According to French government estimates, more than 12 million people in France are affected by a disability—and if your digital experiences aren’t accessible, your organization may face steep fines for failing to meet RGAA compliance requirements under French accessibility law.
The RGAA (Référentiel Général d’Amélioration de l’Accessibilité) is legally binding and applies not just to public bodies but also to many private companies and their vendors.
RGAA is already enforceable in France. Separately, the European Accessibility Act (EAA) took effect on June 28, 2025, extending digital accessibility obligations to additional private sector businesses across the EU. The EAA's technical backbone is EN 301 549, which closely mirrors — but is not identical to — the RGAA. For organizations serving French customers, RGAA-aligned auditing typically satisfies both regimes, but the legal obligations are distinct and should be addressed together. Book a meeting with UsableNet to get expert support ahead.
Whether you manage a municipal website in Lyon or run an international e-commerce site serving French customers, this guide outlines the five key steps to achieving RGAA France compliance to mitigate risk, maintain eligibility for public contracts, and support inclusive user experiences.
What Is RGAA—and Why It Matters for Your Business
The Référentiel Général d’Amélioration de l’Accessibilité (RGAA) is the French government’s accessibility standard. It makes WCAG 2.1 AA conformance a legal requirement under Article 47 of Law No. 2005-102 and Decree No. 2019-768.
The current version, RGAA 4.1.2, includes:
- 13 thematic chapters
- 106 criteria
- Over 250 individual tests
RGAA’s scope goes well beyond public sector websites—it covers:
- Public and private websites
- Mobile and desktop applications
- Intranets and extranets
- Downloadable files and documents
Organizations must also publish a French-language accessibility statement (Déclaration d’accessibilité) that declares conformance levels and includes a user feedback mechanism.
RGAA vs. WCAG 2.1 AA: What’s the Difference?
While RGAA is based on WCAG 2.1 AA, it adds legal structure and practical implementation details for the French market.
Key differences:
- Legal references: Each RGAA criterion is tied to French law, enabling enforcement.
- Granularity: RGAA breaks WCAG success criteria into more specific, individually testable checks. For example, a single WCAG criterion may map to multiple RGAA tests within the same thematic chapter, each targeting a distinct implementation detail.
- Proof of Compliance: RGAA mandates a scored audit and published statement; WCAG alone is voluntary unless adopted by a law.
Understanding these differences helps avoid gaps in testing and ensures your documentation meets legal expectations.
Does RGAA Apply to You? Fines, Risks, and Enforcement Explained
In France, digital accessibility is mandated by Law No. 2005-102, also known as the "Loi pour l'égalité des droits et des chances, la participation et la citoyenneté des personnes handicapées." This law requires certain organizations to comply with the Référentiel Général d’Amélioration de l’Accessibilité (RGAA), which aligns with WCAG 2.1 AA standards.
Who Must Comply?
1. Public Sector Organizations:
All public entities in France, including state administrations, local authorities, and public institutions, are required to ensure the accessibility of their digital services. This encompasses websites, mobile applications, intranets, and other digital platforms.
2. Private Companies with Significant Revenue:
Private Companies with Significant Revenue: Private companies operating in France with an average annual revenue exceeding €250 million over the previous three years are subject to digital accessibility obligations under Article 47 of Law No. 2005-102. In France, conformance is demonstrated using the RGAA as the technical reference. This applies to digital services offered to the public, such as websites and mobile applications.
3. Service Providers and Subcontractors:
Third-party vendors and service providers working with the aforementioned public and private entities must also ensure their digital offerings meet RGAA compliance levels. Non-compliance can lead to exclusion from tenders or termination of existing contracts.
Penalties for Non-Compliance
Failure to adhere to RGAA requirements can result in administrative fines of up to €50,000 per non-compliant digital service under Ordonnance 2023-859. If non-compliance persists more than six months after the initial sanction, ARCOM may impose an additional sanction. A separate penalty of up to €25,000 applies for failing to publish a required accessibility statement or multi-year accessibility plan. Organizations may also be listed on a public register of non-compliant entities, which can impact their reputation and eligibility for public contracts.
Under the updated framework, ARCOM (Autorité de régulation de la communication audiovisuelle et numérique) can issue a formal notice before imposing fines. If non-compliance persists beyond six months after the initial sanction, additional penalties can be imposed. The timeline may vary based on non-compliance severity and the entity’s responsiveness.
Common RGAA Compliance Mistakes to Avoid
Even well-intentioned organizations frequently stumble in the same areas. Watch out for these pitfalls:
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Relying solely on automated tools: Automated scans can only test a fraction of RGAA’s 106 criteria—the rest require expert manual evaluation. Without manual testing, the majority of accessibility issues go undetected.
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Ignoring documents and downloadable files: PDFs, Word docs, and spreadsheets are in scope. Many organizations overlook them entirely.
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Publishing an incomplete Déclaration d'accessibilité: The statement must include your audit score, technologies assessed, any exemptions claimed, and a working user feedback mechanism.
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Assuming WCAG 2.1 AA alone is enough: While RGAA is based on WCAG 2.1 AA, it includes additional criteria and legally mandated documentation requirements that WCAG alone does not address.
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Treating compliance as a one-time project: RGAA requires ongoing monitoring. A site that passes an audit today can fall out of compliance after a redesign or content update.
Five-Step Roadmap to RGAA Compliance
Following this process will help you move from risk to readiness:
- Audit your digital properties: Use a mix of automated scans and expert manual testing across websites, mobile apps, and documents. Try a free automated scan with UsableNet AQA.
- Prioritize and plan: Organize issues by severity, frequency, and level of effort to fix. Align on timelines and responsibilities.
- Remediate and retest: Designers, developers, and content authors make necessary fixes. QA validates every update against RGAA criteria.
- Publish your Déclaration d’accessibilité: Required by law, this French-language statement must include your audit score, covered technologies, any exemptions, and a user feedback channel.
- Monitor continuously: Schedule regular automated scans and conduct at least one full expert audit annually to maintain compliance.
RGAA Compliance Checklist: Are You Ready?
Use this checklist to assess your organization's current RGAA compliance posture:
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Completed an automated scan of all public-facing web pages
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Conducted a full manual RGAA 4.1.2 audit with assistive technology testing
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Identified and prioritized accessibility issues by severity and effort
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Remediated high-priority barriers across websites, mobile apps, and documents
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Published a French-language Déclaration d'accessibilité on each covered digital service
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Included a user feedback mechanism in your accessibility statement
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Confirmed all third-party vendors and subcontractors meet RGAA requirements
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Scheduled recurring automated monitoring and annual expert audits
Frequently Asked Questions About RGAA Compliance
How does RGAA France relate to WCAG 2.1 AA?
RGAA 4.1.2 is based on WCAG 2.1 AA. Meeting all RGAA criteria means you meet WCAG 2.1 AA—but not vice versa.
What are the penalties for non‑compliance?
Under the updated framework, ARCOM (Autorité de régulation de la communication audiovisuelle et numérique) can issue a formal notice before imposing fines. If non-compliance persists beyond six months after the initial sanction, additional penalties can be imposed. The timeline may vary based on non-compliance severity and the entity’s responsiveness.
Does RGAA apply to internal platforms and documents?
Yes. RGAA covers intranets, extranets, downloadable documents, media players, and certain kiosks.
What if we sell into France but aren’t based there?
RGAA obligations flow from being a covered entity under French law — public sector bodies, private companies with €250M+ average annual revenue, delegates of public services, and vendors to those organizations. Operating a French-language site or serving French customers does not, by itself, place a company within RGAA scope. However, businesses serving EU customers should separately assess their obligations under the European Accessibility Act, which applies more broadly.
How UsableNet Helps
RGAA compliance requires more than testing — it demands an ongoing strategy. UsableNet offers three ways to get there, depending on how much of the work your team wants to own:
• Assistive — A fully managed remediation service. UsableNet's team handles audits, code-level fixes, and ongoing monitoring on your live site, with minimal lift from your team.
• Accessibility as a Service — Expert audits, a remediation roadmap, user testing with people with disabilities, and training (including UsableNet University) to build internal capability. Your team implements with UsableNet's guidance.
• AQA Platform — A self-managed accessibility testing and management platform with automated and guided manual testing, code-level fix recommendations, and CI/CD integrations. Your team finds and fixes issues independently.
All three include bilingual support (French and English) and can be aligned specifically to RGAA 4.1.2 criteria and the Déclaration d'accessibilité requirements.Conclusion: RGAA Compliance Isn’t Optional—But It Can Be Manageable
RGAA enforcement is already active. For organizations subject to RGAA France requirements, proactive preparation is the clearest path to avoiding penalties. By auditing early, prioritizing fixes, and publishing your Déclaration d’accessibilité, you can avoid fines and demonstrate your commitment to inclusion in one of the world’s most digitally regulated markets.
Ready to take action? UsableNet offers a range of educational tools and support materials to help businesses prepare for the upcoming EAA deadline.
- Visit the European Accessibility Act Resource Hub to learn more
