France -- RGAA

What It Is

The Référentiel général d'amélioration de l'accessibilité (RGAA) is France's official audit methodology for digital accessibility, maintained by the Direction interministérielle du numérique (DINUM)^[1]. The current version is RGAA 4.1.2, published on the DINUM accessibility portal. It is the national instrument through which France implements Directive (EU) 2016/2102 on the accessibility of public-sector websites and mobile applications^[2], and it normatively points at WCAG 2.1 Level AA and EN 301 549 as the technical baseline.

What distinguishes RGAA from a bare WCAG reference is its test catalogue: 106 control criteria (critères de contrôle), each with a prescribed, deterministic test method covering HTML structure, images, colours, multimedia, forms, navigation, scripts, mandatory elements, and consultation contexts^[1]. An audit walks the catalogue against a sample of pages and outputs a conformance rate in percent, not a pass/fail on individual WCAG success criteria.

Why It Matters

The obligation and its penalties sit in French primary and secondary law, not in RGAA itself. Article 47 of Loi n° 2005-102 du 11 février 2005 (the "loi handicap") creates the accessibility obligation for online public communication services; Décret n° 2019-768 du 24 juillet 2019 operationalises Article 47 by naming RGAA as the technical reference and setting the enforcement regime^[3]. Under the décret, in-scope entities must publish an accessibility declaration, a multi-year accessibility plan (schéma pluriannuel, up to three years) and an annual action plan on each site's home page, plus a visible accessibility status label and a contact route for users to report barriers.

Non-compliance is punishable by an administrative fine pronounced by the minister in charge of disabled persons, capped at 20,000 EUR per online public communication service, reduced to 2,000 EUR for municipalities and their groupings with fewer than 5,000 inhabitants and certain small public bodies^[3]. The fine is per service and can be renewed, so a public body running several sites and apps faces cumulative exposure.

Scope

RGAA-backed obligations cover public-sector bodies (State, local authorities, public establishments), bodies delegated a public-service mission, and private-sector entities established in France whose annual turnover in France is at least 250 million EUR averaged over the last three financial years^[3]. The covered digital surface is wide: public-facing websites, intranets, extranets, mobile applications, packaged software, and digital street furniture. Note that the 250 million EUR threshold is the Article 47 / décret regime, which is narrower than the private-sector obligations that arrive in France through the transposition of the European Accessibility Act -- those follow a different scope test and should not be conflated with the RGAA obligation on this page.

How It Relates to WCAG and EN 301 549

RGAA 4 does not invent requirements. Its 106 criteria are a testable projection of WCAG 2.1 Level AA and the web-content clauses of EN 301 549, restructured so each criterion corresponds to one or more prescribed test steps. A site can therefore be "WCAG 2.1 AA" by self-assessment and still score poorly on an RGAA audit -- the audit is evidence-driven, and a criterion is only counted as conformant when the documented test method produces a pass result on the sampled pages.

Practical Implications

• If the 250 million EUR revenue test or public-sector scope applies, the outputs are not optional: accessibility declaration, schéma pluriannuel, annual action plan, visible status label on each site's home page, and a user-reporting contact route -- all required by Décret n° 2019-768^[3].
• Plan work against the 106 RGAA control criteria, not only against WCAG success criteria. The audit trail a French auditor will ask for is the RGAA test method and its result on sampled pages.
• Budget for an external RGAA audit against a representative page sample. The conformance percentage printed on the declaration is the number the Ministry and users will cite back.
• Treat the declaration as a living document: Décret n° 2019-768 requires it to be updated when the site changes materially and at least annually via the action plan.

Related Clauses

• Germany (BITV / BFSG)
• Italy (Stanca Law)
• EAA accessibility statements