA is, and what it's for

The RGAA gives everyone the same method for checking whether a website or web application works for people using different access methods and assistive technologies. Two teams auditing the same site against the same criteria should reach the same result, and that's the point of it.

The RGAA isn't a law in itself. The obligations come from Article 47 of Law No. 2005-102 and its implementing texts. What the RGAA adds is the translation layer: it turns legal requirements into criteria, tests, results, and documents you can actually produce and publish.

DINUM, the French interministerial digital directorate, publishes the framework, the official website, the criteria and tests, the audit kit, and the reference documents.

Who must comply with the RGAA?

Scope depends on your status, your activity, your relationship with a public body, your revenue, and the type of service concerned. Publishing a website in French doesn't put an organization in scope on its own.

If you sell to consumers in France, assess your European Accessibility Act obligations separately. The two regimes share technical references, but they aren't the same legal framework, and a company can fall under both.

Which digital services are covered?

Two things get merged here. One is which services the law requires to be accessible. The other is which technical framework you use to evaluate them. The answers are not the same.

What the law covers. Article 47 and Decree No. 2019-768 apply to online public communication services:

• websites, intranets, and extranets;

• mobile applications;

• software packages, when they are used through a web browser or a mobile application;

• digital street furniture, for its applicative or interactive functions.

What the RGAA tests. The RGAA is the evaluation method for web content. Its 106 criteria are written for websites, web applications, intranets, extranets, and the documents and media published inside them, including downloadable office files and audio and video content.

For mobile applications, software packages, and digital street furniture, the RGAA does not define an evaluation method. DINUM is explicit about it: where the RGAA does not define the method, the one from the European directive applies, through EN 301 549.

So an organization can be fully in scope of the law for its mobile app and have nothing in the RGAA to test it against. Closing that gap is part of what RGAA 5 is for.

In everyday use in France, "RGAA" gets applied to all of it. That is fine in conversation. It is not fine in an audit report, an accessibility statement, or a tender response, where naming the wrong reference framework undermines the result.

The evaluation shouldn't stop at the homepage. Page templates, reusable components, forms, authenticated areas, transaction journeys, documents, media, third-party content, and essential functionality all belong in scope. Define that scope before the audit starts, and document it in your results and your accessibility statement.

What are the 106 RGAA criteria, by theme

RGAA 4.1.2 organizes 106 control criteria into 13 themes. Each criterion comes with its own tests, so an auditor can determine whether it applies, whether it's met, and what evidence supports the result.

For the full wording, the tests, and the special cases, the official RGAA criteria and tests page is the reference.

What the RGAA requires beyond a score

A reliable RGAA evaluation needs applicable tests, a defined scope, evidence, manual checks, and documented results. Installing an automated tool doesn't get you there.

Automation is useful. It detects certain categories of issue quickly and it catches regressions between audits. What it can't do on its own is judge whether an image needs a text alternative in the first place, whether a journey is logical, whether reading order makes sense, whether error handling works, or what the experience is like with a screen reader.

That distribution is why a scanner score and a compliance rate are not the same number. These figures move as tools improve, so treat them as a snapshot rather than a constant.

A complete RGAA program combines:

1. scope analysis;

2. a representative selection of pages and journeys;

3. manual and technical checks;

4. assistive-technology testing where relevant;

5. documented evidence and results; and

6. correction tracking and retesting.

What changes with RGAA 5 at the end of 2026?

The official website currently presents RGAA 4.1.2. That's the version to reference for evaluation unless an official source or applicable legal text says otherwise.

RGAA 5 is being drafted, with publication planned for the end of 2026. It brings five changes:

• alignment with WCAG 2.2

• new criteria and tests for mobile applications and office documents

• reworded and simplified existing criteria

• Arcom designated as the control authority

• an online service for filing and publishing accessibility statements

What happens to a statement you publish now?

Accessibility statements published before RGAA 5 is released stay valid for 18 months, within a limit of three years from their publication date.

Should you wait?

DINUM is explicit that this timing doesn't undermine work already under way. Accessibility programs built on 4.1.2 stay relevant and shouldn't be paused while waiting for a new version.

Whichever version you use, name it in your report and your accessibility statement, follow the official revision notes, and assess what a new version means for your documents and your update obligations.

RGAA, WCAG, EN 301 549, and the EAA: what's the difference?

The RGAA builds on international technical references, and then organizes criteria, tests, results, and documentation for the French context. Meeting WCAG doesn't in itself demonstrate that the French requirements on scope, testing, publication, and documentation have been met. And for the services the RGAA does not test, the reference to name in your report and your accessibility statement is EN 301 549, not the RGAA.

What is the legal basis for digital accessibility in France?

What changed in August 2026?

Decree No. 2026-816 was published in the Journal officiel on 26 August 2026 and took effect the following day. It doesn't create a new RGAA version. What it does:

• aligns certain French arrangements with the dates and deadlines in European Directive 2019/882, transposed by Law No. 2023-171;

• clarifies that the RGAA must identify the categories of service, content, and functionality its criteria apply to;

• requires covered services, content, and functionality to meet at least the applicable harmonized-standard requirements;

• replaces the former chapter heading "Sanctions et suivi" with "Suivi", and repeals Article 8 of the 2019 decree;

• establishes annual monitoring by the minister responsible for disability, covering websites, intranets, extranets, and mobile applications of the organizations in categories 1 to 3 of Article 47, with a report to the European Commission every three years; and

• provides a transitional rule allowing digital street furniture already installed to remain in service until the end of its economic life, within a limit of 15 years.

The repeal of Article 8 doesn't remove financial sanctions. It moves where they live. See the section on consequences below.

How is RGAA compliance measured?

The RGAA sets three official statuses, and one calculation rule.

• Fully compliant, when all applicable RGAA control criteria are met.

• Partially compliant, when at least 50% of the applicable criteria are met.

• Non-compliant, below 50%, or when there's no current, valid audit result that allows compliance to be measured.

The 75% threshold that circulates in French tender documents has no legal basis. It comes from a 2019 government observatory publication and spread from there. If you've seen it in a specification, the number to work from is 50%.

A percentage alone also says very little about the experience. A service at 76% with a keyboard trap in its checkout is less usable than one at 72% without. Read the rate alongside the audit date, the scope, the sample, and the barriers that remain.

Which documents are required for RGAA?

RGAA compliance isn't reduced to a percentage. Covered organizations publish and maintain accessible information about their program.

These are checkable immediately, whatever the technical state of the service. A statement that honestly reads "non-compliant" alongside a dated action plan puts you in a better position than no statement at all.

Exemptions and disproportionate burden

These are two different things, and they're often confused.

Exempt content covers categories Article 3 of the decree sets out, each under its own conditions:

1. office documents published before 23 September 2018, unless needed for an active administrative process

2. pre-recorded audio and video published before 23 September 2020

3. live audio and video

4. online maps, where the essential information is provided another way

5. third-party content you neither fund, develop nor control

6. reproductions of heritage items that cannot be made accessible without damaging them

7. intranet and extranet content published before 23 September 2019, until substantially revised

8. archives no longer needed for an active administrative process and not updated since 23 September 2019

Decree No. 2026-816 did not change these dates.

Disproportionate burden applies to specific content or functionality, never to a whole service by default. It's assessed case by case, weighing your organization's size, resources, and nature, the cost involved, the expected benefit for people with disabilities, how often and how long the service is used, and how important it is. Where it's reasonably possible, provide an accessible alternative.

A technical or budget difficulty isn't automatically a disproportionate burden. Document every exemption and derogation, and name it in your accessibility statement.

What happens if you don't comply?

The first consequence is the one that matters most: people can't get information, complete a process, or use a service they're entitled to use.

Financial penalties

Penalties sit in Article 47-1 of Law No. 2005-102, not in the decree. Arcom can find a breach and set the amount according to its seriousness, nature, and duration.

These are maximums, not standard amounts.

Decree No. 2026-816 repealed Article 8 of the 2019 decree and replaced the "Sanctions et suivi" chapter with "Suivi", which reorganized monitoring. It did not remove the penalties themselves.

Other consequences

Non-compliance can also lead to:

• correction requests from the authority

• complaints through your own published reporting channel

• administrative monitoring

• consequences in public procurement

• court proceedings brought by users or associations

• an obligation to update your compliance documents

How to run an RGAA audit

An RGAA audit is a documented evaluation. A score from a scanner isn't enough.

Step 1: define the scope. Identify the service, page templates, components, functionality, documents, media, authenticated areas, suppliers, and the journeys that matter.

Step 2: select a representative sample. The sample reflects the diversity of the service. It typically includes the homepage, authentication, contact, the accessibility page, legal notices, help, the site map, search, key journey pages, different content types, and pages chosen according to the applicable method.

Step 3: combine automation and manual checks. Automated tools flag certain issues and track regressions. Manual checks evaluate applicable criteria, relationships between content, component states, errors, context changes, and complete journeys.

Step 4: test interactions and assistive technologies. Keyboard access, navigation, focus, forms, and screen readers, tested across the environments, devices, and journeys that apply to your service. Naming the tool you used doesn't replace justifying the testing environment.

Step 5: document the results. Locate each non-conformity, link it to its criterion, explain the problem, provide evidence, state the reproduction conditions, and write a recommendation your design, content, and development teams can act on.

Step 6: correct, retest, and maintain. After corrections, retest the relevant criteria and the important journeys, then fold the results into your design, development, publication, and monitoring processes.

RGAA compliance FAQ

Is there a universal fine for RGAA non-compliance?

No. Exposure depends on your organization, the applicable regime, the service, the barriers, the evidence, any complaints or proceedings, and the authority or court involved. Arcom can impose up to 50,000 euros for breaching accessibility rules and up to 25,000 euros for other obligations under Article 47-1 of Law No. 2005-102. Other consequences include correction requests, formal notices, court orders, daily penalties for breaching an order, damages, and procurement consequences.

Does partial compliance protect an organization from legal action?

No. Partial compliance is an evaluation status, not a safe harbor from complaints, monitoring, contractual requirements, or litigation. Read it alongside the audit date, scope, sample, remaining barriers, and remediation plan. A published statement shows transparency. It doesn't guarantee that every function is usable.

Does the RGAA apply to our mobile application?

The legal obligation does. The RGAA's criteria do not. Article 47 and Decree No. 2019-768 put mobile applications in scope, but the RGAA does not define a testing method for them, so the evaluation runs against EN 301 549. RGAA 5, planned for the end of 2026, is expected to add criteria and tests for mobile applications.

Does publishing an accessibility statement make an organization compliant?

No. It's a transparency obligation, not proof that an inaccessible service is compliant. The statement has to reflect a current evaluation, identify inaccessible or exempt content, provide contact and resource information, and be updated as the service changes.

How often should we review our accessibility status?

There's no universal interval. Review it after a substantial change, a redesign, a major release, a new legal or framework requirement, or whenever the current evaluation stops reflecting the service. Public-sector monitoring and annual action planning may impose their own rhythm. Let release frequency, critical journeys, and user impact drive the cycle rather than a percentage.

We're not sure whether the RGAA applies to us. Where do we start?

Document your legal status, activities, digital services, users, contracts, revenue conditions, and any European or consumer-law obligations. Then confirm the scope and framework, get an evidence-based evaluation, update the required documents, and build a prioritized remediation plan. A free scan is a useful first signal, and a legal-scope review plus an expert evaluation usually come before any public compliance claim.

Does RGAA compliance cover our EAA obligations too?

No. Assess the RGAA alongside the European Accessibility Act and French consumer-law obligations where they apply. The frameworks differ in scope, covered services, deadlines, documentation, and enforcement, and compliance with one isn't evidence of compliance with another.

How we support RGAA compliance

Accessibility is built and maintained over time, so we've designed our work around that rather than around a report you receive once a year.

Automation detects and monitors at scale. People handle judgment and complex remediation, and your development team resolves the issues with what we give them. That hybrid is deliberate, and it's why Accessiway does not promise an automatic route to conformance.

If you operate in other European markets, the same obligations take a different form in Germany, Austria and Italy.

Official references

1. RGAA criteria and tests, DINUM

2. Accessibility statement, DINUM

3. Multi-year accessibility plan, DINUM

4. Law No. 2005-102, Article 47, Légifrance

5. General Accessibility Improvement Framework, DINUM

6. Decree No. 2019-768, Légifrance

7. Decree No. 2026-816 of 24 August 2026, Légifrance

8. Digital accessibility of websites and services, Arcom

9. RGAA audit kit, DINUM

10. Test methodology, DINUM

11. RGAA 5, announcement, DINUM

12. Law No. 2005-102, Article 47-1, Légifrance

13. Law No. 2023-171 of 9 March 2023, Légifrance