| 106 criteria | RGAA 4.1 — organized into 13 themes, built on WCAG 2.1 AA |
|---|---|
| €250M | French turnover threshold naming large private companies directly (Decree 2019-768) |
| <10 / <€2M | Micro-enterprise exemption from the EAA transposition |
| Jun 2025 | EAA transposition in force — broader private-sector obligation |
Four layers at a glance
Each layer answers a different question — reading only one gives an incomplete picture of what's actually required.
Law No. 2005-102, Article 47 (11 Feb 2005) is the foundation: it establishes that an accessibility obligation exists for online public communication services. Everything that follows amends or implements this article rather than replacing it, which is why guidance still cites a 2005 statute even when discussing a 2025 obligation.
The Digital Republic Act (2016) extends that obligation to mobile apps and software, and introduces the first real enforcement mechanism behind it.
Decree No. 2019-768 (2019) names the RGAA as the official technical standard for measuring compliance, and widens scope to large private companies for the first time.
The EAA transposition (Ordonnance n° 2023-859, Décret n° 2023-931), in force since June 2025, extends obligations across most of the private sector — a parallel regime sitting alongside the RGAA rather than replacing it.
Who must comply with the RGAA
- Public-law entities — the State, local authorities, and public institutions; covered directly, no threshold to check
- Public-service delegation / general-interest mission — transport operators, water/sanitation services, tourist offices, cultural institutions, even if privately run
- Large private companies — annual French turnover above €250 million (Decree 2019-768), regardless of public mandate
- Broader private sector, since June 2025 — extended by the EAA transposition, exempt only for micro-enterprises (<10 employees, <€2M turnover)
What is the RGAA?
- 106 testable criteria, organized into 13 themes (RGAA 4.1)
- Built on WCAG 2.1 Level AA, referencing EN 301 549
- Produces a conformance rate from a representative page sample, not a simple pass/fail
- Test results feed directly into the mandatory accessibility statement
Required documents
- Accessibility statement (déclaration d'accessibilité) — conformance level achieved, inaccessible content and why, a way to report a barrier
- Multi-year accessibility scheme — typically 3 years, showing accessibility as a planned, budgeted effort
- Annual action plan — the current year's slice of that roadmap
- Visible compliance status — displayed on the service itself (homepage/footer), not buried in a policy page
How to comply, in order
Compliance follows a dependency order — skipping ahead tends to produce a document that makes claims the organization hasn't earned.
Audit
Remediate
Write the accessibility statement
Publish the multi-year scheme and annual action plan
Display compliance status
Penalties for non-compliance
Two separate penalty regimes can apply, and exact figures vary by entity type and amendment history.
Decree 2019-768 fines
Administrative fines for missing/undisplayed RGAA information; amounts scale by entity type, renewable every 6 months while non-compliant
EAA transposition fines
A separate penalty track for private-sector scope; can apply to individuals and organizations, and recur for ongoing non-compliance
- Non-financial risk: formal notice procedures (mises en demeure) from advocacy groups — reputational exposure independent of any fine
- Procurement risk: public bodies and large private partners can lose eligibility for public contracts requiring demonstrated accessibility
RGAA vs. WCAG
- WCAG is the international technical standard published by the W3C
- RGAA 4.1 is built directly on WCAG 2.1 Level AA — not a competing standard
- RGAA adds a French testing methodology, a conformance-rate calculation, EN 301 549 references for non-web contexts, and a legal duty to publish a statement
- A site can honestly claim WCAG 2.1 AA conformance and still fail RGAA compliance without the required statement and French-format test results
Frequently asked questions
Does the RGAA apply to private companies?
Yes, for two reasons: large private companies with more than €250 million in French turnover are named directly in Decree 2019-768, and since June 2025 most other private companies are in scope through the EAA transposition, unless they qualify as a micro-enterprise.
Is WCAG compliance enough for France?
No. RGAA 4.1 is built on WCAG 2.1 Level AA, but it also requires a French testing methodology, a published accessibility statement, and EN 301 549 references for non-web contexts.
What is the difference between the RGAA and the European Accessibility Act?
The RGAA is France's national technical standard and testing methodology, historically focused on public-sector services and large private companies. The EAA is an EU directive transposed separately, broadening obligations across most of the private sector. The two run in parallel.
Is an accessibility statement mandatory?
Yes, for any organization within the RGAA's scope. It must state the conformance level achieved, list inaccessible content and why, and provide a way to report barriers — a generic commitment page doesn't satisfy this.
What happens if an organization fails to comply with the RGAA?
Exposure on multiple fronts: administrative fines under Decree 2019-768, a separate track under the EAA transposition if in scope, plus non-financial risks like formal notices from advocacy groups or reduced public-contract eligibility.
Source
- Loi n° 2005-102 du 11 février 2005, Article 47
- Loi n° 2016-1321 (Loi pour une République numérique)
- Décret n° 2019-768
- Ordonnance n° 2023-859 & Décret n° 2023-931 — EAA transposition
- Directive (EU) 2019/882 — European Accessibility Act
