If you sell into France, run a service used there, or build for a French client, RGAA may apply. It is not the European Accessibility Act, and meeting one does not automatically mean meeting the other. That distinction is where most of the confusion starts.
This guide covers what the RGAA is, which version applies, who is in scope and who is not, the three documents French law requires, how an audit and its conformity rate work, and what ARCOM can enforce.
What is the RGAA?
The RGAA, or Référentiel général d’amélioration de l’accessibilité, is the official French framework for checking that a website or digital service is accessible to people with disabilities. It is published by DINUM, the French government’s digital agency, and the version in force is RGAA 4.1.2.
The framework sets 106 control criteria across 13 topics, each broken into numbered tests stating exactly what to check. Those criteria map onto WCAG 2.1 level AA; but RGAA adds test methods, which close the interpretation gaps that let two WCAG audits of the same content disagree, plus a set of French documents you have to publish.
Note that the RGAA is not itself a law. Article 47 of the 2005 disability act creates the accessibility obligation for public bodies, and the arrêté of 20 September 2019 designates the RGAA as the reference for measuring it, which is what makes it binding for them.
No French text designates it for private companies under the European Accessibility Act, though they commonly use it anyway.
The 13 topics
| Topic | What it checks |
|---|---|
| Images | Text alternatives, informative images, decorative images |
| Frames | A meaningful title on every iframe |
| Colors | Information not carried by color alone, contrast ratios |
| Multimedia | Transcripts, captions, audio description for time-based media |
| Tables | Data tables versus layout tables, headers, summaries |
| Links | Explicit link text, identical links pointing to different targets |
| Scripts | Compatibility with assistive technology, control of context changes |
| Mandatory elements | doctype, page language, page title, language changes |
| Information structure | Heading hierarchy, lists, quotations, semantic markup |
| Information presentation | CSS disabled, 200% zoom, text spacing, focus visibility |
| Forms | Labels tied to fields, grouping, input assistance, error handling |
| Navigation | At least two navigation systems, skip links, tab order |
| Consultation | Time limits, downloadable documents, new windows |
Every criterion and its tests are published on the official criteria and tests page, in French.
Does RGAA compliance apply to you?
The official scope page lists four categories.
Public law entities, private bodies delegated a public service mission, private bodies set up by either of those to meet general interest needs of a non-industrial and non-commercial character, and companies with French turnover above 250 million EUR.
What they owe it on is the “service de communication au public en ligne”, which takes in websites, intranets, extranets, mobile apps, digital street furniture, and software packages where they are used through a web browser or a mobile app.
Set against the situations people actually ask about, that works out as follows.
| Your situation | RGAA required? | What it means |
|---|---|---|
| French public law entity (state, local authority, public institution, hospital, university) | Yes | Audit, declaration, multi-year plan, annual action plan, homepage statement |
| Delegate of a public service mission, or a body mainly funded or controlled by a public entity | Yes | Same obligations |
| Private body set up by a public entity or a public service delegate to meet general interest needs of a non-industrial, non-commercial character | Yes | Same obligations |
| Private company with French turnover above 250 million EUR | Yes | Same obligations |
| Non-profit offering neither essential public services nor services aimed at people with disabilities | No | Outside article 47 |
| Private SME below the 250 million EUR threshold, outside the EAA sectors | No | No RGAA obligation, but see below |
| Private SME in an EAA sector (ecommerce, banking, transport, electronic communications, e-books) | No, not under the RGAA | Covered by the EAA since 28 June 2025, unless it is a micro-enterprise |
The 250 million EUR threshold is not last year’s revenue. The text uses the average annual turnover generated in France over the last three closed financial years. A company that crosses the line in a single year does not mechanically fall into scope.
If your company is not French
A company headquartered outside France is not exempt by virtue of geography, and it is not automatically in scope either. What matters is the regime, not the passport.
Under the public sector regime, the test is whether you are a French public law entity, a delegate of a French public service mission, or a private company whose French turnover averages above 250 million EUR over the last three closed financial years.
A US or UK company selling into France on a normal commercial basis is almost never caught by that regime. If you sell online into France, run a bank or a transport service there, or distribute e-books there, it is the EAA that applies to you, and it has applied since 28 June 2025.
There is one route that pulls a non-French company into the RGAA anyway, and it has nothing to do with turnover. Bid on a French public contract and the RGAA arrives contractually.
The tender route
A public buyer in France is itself bound by article 47 and cannot procure a service that would put it in breach. French public tender specifications can therefore ask for a commitment to RGAA conformity, and sometimes for an existing audit and declaration.
“We are not in scope” is not an answer that survives that question. It disqualifies the bid.
Running the audit while nothing is at stake costs less and takes less time than discovering the requirement three weeks before a submission deadline.
How an RGAA audit works
An RGAA audit applies all 106 criteria to a defined sample of pages, recording a written verdict for each criterion. Both the sample composition and the verdict format are prescribed, which makes it narrower and stricter than a general accessibility audit.
You do not have to buy tooling to start. DINUM publishes a free audit kit: the Ara tool for running the audit and generating the report and declaration, an RGAA 4.1.2 audit grid as a spreadsheet, and report and declaration templates.
#1. Building the sample
The official evaluation method starts with a list of mandatory pages where they exist: homepage, contact page, legal notice, accessibility page, sitemap, help page, and login page.
To those you add at least one representative page per type of service, at least one downloadable document per type, every step of multi-page processes such as a form or a transaction, and pages whose layout or content type differs, such as tables, multimedia, or maps.
The sample is then topped up with randomly drawn pages representing at least 10% of the sample itself, not of the whole site.
For a mid-sized municipal site, the sample might come out like this:
- The mandatory pages that exist: homepage, contact, legal notice, accessibility page, sitemap, help, login. 7 pages
- One page per type of service: a news article, an event listing, a service request landing page. 3 pages
- One document per format published: a PDF, a Word file, a spreadsheet. 3 documents
- Every step of the multi-page contact form, from the first screen to the confirmation. 4 pages
- Pages whose layout or content type differs: a data table, a video page, a map. 3 pages
- Random pages, at least 10% of the 20 above. 2 pages
That gives a sample of 22, and all 106 criteria are then assessed against every one of them. A 400-page site and a 4,000-page site can end up with samples of a similar size, because the sample tracks the number of distinct templates and content types, not the page count.
#2. Calculating the conformity rate
The conformity rate is the number of criteria met divided by the number of applicable criteria. A criterion only counts as met if it passes on every page in the sample, so a single failure on a single page invalidates the criterion for the whole audit.
Take that 22-page sample. A site with no video and no data tables will have a batch of criteria come back as not applicable, so say 26 drop out, and 80 criteria apply. If 60 of those pass on all 22 pages, the conformity rate is 60 divided by 80, or 75%, which is declared as « Accessibilité: partiellement conforme ».
The all-pages rule is what makes that number move slowly. If five further criteria each pass on 21 pages and fail on one, they count as failed outright, and the rate falls to 55 out of 80, or 69%. One neglected template can cost several points on its own.
The second indicator, the average conformity rate, averages the per-page rates. It is more flattering, and it does not replace the first one in the declaration.
See where your site stand on RGAA compliance
WebYes Accessibility checks every page and reports what a tool can catch, with AI suggestions for each fix.
The three documents RGAA compliance requires
Beyond making the service accessible, article 47 requires three published artifacts. All three can be checked from outside in a few minutes, which is exactly why they are the first things anyone looks at after a complaint or an inspection.
1. The déclaration d’accessibilité (accessibility declaration)
The déclaration d’accessibilité is the document that publicly states the service’s conformity status. It has to be published in an accessible format, on an accessibility page reachable directly from the homepage and from any page of the site.
Most people know this document as an accessibility statement.
Its contents are prescribed. It states the conformity status, lists non-accessible content while distinguishing outright non-conformities from disproportionate-burden derogations and exempt content, gives the assistance and contact channels, and points to the right to refer the matter to the Défenseur des droits (the French ombudsman).
Its shelf life is prescribed too. The declaration has to be redone on any substantial modification or redesign, at the latest three years after publication, or within 18 months of a new version of the framework being published.
DINUM publishes a worked example declaration showing the required sections, with fill-in templates in ODT, PDF and HTML inside the audit kit. For a live one, the declaration for impots.gouv.fr shows the format as it is actually filed, including the named auditor and the section-by-section list of non-conformities.
2. The schéma pluriannuel (multi-year accessibility plan) and annual action plan
The schéma pluriannuel de mise en accessibilité covers a maximum of three years. It sets out the organization’s accessibility policy: governance, staffing and budget, training, how accessibility enters procurement, and the path to conformity.
The annual action plan turns that into dated actions for the current year. Both documents have to be published online in an accessible format and referenced from the accessibility declaration.
This is the obligation easiest to overlook, because it is governance work rather than technical work.
The French ministries of Labour and Solidarity and of Health publish theirs as a single combined document, the schéma pluriannuel 2025-2028 with its action plan, which is a usable model for the level of detail expected.
3. The conformity statement on the homepage
The homepage has to carry a clearly visible statement of the conformity level. The wording is prescribed to the word, in French, and there are exactly three options.
| Level | Exact wording to display | Condition |
|---|---|---|
| Full conformity | Accessibilité : totalement conforme | Every applicable control criterion is met |
| Partial conformity | Accessibilité : partiellement conforme | At least 50% of applicable control criteria are met |
| Non-conformity | Accessibilité : non conforme | Under 50% met, or no valid audit |
Those French strings are the legal text, so an English site serving French users displays them as they stand rather than translating them. They mean, in order, fully compliant, partially compliant, and not compliant.
The statement can be made clickable through to the accessibility page or the declaration. What is not allowed is rewording it, replacing it with a percentage, or leaving it off while the site improves. A site with no valid audit displays « Accessibility: not compliant », and in that situation that is the only accurate thing to display.
RGAA enforcement and penalties
Article 47-1 of loi n° 2005-102 sets out the applicable sanctions regime. The competent authority is ARCOM, the French audiovisual and digital regulator.
The procedure runs through a mise en demeure (a formal notice to comply). ARCOM records the breach, formally notifies the organization to fix it within a deadline it sets, and only issues a financial penalty if the breach persists.
| Breach | Maximum penalty |
|---|---|
| Failure to meet the accessibility obligation (article 47 I) | 50,000 EUR |
| Failure to meet the declaration obligations (article 47 III and IV) | 25,000 EUR |
RGAA 5: what changes and what to decide now
DINUM has announced a new version of the framework for late 2026. It is not in force: RGAA 4.1.2 remains the applicable version today, and work already under way on that basis stays valid.
According to the official announcement, RGAA 5 brings four changes.
- Integration of WCAG 2.2, which adds criteria on visible focus, pointer target size, and accessible authentication.
- Extension to mobile apps and office documents, with dedicated technical criteria and tests, where the current framework is mostly web-focused.
- ARCOM designated as the control authority, with a service for filing and publishing accessibility declarations.
- Simplified criteria wording, to narrow the gap between auditors’ interpretations.
One provision drives today’s decision: accessibility declarations published before RGAA 5 arrives will stay valid for 18 months, within the three-year cap from their publication date.
Waiting for RGAA 5 before starting an audit buys nothing and costs time. Publishing a 4.1.2 declaration now is still the right move, and it opens an 18-month window after version 5 lands in which to re-audit. An audit run in late 2026 therefore holds until around mid-2028, as long as it stays inside the three-year ceiling.
Extending the framework to office documents brings files currently treated at the margins of the audit inside the tested perimeter, which matters most to anyone managing a large PDF library. Fixing your most widely distributed document templates now avoids reworking an entire archive later.
FAQs on RGAA
It is not a law. The obligation comes from article 47 of loi n° 2005-102, and the arrêté of 20 September 2019 designates the RGAA as the reference for measuring it. That designation is what makes the RGAA binding for the bodies article 47 covers, without making it a law in its own right.
There is no single text. For public bodies it is article 47 of loi n° 2005-102 with décret n° 2019-768, amended by décret n° 2026-816. For private companies in the covered sectors it is the European Accessibility Act, transposed by loi n° 2023-171 and décret n° 2023-931.
WCAG is the W3C’s international recommendation; the RGAA is the French method that makes it verifiable. The RGAA takes WCAG 2.1 level AA and adds detailed tests that remove interpretation gaps, plus French declaration obligations that WCAG does not contain. The accessibility bar itself is the same.
For public bodies, public service delegates, general-interest private bodies and companies above 250 million EUR in average French turnover over three financial years, yes. For a private SME outside the EAA sectors, no. That SME can still be asked for it contractually in a French public tender.
It depends on what you are, not on which you would prefer. Public bodies fall under the article 47 regime and owe an RGAA audit. Private companies selling online, banking or running transport fall under the EAA regime whatever their size, unless they are micro-enterprises, and a large company doing both can be in both regimes for the same site.
Not automatically, though the technical overlap is wide. An RGAA 4.1.2 audit covers most of what the EAA expects from a web interface, since both regimes land on EN 301 549 and therefore on WCAG level AA. The EAA does not stop at the website though, so an RGAA audit says nothing about hardware products, self-service terminals, or the EAA’s own documentation duties.
Yes. The clearest difference is reach: the EAA extends beyond websites into products, self-service terminals and other service touchpoints that sit outside what the RGAA tests. It also carries its own information and documentation duties, which the EAA guidance covers in detail.
No, and it predates it. Version 4 was established by the arrêté of 20 September 2019, whereas the EAA was transposed only by the loi of 9 March 2023 and the décret of 9 October 2023. The RGAA descends from a different line, article 47 of the 2005 law and directive (EU) 2016/2102 on public sector websites.
In everyday use, yes: the déclaration d’accessibilité is what English speakers usually call an accessibility statement. What is distinctive is that its contents are prescribed by French law and it reports a conformity status derived from an audit. The EAA regime asks for comparable information under its own texts.
AUTHOR
Melwyn holds a Bachelor's degree in Computer Science and has been writing professionally for over 4 years. He has a strong background in SEO and is certified in web accessibility from the World Wide Web Consortium (W3C). When he's not writing about website optimisation, you can find him enjoying a game of FIFA or exploring the open world of GTA.
Melwyn Joseph 
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