RGAA Guide: how to achieve compliance?

RGAA Guide: how to achieve compliance?

In brief

  • The RGAA (Référentiel Général d'Amélioration de l'Accessibilité) is the French framework that provides a practical implementation of the digital accessibility obligation. Achieving compliance means bringing your websites and applications in line with its criteria, measuring a compliance rate, publishing an accessibility statement, and producing a multi-year plan.

What is the RGAA?

The RGAA is the reference framework that makes France's legal digital accessibility obligation operational. It translates international criteria (WCAG) into a list of testable criteria and an evaluation methodology, enabling the accessibility level of a website or application to be measured objectively.

It is primarily aimed at the public sector (government bodies, local authorities, public institutions) and certain large companies, but serves as a useful reference for any organisation committed to accessibility.

Beyond technical compliance, the RGAA requires a structured approach: measuring, declaring, and planning improvement over time through a multi-year scheme. Accessibility is viewed as a continuous process, not a fixed state.

Who is affected?

The scope of the RGAA covers the public sector and part of the private sector. The EAA further extends accessibility to many private services.

  • Government bodies, local authorities and public institutions.
  • Organisations delegated to deliver public services.
  • Large companies exceeding certain turnover thresholds in France.
  • By extension via the EAA: many private services (e-commerce, banking, transport).

The concrete obligations of the RGAA

RGAA compliance takes the form of specific, visible deliverables that are regularly monitored.

ObligationWhat it entails
Compliance rateMeasurement of the percentage of RGAA criteria met
Accessibility statementPublic document indicating the level achieved
Visible noticeDisplay of the compliance level on the website
Multi-year schemeAccessibility roadmap and annual action plans

The statement and the level notice must be accessible and up to date; their absence constitutes a breach in itself.

RGAA, WCAG and EAA

The RGAA does not exist in isolation: it implements the WCAG and works in conjunction with the EAA.

  • WCAG: the international foundation whose criteria the RGAA implements in a testable manner.
  • EAA: extends accessibility to the private sector, with converging requirements.
  • Pooling: targeting WCAG Level AA serves both the RGAA and the EAA simultaneously.
  • Evidence: a declaration and a roadmap are expected under both frameworks.

What penalties apply in the event of non-compliance?

Non-compliance with RGAA exposes organisations to financial penalties and remediation obligations, as well as reputational risk and the exclusion of a portion of users.

BreachConsequence
Missing declaration / statementFinancial penalty, formal notice
Persistent non-accessibilityRemediation obligation, sanctions
Exclusion of usersLoss of audience, reputational damage

How to achieve compliance: the 6-step roadmap

Step 1 — Determine your obligations

Check whether you fall under the RGAA (public sector, delegated operators, large enterprises) and, where applicable, the EAA. Document this analysis to frame your obligations.

The scope includes websites, intranets, applications and relevant documents.

  • Verify your status with regard to the RGAA.
  • Cross-reference with any applicable EAA obligations.
  • Identify the sites and applications to be made compliant.

Step 2 — Audit against the RGAA

Carry out a RGAA compliance audit, which implements WCAG criteria, and calculate your conformance rate. Combine automated testing with manual testing using assistive technologies.

This audit establishes your baseline and feeds into the multi-year plan.

  • Audit against RGAA criteria.
  • Calculate the conformance rate.
  • Combine automated and manual testing.

Step 3 — Remediate and embed accessibility

Fix non-conformities (colour contrast, keyboard navigation, alternatives, structure, forms) and integrate accessibility from the design stage of all future developments.

Prioritise the most frequently used and most critical user journeys.

  • Remediate priority gaps.
  • Integrate accessibility from the design stage.
  • Train your teams on RGAA criteria.

Step 4 — Publish the statement and notice

Draft and publish the accessibility statement, display the conformance level prominently, and provide a means of reporting accessibility issues.

These elements are mandatory and subject to oversight.

  • Publish the accessibility statement.
  • Display the conformance level prominently.
  • Provide a reporting channel.

Step 5 — Establish the multi-year plan

Formalise a multi-year accessibility plan and annual action plans, describing the planned actions and their timeline.

This plan gives concrete form to the continuous approach required by the RGAA.

  • Draft the multi-year plan.
  • Break it down into annual action plans.
  • Publish and track its progress.

Step 6 — Maintain compliance

Re-audit regularly, fix regressions and update the accessibility statement and conformance rate. Accessibility is a process, not a one-time achievement.

Integrate checks into every production release.

  • Re-audit after each change.
  • Update the statement and conformance rate.
  • Remediate regressions promptly.

Common mistakes to avoid

  • Failing to publish the accessibility statement and the compliance level indication, both of which are mandatory.
  • Neglecting the multi-year roadmap, which is nonetheless required.
  • Relying solely on automated testing, which is insufficient for the RGAA.
  • Addressing accessibility at the end of a project rather than from the outset.
  • Ignoring the relationship with the EAA for the private sector.
  • Not re-auditing after updates, allowing regressions to take hold.

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Frequently asked questions

Who is subject to RGAA?

The public sector (government bodies, local authorities, public institutions), public service delegates, and large companies exceeding certain turnover thresholds in France. The EAA further extends accessibility requirements to many private-sector services.

What is the RGAA compliance rate?

This is the percentage of RGAA criteria met by a website or application, as measured during an audit. It must be stated in the accessibility declaration and displayed prominently.

What is the difference between RGAA and WCAG?

WCAG is the international reference framework; RGAA is its French adaptation, with testable criteria and an evaluation methodology. Targeting WCAG level AA enables compliance with the RGAA.

Does the RGAA require a multi-year plan?

Yes. Subject organisations must publish a multi-year accessibility implementation plan, broken down into annual action plans, in addition to the accessibility statement and the indication of the level achieved.

What is the link between RGAA and EAA?

The RGAA primarily targets the public sector in France; the EAA extends accessibility requirements to many private services across the EU. Both are based on WCAG, enabling compliance efforts to be shared. Make accessibility a quality and inclusion requirement.