Image description: An official French government document with the Marianne emblem and a wax-seal stamp resting on a polished wooden desk — the bureaucratic anchor of France’s RGAA accessibility framework.

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France’s Référentiel général d’amélioration de l’accessibilité (RGAA — the General Accessibility Improvement Framework) is the country’s national technical reference standard for digital accessibility. Now in version 4.1.2, it operationalises Article 47 of the Loi n° 2005-102 du 11 février 2005 pour l’égalité des droits et des chances (Law of 11 February 2005 on equal rights and opportunities) and aligns French public-sector compliance with WCAG 2.1 level AA. For the broader European context, see the national disability-rights regulations index and the Disability World primer on the European Accessibility Act (EAA).

Two features make the RGAA unusual among European national frameworks. First, every covered entity must publish — on the home page of the service — an annual déclaration d’accessibilité (accessibility statement) backed by a documented self-audit and a multi-year schéma pluriannuel (multi-year roadmap). Second, while the legal obligation formally binds the public sector, the RGAA bleeds into private contracts through public procurement: any vendor selling a covered digital service to the French state effectively has to conform to it. With the Loi du 9 mars 2023 portant diverses dispositions d’adaptation au droit de l’Union européenne (BFG, the French transposition of the EAA) taking effect on 28 June 2025, the obligation now also reaches a defined set of private services. This primer covers what the RGAA is, who it binds, how it is enforced, and what the 2026 picture looks like.

Purpose and scope

The RGAA is a technical reference framework maintained by the Direction interministérielle du numérique (DINUM) — the inter-ministerial digital directorate inside the Prime Minister’s office — that translates the WCAG success criteria into a structured French-language audit methodology. It is not, in itself, the source of legal obligation: the obligation comes from Article 47 of the 2005 Law, fleshed out by decree n° 2019-768 du 24 juillet 2019 and the implementing arrêté of 20 September 2019 (revised in 2020 and 2023). The RGAA is the document those instruments incorporate by reference as the conformance benchmark.

Version 4 of the RGAA, published in 2019 and updated through point releases to 4.1.2 in 2023, restructured the framework around WCAG 2.1 level AA. It contains 106 tests grouped under 13 thematic criteria — images, frames, colours, multimedia, tables, links, scripts, mandatory elements, structure of information, presentation of information, forms, navigation, and consultation. Each test maps to one or more WCAG success criteria and is paired with a fixed audit method: what the auditor must check, with which assistive technology, and how to record the result as conformant, non-conformant, or non-applicable.

Who is covered

The obligation under Article 47 of the 2005 Law, as amended by the Loi n° 2016-1321 du 7 octobre 2016 pour une République numérique (Digital Republic Act), extends to:

  • Public-sector bodies — central government, local authorities (regions, departments, communes), public hospitals, public universities, and any administrative public establishment.
  • Bodies governed by public law — entities that, while not strictly part of the administration, are publicly financed or controlled, such as social-security funds and certain national agencies.
  • Private organisations carrying out a public-service mission — operators of public transport, public broadcasters, and certain delegated-service concessionaires.
  • Private entities above the threshold — private companies with a turnover in France above EUR 250 million over the most recent three fiscal years, brought in by the 2018 Loi pour la liberté de choisir son avenir professionnel (Law on the freedom to choose one’s professional future) and detailed in the 2019 decree.

The EUR 250 million threshold is the bridge that surprises non-French observers: the RGAA is often described as a “public-sector” framework, but in practice large private companies operating in France — banks, telecoms, retailers, energy providers — are already inside its perimeter, independently of the EAA. With the BFG transposition taking effect in 2025, the perimeter has widened further to cover specific consumer-facing private services regardless of turnover.

Key provisions: the audit obligation

What distinguishes the RGAA from a soft reference standard is the operational compliance architecture written into the 2019 decree and arrêté. Every covered entity must do four things, on a rolling annual cycle.

The accessibility statement

First, publish a déclaration d’accessibilité on every covered digital service — website, mobile application, intranet, extranet, and back-office tool used by the public — accessible from the home page. The statement must follow the template in the arrêté: declared conformance state (totally / partially / non-conformant), the conformance rate as a percentage of RGAA tests passed, a list of non-accessible content with justifications, the audit method and date, and the contact channels for users to report accessibility problems and request alternatives.

An accessibility statement that claims “totally conformant” must rest on an audit carried out by an external or qualified internal auditor against the full 106-test RGAA matrix. “Partially conformant” requires the audit and a conformance rate of at least 50 percent of applicable tests. Below 50 percent, the service must declare “non-conformant” — a statement that, by 2026, has become uncomfortable to display publicly given press and DPO attention.

The multi-year roadmap

Second, every covered entity must publish a schéma pluriannuel de mise en accessibilité — a three-year accessibility roadmap — and an annual action plan derived from it. Both documents are public. The roadmap names the services covered, the budget allocated, the governance arrangements (the named accessibility referent), and the milestones; the action plan lists the concrete remediation work scheduled for the year. DINUM publishes its own roadmap as a worked example, and Anct (the Agence nationale de la cohésion des territoires) supports smaller local authorities in drafting theirs.

User feedback and ombudsman recourse

Third, every accessibility statement must give users a feedback channel and explain the route to the Défenseur des droits — the French ombudsman — if no satisfactory response is received. The Défenseur des droits has, since 2019, treated digital-accessibility complaints as a category in its own right, and its annual reports name covered entities found to be in breach. Although the Défenseur’s recommendations are not binding, they are publicly issued and have moved the needle on several large public-service migrations.

Mandatory training

Fourth, the 2019 decree requires covered entities to train staff who design, develop or publish digital content. Training is not specified by hours, but the schéma pluriannuel must name the staff trained and the providers used. DINUM’s Design Gouv guidelines and the Accessibilité numérique course catalogue maintained by the public-service training agency are the de facto reference offerings; private universities and bootcamps that run RGAA-aligned curricula have proliferated since 2022.

Timelines: how the RGAA reached version 4.1.2

  • 11 February 2005 — Article 47 of the loi pour l’égalité des droits et des chances establishes the principle that public-sector online services must be accessible.
  • 2009 — RGAA version 1 published. Built on WCAG 1.0; immediately criticised by DPOs as too vendor-friendly.
  • 2014 — RGAA version 2 aligned with WCAG 2.0 level AA.
  • 7 October 2016 — Loi pour une République numérique extends the obligation to cover online public-service bodies and introduces the private-sector turnover threshold (then EUR 250 million).
  • 2017 — RGAA version 3.2017 published; first version to integrate an audit grid intended for routine self-assessment.
  • 2019 — Decree n° 2019-768 of 24 July 2019 and the implementing arrêté of 20 September 2019 set the operational obligations — accessibility statement, schéma pluriannuel, annual plan, training. RGAA version 4 published the same year, aligned with WCAG 2.1 AA and Web Accessibility Directive (2016/2102) requirements.
  • 2020–2023 — Point releases 4.0, 4.1, 4.1.1 and 4.1.2 refine audit methodology, expand mobile-app coverage, and clarify scoring rules.
  • 9 March 2023 — Loi portant diverses dispositions d’adaptation au droit de l’Union européenne (BFG) transposes the European Accessibility Act into French law. (The user assignment cited “loi du 19/12/2023”; the operative French enabling vehicle for the EAA was the BFG, with the implementing decree adopted later in 2023.)
  • 28 June 2025 — BFG provisions for private consumer-facing services enter into force, mirroring the EAA’s application date across the EU.
  • 2026 — first full reporting year under the expanded perimeter; the ARCOM transparency report incorporates compliance data on private-sector services for the first time.

Enforcement: ARCOM, DGCCRF, and the Défenseur des droits

French digital-accessibility enforcement runs across three authorities with overlapping but distinct mandates. Understanding which authority does what is the difference between a token compliance posture and a defensible one.

ARCOM — the platform regulator with the accessibility brief

The Autorité de régulation de la communication audiovisuelle et numérique (ARCOM) — created in 2022 by the merger of the audiovisual regulator CSA and the online-content body HADOPI — inherited responsibility for monitoring public-sector and large-private digital accessibility under Article 47. ARCOM publishes a periodic rapport sur l’application de l’article 47 naming covered entities, their declared conformance rates, and the entities that failed to publish a statement at all. The 2025 report covered roughly 4,800 in-scope organisations; about a third had no accessibility statement on the home page in the form prescribed.

ARCOM has, since 2020, the power to issue administrative fines of up to EUR 50,000 per service for failure to publish a compliant accessibility statement, failure to produce a schéma pluriannuel, or publication of a statement materially misrepresenting the conformance state. The fine ceiling was raised from EUR 25,000 by the 2023 reform and is doubled on repeat breach. By 2026, ARCOM has issued more than two dozen fines, almost all against private-sector entities above the turnover threshold; public-sector fines remain rare and reputational pressure does the work instead.

DGCCRF — consumer-protection enforcement on the private side

The Direction générale de la concurrence, de la consommation et de la répression des fraudes (DGCCRF) — the consumer-protection and competition directorate inside the Ministry of Economy — handles enforcement on private-sector consumer services brought into scope by the BFG. Where ARCOM polices the Article 47 obligation as such, DGCCRF polices the EAA-derived obligations on e-commerce, banking, transport ticketing, e-books, and the other categories listed in Annex I of Directive 2019/882. DGCCRF agents have inspection powers, can issue administrative penalties up to EUR 75,000 for legal entities, and refer the most serious cases to public prosecutors.

The split matters because a large French retailer’s website is, simultaneously, in scope of ARCOM under the EUR 250 million threshold and of DGCCRF as a consumer e-commerce service under the BFG. Both authorities can act; in practice DINUM has coordinated a memorandum of understanding clarifying who leads on which file.

The Défenseur des droits — individual complaints

The Défenseur des droits handles individual complaints from users who cannot access a covered service. The institution’s recommendations are not binding but are publicly published, and in repeated cases the Défenseur has referred files to ARCOM for follow-on administrative action. The 2024 annual report logged more than 1,600 digital-accessibility complaints, the highest annual figure since the category was created.

How the RGAA bleeds into private contracts

The RGAA’s reach beyond its formal scope is largely a function of French public procurement. Article L2112-2 of the Code de la commande publique (Public Procurement Code) and the standard cahier des clauses administratives générales (CCAG) templates published by Bercy require contracting authorities to integrate accessibility requirements into technical specifications for digital services. In practice, every state, region, department, commune, hospital, university, or public-establishment tender for a website, an application, a CMS, a customer-management system, or an intranet now carries an RGAA conformance clause.

For vendors, the consequence is direct. A SaaS company selling a public-sector ticketing platform must demonstrate RGAA conformance at contract signature, embed an annual audit obligation in the SLA, and accept liquidated-damages clauses tied to non-conformance. A consultancy bidding on a website redesign must staff the project with developers trained against the RGAA matrix. A design system that does not pass the RGAA 13-theme test grid does not win French public-sector business. The framework’s geographic and sectoral footprint is therefore much larger than the legal obligation suggests — and is one reason French accessibility-engineering firms have built mature consulting practices around RGAA audits.

The EAA expansion: 2025 onward

The European Accessibility Act (Directive 2019/882) was transposed into French law by the BFG of 9 March 2023, with implementing decrees adopted later in 2023. Application started on 28 June 2025, mirroring the EU-wide date. The transposition does not replace the RGAA; it sits alongside it. The RGAA remains the audit benchmark for public-sector services and for large private services already inside Article 47’s perimeter. The BFG extends a parallel obligation to a defined list of consumer-facing private services — e-commerce, retail banking and consumer credit, e-books and dedicated reading software, electronic communications services, audiovisual media services access, transport ticketing and information, and ATM and self-service terminals — regardless of company size, subject to the EU’s harmonised micro-enterprise exemption.

For those private services, conformance is measured against the harmonised European standard EN 301 549, which itself incorporates WCAG 2.1 AA for web and mobile. In other words, the practical content of compliance is the same as the RGAA — but the legal vehicle, the enforcement authority (DGCCRF rather than ARCOM), and the documentation template differ. Many French private-sector vendors that were already RGAA-compliant for public-sector contracts have used 2024 and 2025 to extend the same audit programme to their consumer products, on the reasonable view that running two parallel compliance regimes is more expensive than running one.

Practical implications: what to prepare for in 2026

For organisations newly inside the perimeter — particularly mid-sized French private services in the BFG categories — the operational lift breaks into four workstreams. None is exotic; all are unforgiving on timeline.

  • Run the audit. Whether against the RGAA 13-theme test grid (public sector and large private) or EN 301 549 (BFG private services), the audit must be documented, dated, and signed by an identifiable auditor. Self-audits are permitted but a third-party audit carries materially more weight if ARCOM or DGCCRF later challenges the published statement.
  • Publish the statement. The accessibility statement must sit on the home page of every covered service, follow the official template, and update at least annually. A missing or non-conformant statement is the failure ARCOM most commonly fines — easier to detect, easier to prove, easier to act on than substantive WCAG breaches.
  • Draft the schéma pluriannuel. Public-sector bodies have a three-year roadmap obligation. Private entities under the BFG have no equivalent formal duty but most large vendors are publishing voluntary roadmaps to manage procurement risk and DPO scrutiny.
  • Train and name a referent. Every covered entity must train its design, development and editorial staff, and name an accessibility referent. The referent’s contact details belong in the accessibility statement; the training programme belongs in the schéma pluriannuel.

Conclusion: a national framework with EU-shaped edges

Twenty-one years after the 2005 Law set the principle, the RGAA has become one of the most operationally specific national digital-accessibility frameworks in Europe — a 106-test audit methodology, a mandatory annual self-assessment, a public accessibility statement, a three-year roadmap, named referents, mandatory training, and two regulators (ARCOM and DGCCRF) with administrative-fine powers. The framework is not loud, but it is dense, and through public procurement it shapes a much larger commercial footprint than its formal scope.

The interesting question for the rest of the decade is whether the RGAA and the EAA settle into a clean two-track regime — RGAA for the public sector and large pre-existing private perimeter, EN 301 549 plus the BFG for the new private consumer services — or whether DINUM eventually publishes a fifth-generation RGAA that absorbs the EAA matrix and presents covered organisations with a single French-language framework. The 2024 RGAA consultation hinted at the latter. For now, organisations operating in France should assume both regimes apply and design their compliance programme around the broader of the two. For further reading, see the Disability World primer on the European Accessibility Act and the national disability-rights regulations index.