RGAA Compliance Guide to French Digital Accessibility Standards
If your organization operates in France or works with French public bodies, you will come across the term RGAA very quickly. Understanding RGAA is essential because France takes digital accessibility very seriously. This standard isn’t just a recommendation; it is a legal requirement backed by audits, documentation, and penalties.
Whether you’re a designer, developer, product owner, or founder, this guide will help you understand what RGAA is, who it applies to, what you must publish, and how to stay compliant without getting lost in technical complexity.
So… What Exactly is RGAA?
RGAA = Référentiel Général d’Amélioration de l’Accessibilité means General Accessibility Improvement Framework.
It is France’s official digital accessibility standard that ensures websites, mobile apps, and digital services are usable by people with disabilities.
Current version: RGAA 4.1.2 (updated in 2022, still the one used in 2025) It contains 106 precise tests you have to pass (think of them as checklist items).
It’s basically the French version of the international standard (WCAG 2.1 AA), but with stricter rules, mandatory paperwork, and real legal teeth.
Why Do You Need to Know RGAA?
Because:
- France legally requires it for public and certain private organizations.
- Non-compliance leads to fines, public naming, and loss of contracts.
- If you’re already following WCAG, RGAA helps you enter the French market with confidence.
- It demands transparency — compliance percentage, public statement, and feedback system.
Knowing RGAA means you can avoid legal issues, build trust with French users, and create inclusive digital products.
Who Must Comply with RGAA?
| You HAVE to comply if… | You’re exempt if… |
|---|---|
| You are a public body (government, city hall, public hospital, university, etc.) in France. | You’re a small private company (< €250M turnover) with no public mission |
| You’re a private company in France with > €250 million average turnover in the last 3 years | Your tool is purely internal (intranet, not public) |
| You run a public service of general interest (transport, energy, telecom, banking in some cases) | You’re a tiny startup or association below the threshold (although accessibility is still recommended) |
| You are a vendor who provide products/services to public entities |
Key Compliance Deadlines
| Service Type | Deadline | Status |
|---|---|---|
| Public websites | Sept 2020 | ⚠️ Already passed |
| Mobile apps & digital interfaces | June 2021 | ⚠️ Already passed |
| Private sector (under EAA rules) | June 28, 2025 | ⚠️ Already passed |
What Happens if You Don’t Comply?
Legal and practical consequences:
- Fines up to €20,000 per digital service, renewed annually
- Public listing as non-compliant, damaging reputation and partnership potential
- Disqualification from public contracts or tenders or risk of contract termination for vendors.
- Legal complaints from users via the Défenseur des droits (Rights Defender) with enforced remediation.
Is Being WCAG 2.2 AA Compliant Enough?
No, but you’re very close.
RGAA is aligned with WCAG 2.1 (just like many global standards), but it translates and interprets WCAG success criteria into a more testable and actionable format, specifically adapted for the French context.
What WCAG 2.2 AA Gives You:
- Technical accessibility foundation
- Most of the way toward RGAA compliance
- Strong starting point for French market
You still need to do extra things like:
- Exactly defined test procedures
- Mandatory French accessibility statement
- Mandatory compliance percentage display
- Required feedback mechanism
- Rights Defender escalation
- Multi-year accessibility plan
- French-language and formatting requirements
RGAA vs WCAG 2.2 : Quick Comparison
| Feature | WCAG 2.2 | RGAA 4.1 (France) |
|---|---|---|
| Origin | W3C (International) | French government |
| Criteria | ~50 success criteria(A/AA) | 106 criteria + 300 test methods |
| How strict? | Flexible (“as long as it works”) | Strict pass/fail methods (exact way to test) |
| Accessibility statement | Optional | Mandatory + exact French template |
| Show your score publicly? | No | Mandatory % score |
| User complaint system | Nice to have | Mandatory + link to government ombudsman |
| Multi-year improvement plan | Not required | Mandatory and public |
| Fines for not doing it | Usually none | Up to €20,000 per service per year |
The 6 Things You Absolutely Must Do for RGAA
To achieve and maintain compliance with RGAA (Référentiel Général d’Amélioration de l’Accessibilité), organizations operating digital services in France must fulfill specific legal and technical obligations. Here’s the entire checklist:
1. Comprehensive Accessibility Audit
Organizations must conduct thorough audits of all digital products and services against RGAA’s 106 technical criteria.
Scope:
- Identify all accessibility barriers across the digital ecosystem
- Evaluate websites, mobile applications, and digital documents
- Manual expert review + assistive technology testing
- Evidence documentation (screenshots, code samples, recordings)
- Per-page/per-screen assessment with representative sampling
- Test against all applicable RGAA success criteria
Frequency:
At launch, annually, and after major updates.
2. Mandatory Accessibility Statement (Déclaration d’Accessibilité)
Organizations must publish a detailed, legally formatted accessibility statement in French for each digital service.
Must Include:
- Compliance status and percentage
- Date of the statement and audit
- Technologies used
- Test environment details (browsers, assistive technologies)
- Detailed list of non-compliant elements with explanations
- Exemptions and disproportionate burden justifications (if applicable)
- Feedback mechanism details
- Legal remediation process information
Placement: Statement must be easily accessible from every page (typically in footer)
Update:
You must update it at least once a year and within 3 months of major changes.
3. Public Compliance Percentage Display
The RGAA compliance percentage must be publicly displayed on each digital service, typically on the homepage and in the footer.
| Compliance Level | Score | Requirement |
|---|---|---|
| Fully Compliant (Totalement conforme) | 100% | Must be prominently displayed |
| Partially Compliant(Partiellement conforme) | 50% – 99% | Must include percentage and list of non-compliances |
| Non-Compliant (Non conforme) | Below 50% | Must state non-compliance and remediation timeline |
Visibility: Compliance badge/statement must be visible on the homepage and accessible site-wide
4. User Feedback Mechanism & Rights Defender Contact
Websites and applications must provide an accessible channel for users to report accessibility barriers and include contact details for the Défenseur des droits (French Rights Defender) for unresolved complaints.
Required Elements:
A. Feedback Channel
- Dedicated accessibility feedback form or email address
- Clear instructions in French on how to report issues
- Expected response timeframe (typically within 1 month)
- Acknowledgment process for received complaints
B. Rights Defender Contact
You must provide:
- Contact details for Défenseur des droits must be published
- Information on escalation process if internal resolution fails
- Direct link to: https://formulaire.defenseurdesdroits.fr/
- Alternative contact methods (postal address, phone number)
5. Fixing Accessibility Issues (Remediation)
Organizations must actively fix identified accessibility barriers across all digital touchpoints.
Remediation Scope:
| Area | Actions Required |
|---|---|
| Code | Fix HTML structure, ARIA implementation, keyboard navigation, focus management |
| Design | Ensure sufficient color contrast, scalable text, visible focus indicators, responsive layouts |
| Documents | Remediate PDFs, Word documents, presentations to be accessible |
| User Journeys | Ensure all critical paths are accessible (forms, checkout, registration, authentication) |
| Multimedia | Add captions, transcripts, audio descriptions where required |
Timeline: Remediation must follow a reasonable schedule documented in the accessibility statement
6. Multi-Year Accessibility Plan (Schéma Pluriannuel)
Organizations must publish and maintain a strategic, multi-year accessibility improvement plan outlining ongoing efforts.
Must include:
- Establish an accessibility improvement roadmap with milestones
- Assign responsibility for accessibility within the organization
- Conduct regular audits (recommended annually or after major updates)
- Update accessibility statements within 3 months of significant changes
- Train staff on accessibility requirements
- Monitor and respond to user feedback
- Document all accessibility efforts and progress
RGAA Compliance Summary Table
| Requirement | Key Deliverable | Timeline/ Frequency | Legal Obligation |
| Comprehensive Audit | Full RGAA technical audit report | At launch + annually + after major updates | Mandatory |
| Accessibility Statement | Detailed declaration in French with compliance status | Published within 3 months of audit | Mandatory – Must be public |
| Compliance Percentage Display | Visible badge showing 0-100% compliance | Permanent display on all pages | Mandatory – Homepage minimum |
| User Feedback Mechanism | Accessible form/email for reporting barriers | Always available | Mandatory |
| Rights Defender Contact | Published contact information for escalation | Always visible in statement | Mandatory |
| Issue Remediation | Fixed code, design, documents, user flows | Ongoing with documented timeline | Mandatory – Reasonable timeframe |
| Improvement Plan | Documented roadmap and progress tracking | Continuous with regular updates | Mandatory – Show ongoing effort |
RGAA’s Stricter Interpretation of WCAG
Examples:
| WCAG Criterion | WCAG Expectation | RGAA Interpretation |
|---|---|---|
| 1.3.1 | Programmatic structure | Requires specific <label>, <fieldset>, table markup |
| 2.4.4 | Link purpose | Stricter rules for link clarity |
| 1.4.3 | Contrast | Applies to UI components too |
| 3.3.2 | Labels | Mandatory explicit <label> usage |
| 4.1.2 | Name/Role/Value | Detailed ARIA rules |
RGAA = More strict, more specific, more test-driven.
How to Adapt Your WCAG Audit Report for RGAA
RGAA prescribes a detailed audit report structure:
- Test grid showing results for each RGAA criterion (page by page or representative sample)
- Justification for each conformity/non-conformity with reference to specific “test units”
- Compliance percentage calculation broken down by page, overall site, and A/AA/AAA levels
- Clear linkage to accessibility statement and multi-year plan
- Alignment with official templates published by French authorities (DINUM)
Final Thoughts – It’s Doable and Worth It
Yes, RGAA has more paperwork than WCAG, but once the system is in place it runs smoothly, and you end up with a much better product.
Plus, you avoid fines, bad press, and losing big French contracts.
Start today:
- Run a quick automated scan (WAVE, axe core) to see the low-hanging fruit
- Book a proper RGAA audit with a French-certified expert
- Use the official government templates (they’re free!)
Need help with RGAA compliance?
DigitalA11Y provides digital accessibility audits, accessibility statement creation, and ongoing compliance support, with expertise in French legal requirements.
Related Reads:
- Latest RGAA 4.1.2
- Accessibility statement generator & templates
- Rights Defender Complaint Form
- DINUM (French Digital Authority): Official audit templates and guidance
