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RGAA France: The Accessibility Standard Your Site Is Measured Against

If you run a website or app that reaches French users, you will eventually meet the RGAA. In France it is the official method auditors use to decide whether a digital service is accessible, and it is the document a regulator points to when something is challenged. Understanding RGAA France is less about learning a new set of rules and more about learning how France tests the rules you may already know from WCAG.

This guide explains what the Référentiel général d'amélioration de l'accessibilité actually is, how it maps onto WCAG 2.2 and EN 301 549, which organisations it binds, and the specific accessibility-statement obligations that trip up most teams. The technical bar is WCAG; the RGAA is how France checks you cleared it.

What the RGAA actually is

The RGAA (Référentiel général d'amélioration de l'accessibilité) is France's official accessibility framework, maintained by the DINUM (Direction interministérielle du numérique). It is not a separate set of accessibility goals that competes with international standards — it is a testing methodology built directly on top of the Web Content Accessibility Guidelines.

In practice the RGAA does two things WCAG alone does not. First, it turns each applicable success criterion into concrete, numbered test cases organised into thematic topics — images, frames, colour, multimedia, tables, links, scripts, mandatory elements, structure, presentation, forms, navigation, and consultation. Second, it tells an auditor exactly how to evaluate each one, so two different auditors checking the same page should reach the same verdict. That repeatability is the whole point.

So when a French audit report cites a criterion number, it is pointing at an RGAA test that wraps a specific WCAG requirement. The RGAA is the wrapper; WCAG is the substance inside.

How the RGAA maps to WCAG and EN 301 549

The cleanest way to picture the French stack is three layers. WCAG 2.2 Level A and AA sits at the bottom as the technical requirements. EN 301 549, the harmonised European standard, incorporates those WCAG criteria for the web and adds clauses for software, documents, and hardware. The RGAA then sits on top as France's national testing method for verifying conformance, aligned with both.

Because all three layers share the same WCAG core, the work converges. A page that genuinely meets WCAG 2.2 AA will pass the corresponding RGAA tests, because those tests are the WCAG criteria expressed as pass/fail checks. That includes the WCAG 2.2 additions auditors now expect: 2.4.11 Focus Not Obscured (Minimum, AA), 2.5.7 Dragging Movements (AA), 2.5.8 Target Size (Minimum, AA) at 24 by 24 CSS pixels, 3.2.6 Consistent Help (A), 3.3.7 Redundant Entry (A), and 3.3.8 Accessible Authentication (Minimum, AA). Note that WCAG 2.2 also removed the former 4.1.1 Parsing criterion.

The familiar AA workhorses are all in scope too: 1.4.3 contrast of at least 4.5:1 for normal text and 3:1 for large text and UI components, 1.4.4 Resize Text, 1.4.10 Reflow, 1.4.12 Text Spacing, 2.4.7 Focus Visible, and 4.1.3 Status Messages. If you are unsure where you stand, you can scan your site against WCAG 2.2 to clear the machine-detectable failures before a human auditor ever opens the page.

Who the RGAA applies to

The obligation historically targets the public sector, and that scope is broad. It covers French state services, local authorities (régions, départements, communes), public institutions, and bodies carrying out a public-service mission. It also reaches certain large private companies brought into scope under French law above a defined revenue threshold.

Separately, the European Accessibility Act extends binding accessibility duties to a wide range of private businesses. The two regimes overlap rather than conflict: France transposes EU accessibility law nationally, and the RGAA remains the practical yardstick auditors reach for. If your business falls under either regime, building to the same WCAG 2.2 AA baseline satisfies both.

  • Public bodies and public-service missions — long-standing RGAA obligations covering websites, intranets, extranets, and mobile apps.
  • Large private companies above the French revenue threshold — pulled into national scope.
  • Businesses covered by the European Accessibility Act — e-commerce, banking, e-books and e-readers, electronic communications, audiovisual media access services, transport, and self-service terminals such as ATMs and ticketing machines, applicable from 28 June 2025.
  • Suppliers and agencies — if you build digital services for any of the above, conformance is effectively a contractual requirement.

A useful rule of thumb: if you are not certain you are exempt, assume the WCAG 2.2 AA baseline applies and work from there. The cost of conforming is almost always lower than the cost of an enforcement challenge.

The accessibility statement and declaration obligations

This is where the RGAA gets specific, and where many otherwise-compliant sites fall short. Conformance is not just a technical state — it has to be declared, publicly and in a prescribed form. France expects three distinct artefacts, and missing any one is itself a failure.

  • A visible compliance mention on every page (typically in the footer) stating the conformance level: "totalement conforme", "partiellement conforme", or "non conforme".
  • A full accessibility statement (déclaration d'accessibilité) reachable from that mention, listing the conformance rate, the non-conformant content, any derogations, the testing method, and a way to contact the organisation and escalate complaints.
  • A multi-year accessibility plan (schéma pluriannuel) and its annual action plan, published for organisations in scope.

The conformance rate is a number, not a vibe. An RGAA audit produces two headline rates: the conformance rate, the share of applicable criteria passed, and the average compliance rate across pages, with per-topic results behind them. A single failed criterion can pull you from "totalement conforme" to "partiellement conforme", so the statement must be honest about gaps rather than aspirational.

Treat the statement as a living document. The declaration must reflect the current state of the service, so re-audit and re-publish whenever you ship a significant change rather than letting last year's rate sit stale in the footer.

A practical path to RGAA conformance

Start by closing the failures a machine can catch — missing alt text, low contrast, unlabelled form fields, broken heading order, missing language attributes. These are fast wins and they clear the noise so manual testing can focus on judgement calls. Then audit against the RGAA topics with a keyboard and a screen reader: tab order, visible focus, error identification, and reflow at 320 CSS pixels are the areas automated tools cannot fully verify.

Finally, document everything. Record which criteria pass, which fail and why, and what your remediation timeline is — that record is the backbone of both your declaration and your action plan. A free WCAG 2.2 scan is the cheapest possible first step before you commission a formal RGAA audit.

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FAQ

Is the RGAA the same thing as WCAG?

No, but they are tightly bound. WCAG 2.2 supplies the technical success criteria; the RGAA is France's official method for testing whether a service meets them, expressed as numbered, repeatable test cases. If you genuinely meet WCAG 2.2 Level A and AA, you will pass the corresponding RGAA tests.

Does the RGAA apply to private companies?

It can. Large private companies above a defined French revenue threshold are in scope, and the European Accessibility Act extends binding accessibility duties to many more private businesses — e-commerce, banking, e-books, transport and others — from 28 June 2025. The RGAA remains the practical yardstick auditors use in France.

What is the difference between the RGAA and EN 301 549?

EN 301 549 is the harmonised European standard that incorporates WCAG for the web and adds requirements for software, documents and hardware. The RGAA is France's national testing methodology aligned with it. EN 301 549 says what to meet; the RGAA tells a French auditor exactly how to verify it.

What must a French accessibility statement contain?

It needs a visible per-page compliance mention (totalement, partiellement, or non conforme), a full déclaration d'accessibilité listing the conformance rate, non-conformant content, derogations, the test method and contact and complaint routes, plus a multi-year plan for organisations in scope.

How is the RGAA conformance rate calculated?

An RGAA audit reports the conformance rate as the share of applicable criteria that pass, alongside an average compliance rate across pages. Because a single failed criterion drops you below total conformance, the rate must be reported honestly. Re-audit and update your published statement whenever you ship significant changes.

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