RGAA compliance is a legal requirement for public bodies and many private companies operating in France. The Référentiel Général d’Amélioration de l’Accessibilité, France’s official digital accessibility standard, sets out 106 testable criteria that websites, mobile apps, and software must meet. This guide explains who must comply, what RGAA compliance actually costs to ignore, and how it differs from the European Accessibility Act, a separate law that many guides mistakenly treat as the same thing.
What Is RGAA?
RGAA stands for Référentiel Général d’Amélioration de l’Accessibilité, or General Framework for Improving Accessibility. It is France’s official accessibility standard, built on WCAG 2.1 Level AA, and it applies to websites, mobile apps, software, intranets, and extranets.
The Direction interministérielle du numérique (DINUM), the French government’s digital agency, maintains and publishes RGAA. Its own definition keeps the goal simple:
“Digital accessibility means making digital content and services understandable and usable by people with disabilities.” — Direction interministérielle du numérique (DINUM), official RGAA portal, translated from the French original
The current version is RGAA 4.1.2. It contains 106 precise technical criteria, each with its own test method, so an audit produces a clear pass or fail rather than a subjective judgment call.
The Legal Foundation of RGAA
RGAA compliance traces back to a single piece of legislation: Article 47 of Loi n° 2005-102, passed on February 11, 2005. This law established equal rights and opportunities for people with disabilities in France, and Article 47 extended that principle to online public communication services.
Décret n° 2019-768, issued on July 24, 2019, turned that principle into a working framework. It adopted RGAA version 4.0, named EN 301 549 V2.1.2 as the underlying technical standard, and widened the scope beyond government websites to include large private companies and public-service delegates. Loi n° 2016-1321, the 2016 law for a digital republic, had already extended the original obligation to mobile apps and software a few years earlier.
Who Must Comply With RGAA?
RGAA compliance applies to four categories of organizations, and revenue size only matters for one of them. Public bodies and public-service delegates are covered regardless of how much they earn.
| Category | Who it includes | Revenue threshold |
|---|---|---|
| Public sector bodies | State administrations, local authorities, public institutions | None |
| Public-service delegates | Private entities delegated a public-service mission, or created for non-commercial general-interest purposes under public control | None |
| Public-service-created entities | Companies created by public authorities for general-interest, non-commercial purposes | None |
| Large private companies | Any private company doing business in France | Over €250 million in average French revenue |
Public Sector Bodies
Every legal entity under public law in France falls under RGAA compliance automatically. This covers ministries, local councils, public universities, public hospitals, and any digital service they publish, from a city hall website to an internal case-management tool used by civil servants.
Private Organizations With a Public-Service Mission
A private company can be pulled into RGAA compliance even with modest revenue, if it operates under a public-service delegation. A regional transit operator running a city’s bus network, a water utility under municipal contract, or a private hospital fulfilling a public-health mandate can all be in scope, because the law looks at the nature of the mission, not the size of the balance sheet.
Large Private Companies Over €250 Million in Revenue
Private companies that aren’t delegated a public mission still face RGAA compliance once their French revenue crosses €250 million, averaged across the three most recently closed fiscal years.
How the €250 Million Threshold Is Calculated
This detail catches international companies off guard. The threshold counts only revenue earned on French territory, not global revenue. A multinational retailer or SaaS company could report billions in worldwide revenue and still sit below the threshold if its French-derived revenue stays under €250 million. That same company, however, could still face separate obligations under the European Accessibility Act, which uses a completely different and much lower bar.
RGAA vs the European Accessibility Act (How They Differ)
RGAA and the European Accessibility Act are two separate laws in France, not two names for the same obligation. They have different legal foundations, different enforcement bodies, and different penalties, and confusing the two leads to bad compliance decisions.
Two Separate Laws, Two Different Penalties
RGAA flows from Article 47 of the 2005 disability law and is enforced by Arcom. The European Accessibility Act, transposed into French law through Loi n° 2023-171 and Décret n° 2023-931, is enforced mainly by the Direction générale de la concurrence, de la consommation et de la répression des fraudes (DGCCRF), alongside five other sector regulators.
| Parameters | RGAA | European Accessibility Act |
|---|---|---|
| Legal basis | Article 47, Loi n° 2005-102 | Loi n° 2023-171, Décret n° 2023-931 |
| Who’s covered | Public bodies, public-service delegates, companies with over €250 million French revenue | All companies except microenterprises (under 10 employees and under €2 million annual revenue) |
| What’s covered | All digital services of an in-scope entity | Specific services including e-commerce, banking, transport, telecom, audiovisual media services, and e-books |
| Enforcer | Arcom | DGCCRF, ARCEP, ACPR, AMF, Banque de France, and Arcom (for audiovisual services) |
| Maximum fine | €50,000 (non-conformity), €25,000 (publication failures) | €7,500, rising to €15,000 for repeat offenses |
| In force since | September 2019 (RGAA 4.0) | June 28, 2025 |
A company can fall under both laws at once. A French bank with over €250 million in revenue offering online banking is in scope for RGAA because of its size, and in scope for the European Accessibility Act because banking is on the covered-services list. An inaccessible checkout flow on that bank’s website could trigger two separate fines from two separate regulators.
A smaller e-commerce company, well under the €250 million threshold but offering online sales, escapes RGAA compliance entirely but still owes the European Accessibility Act, since the act’s default rule covers nearly every company above microenterprise size.
What Are the Penalties for RGAA Non-Compliance?
RGAA non-compliance carries real financial penalties, not just a warning letter. Arcom can fine an organization up to €50,000 for failing to meet RGAA’s accessibility criteria, and up to €25,000 separately for failing to publish required documents like the accessibility statement or multi-year plan.
These fines can double for a repeat violation, and they can recur every six months for as long as the organization stays non-compliant. Ordonnance n° 2023-859, issued on September 6, 2023, raised these figures from an original cap of €20,000 set by the 2019 décret and handed enforcement to Arcom.
Who Enforces RGAA? Meet Arcom
Arcom, the Autorité de régulation de la communication audiovisuelle et numérique, took over RGAA enforcement from the Ministry for Disabled Persons in 2023. Sanctions have applied since January 1, 2024, and Arcom has already sent warning letters to airlines and over a hundred public administrations.
One detail rarely makes it into RGAA compliance guides, and it changes how large private companies should think about their actual exposure:
“This obligation is not monitored by Arcom for private companies.” — Arcom, official accessibility compliance page, translated from the French original
In plain terms, Arcom checks large private companies for the declarative obligations only: the accessibility statement, the homepage compliance notice, and the multi-year plan. It does not run a technical audit of their actual RGAA conformity the way it does for public bodies and public-service delegates. That doesn’t remove the legal duty to be technically compliant, but it does mean the realistic enforcement risk for a large private company centers on paperwork, not a line-by-line criteria check from Arcom itself.
What Happens Before a Fine Is Issued
Arcom doesn’t fine an organization on first contact. It issues a formal notice (mise en demeure) first, and the organization typically gets three months to fix the identified issues before any fine is on the table. Only if the problems persist past that window does a financial penalty follow.
What Content Is Exempt From RGAA?
RGAA compliance has clearly defined exemptions, and they’re dated rather than open-ended. An organization can’t claim an exemption simply because accessibility wasn’t a priority.
- Office files published before September 23, 2018, unless they’re essential to an administrative procedure
- Pre-recorded audio and video published before September 23, 2020
- Live audio and video content, regardless of when it was published
- Maps and mapping services, as long as essential location information is available in another accessible format
- Third-party content the organization didn’t fund, develop, or control
- Heritage collection reproductions, where making them accessible would compromise preservation or authenticity
- Intranet and extranet content published before September 23, 2019, until the next major redesign
- Archived content that hasn’t been updated since September 23, 2019, and isn’t needed for an active procedure
Audiovisual media service providers, like broadcasters, sit outside RGAA’s scope entirely under French law, as do non-profits that don’t deliver an essential public service or a service specifically for people with disabilities.
One frequently overlooked rule: lack of time, lack of budget, and lack of internal knowledge are explicitly not valid grounds for claiming a disproportionate-burden exemption. The exemption exists for genuine technical or financial impossibility, not for deprioritization.
How to Achieve RGAA Compliance (Step by Step)
Achieving RGAA compliance follows a fairly consistent five-step process, regardless of the size of the organization or the platform involved.
1. Conduct an RGAA Audit
A proper RGAA audit tests a representative sample of pages against all 106 criteria, combining automated scanning with manual testing using screen readers and keyboard-only navigation. Automated tools alone typically catch only a fraction of RGAA’s criteria, since many require human judgment, such as whether alt text actually describes an image meaningfully.
A practical starting point is WCAG 2.2 conformance. WCAG 2.2 builds on WCAG 2.1 AA without removing any existing criteria, so meeting it covers the technical foundation RGAA 4.1.2 already tests against, and it positions an organization ahead of RGAA 5, which is expected to adopt WCAG 2.2 directly when it publishes.
WCAG conformance on its own won’t satisfy RGAA’s French-specific requirements, so the audit still needs to map every finding onto RGAA’s actual test methodology. This is where working with IAAP-certified accessibility professionals matters more than the testing tool used. Pivotal Accessibility audits against both WCAG and RGAA using IAAP-certified specialists, which is where that mapping happens.
2. Publish an Accessibility Statement (Déclaration d’Accessibilité)
Every in-scope organization must publish a French-language accessibility statement covering the audit date, the technologies and assistive tools tested, a list of non-compliant elements, and any exemptions claimed. It must be updated at least once a year, and within three months of a major site change.
3. Display Your Compliance Percentage
RGAA requires a visible compliance status on the homepage and ideally site-wide, using one of three official tiers:
- Totalement conforme (fully compliant): 100%
- Partiellement conforme (partially compliant): 50% to 99%
- Non conforme (non-compliant): below 50%, untested, or missing a valid statement
4. Set Up a Feedback Mechanism
Users need a working way to report accessibility barriers, plus a visible escalation path to the Défenseur des droits (the Rights Defender) if the organization doesn’t resolve the issue. This contact information has to live inside the accessibility statement itself.
5. Publish a Multi-Year Accessibility Plan
The schéma pluriannuel is a public roadmap covering at least three years, with annual action plans showing concrete, dated commitments rather than vague intentions to “improve accessibility over time.” You can read our blog that lays down steps to implement a robust digital accessibility strategy.
RGAA’s Technical Requirements at a Glance
RGAA’s 106 criteria translate into recognizable, practical rules across a handful of areas:
- Structure: logical heading hierarchy, a declared page language, and proper use of landmark elements like header, nav, and main
- Color and contrast: a 4.5:1 ratio for normal text, 3:1 for large text and UI components
- Images: meaningful alt text on every informative image, and alt=”” on purely decorative ones
- Navigation: full keyboard operability, a visible focus indicator, and at least two ways to find any page
- Forms: a label on every input, grouped related fields, and clear error messaging
- Multimedia: captions on video, no autoplay without consent, and accessible alternatives for downloadable files
Each of these maps to a specific RGAA test, with its own pass-fail method, rather than a general principle left open to interpretation.
What’s Changing With RGAA 5
RGAA 5 is currently in development, with publication expected by the end of 2026. DINUM has confirmed it will incorporate WCAG 2.2, extend coverage to mobile apps and office documents more explicitly, and continue Arcom’s role as the enforcement authority.
Organizations don’t need to wait for RGAA 5 to act. DINUM has stated clearly that ongoing accessibility work should continue without delay, since RGAA 4.1.2 conformity carries forward rather than becoming obsolete once the new version arrives.
Getting Started With RGAA Compliance
RGAA compliance isn’t a single checkbox. It’s an ongoing legal obligation that touches legal teams, developers, designers, and content owners at the same time, and it sits alongside a separate set of obligations under the European Accessibility Act for companies with French or EU exposure.
Organizations unsure whether they fall under RGAA, the European Accessibility Act, or both, are better served by a proper scoping review than by guessing from a generic checklist. Contact us if you need help to determine exactly which obligations apply, and what an audit against the actual 106 criteria would surface.