What Is RGAA Compliance & Who Needs to Comply With It?

Understanding France’s RGAA Compliance for Accessibility

What Is RGAA Compliance & Who Needs to Comply With It?

Understanding France’s RGAA Compliance for Accessibility

Key Takeaways

Governments, organizations, and service providers are expected to ensure that digital services are usable by everyone, including people with disabilities. In France, this responsibility is formally addressed through RGAA compliance, a national accessibility framework designed to make digital content inclusive, usable, and legally compliant.

What Is RGAA?

RGAA, Référentiel Général d’Amélioration de l’Accessibilité, is France’s official framework for digital accessibility. It defines how websites, mobile applications, and digital services must be designed and maintained so they are usable by everyone, especially people with disabilities.
It is based on international accessibility standards such as WCAG and provides a structured list of 106 technical tests that organizations must follow. These tests help ensure that digital content is perceivable, operable, understandable, and robust for users relying on assistive technologies.
The framework applies across the entire digital lifecycle, from design and development to content updates and ongoing maintenance.

Which Organizations Need to Comply with RGAA?

RGAA compliance applies to a wide range of organizations operating in France, including:
  • Public Sector Organizations: Government ministries, public administrations, local authorities, and publicly funded institutions must comply with RGAA for all digital services they provide.
  • Private Entities with Public Service Roles: Organizations delivering public services on behalf of the government, such as utilities, transport services, or healthcare providers, are required to meet RGAA standards.
  • Private Entities Formed by Public Authorities: Companies or agencies created by public bodies to manage services or infrastructure must ensure RGAA compliance across their digital platforms.
  • Large Private Companies: Private organizations with annual revenues exceeding €250 million are legally required to comply with RGAA accessibility requirements for their websites, apps, and online services.

Benefits of RGAA Compliance

  • Inclusion: RGAA compliance ensures that everyone, regardless of disabilities, can easily access and use digital services and content from French public administrations. This promotes inclusivity and ensures equal access to information and services for all citizens.
  • Legal Requirements: Public administrations in France have to follow RGAA guidelines by law. Being RGAA-compliant helps these organizations steer clear of legal issues and ensures they meet the necessary accessibility standards.
  • Ethical & Social Responsibility: Ensuring digital content is accessible reflects an organization’s commitment to doing the right thing. It’s a way of respecting diversity and recognizing the rights of people with disabilities to access information and services on an equal basis with others.
  • Enhanced User Experience: Features designed for RGAA compliance not only assist users with disabilities but also enhance the overall user experience. For example, providing alternative text for images benefits not only users with visual impairments but also those in low-bandwidth situations or using text-only browsers.
  • Broader Audience Reach: Making digital content and services accessible means reaching a wider audience, including people with disabilities, older users, and those using assistive technologies. This inclusivity can lead to increased engagement, participation, and satisfaction among users.
  • Compliance with International Standards: RGAA compliance aligns with international standards like the Web Content Accessibility Guidelines (WCAG) from the World Wide Web Consortium (W3C). Following these standards ensures compatibility with various assistive technologies and devices, making digital content accessible to a diverse range of users.

What Are the Key Requirements of RGAA?

Organizations working toward RGAA compliance must implement the following core requirements:
  • Publish a formal accessibility statement explaining the current level of compliance.
  • Define the scope of accessible content and services covered by RGAA.
  • Provide a user feedback mechanism for reporting accessibility issues.
  • Include Rights Defender contact information for unresolved complaints.
  • Establish a multi-year accessibility plan with clear goals and timelines.
  • Remediate identified issues and retest regularly to maintain compliance.
  • Train staff and teams involved in content creation, design, and development.

Law 2005-102: The Legal Foundation of RGAA

RGAA is rooted in Law No. 2005-102, which established France’s commitment to accessibility and equal rights.
  • Equal Rights & Opportunities: The law ensures equal access to digital services for people with disabilities.
  • Public Sector Accessibility: Public services must be accessible by default, including digital communication channels.
  • Inclusion & Citizenship: Accessibility is framed as a fundamental condition for full participation in society.

RGAA Compliance Checklist

  1. Content: It's easier for everyone, especially those using screen readers, to understand well-organized content. Here's what to keep in mind:
    • Make sure the language attribute is set in the HTML.
    • Use a relevant structure for headings (like h1, h2, etc.).
    • Include elements like header, footer, nav, main, article, section, and aside where they fit.
    • Ensure links have clear descriptions or title attributes, especially for linked images.
    • Lists should use appropriate tags like ul, ol, li, dl, dt, and dd.
  2. Colors: Choosing the right colors and contrast is crucial, especially for those with color blindness or vision issues. Here are some guidelines:
    • Opt for colors with sufficient contrast.
    • Text smaller than 24px should have a contrast ratio of 4.5:1.
    • Text larger than 24px and UI elements like icons, borders, buttons, and charts should have a ratio of 3.0:1.
    • Some exceptions include disabled elements, logos, decorative text, and inputs with default browser styles.
  3. Images: Individuals who have visual impairments rely on screen readers to understand what the image in the document conveys. Here’s what an RGAA-compliant image should contain:
    • All important images should have text descriptions. For <img> tags, this means using the alt attribute, and for <svg>, <canvas>, <embed>, <object>, and tags with role="img", use the aria-label attribute.
    • To ensure a better experience for screen readers, it's recommended to conceal decorative images. You can achieve this by using alt="" for <img> tags or aria-hidden="true" for other tags.
    • Images with text, like memes, should have an alternative text containing the text from the image.
  4. Navigation: Making sure keyboard navigation works well is crucial for people with disabilities and those who prefer using the keyboard.
    • Users should be able to access all features of the page using only the keyboard.
    • Hidden content should be truly hidden from screen readers using display: none or the aria-hidden="true" attribute.
    • Elements that can be focused should have a visible indication when they are focused, not just a color change.
    • There should be at least two ways for users to navigate the website, like menus, sitemaps, or page search. However, small sites might only need the browser's search function.
  5. CSS: As people get older, they often rely on zooming features to see better.
    • Websites shouldn't make users scroll both horizontally and vertically at the same time (which means there should be no horizontal scrolling on regular sites).
    • Websites should be easy to read, whether the individual is holding their device vertically or horizontally.
    • The content should still be readable even if someone turns off CSS.
  6. Media: Media like videos and audio often contain important information that some people can't access visually or through hearing.
    • Use standard audio and video players like <audio> and <video>, not Flash or other technologies.
    • Include subtitles for both audio and video content using <track kind="captions">, especially for user-uploaded content.
    • For other types of media like carousels or slides, provide text alternatives.
    • Don't have media autoplay without user interaction.
    • If there are downloadable files, make sure they're accessible or provide an accessible alternative.

    Read More: How to Make Audios Accessible?

  7. Tables: It’s important to organize tables well so they make sense to people using screen readers. Here’s how to do it:
    • Use the <table> tag for tabular data only.
    • Describe the table with a <caption> tag.
    • Give the table a title attribute.
    • Include <th> tags for row and/or column headers.
  8. Forms: Forms can be tricky, especially for people using screen readers or navigating with a keyboard. Here’s how to make them easier to use:
    • Each input should have a label with <label>, aria-label, or aria-labelledby.
    • Keep labels close to the related inputs.
    • Group similar fields using <fieldset> tags (like radios or checkboxes).
    • Every <fieldset> needs a <legend>.
    • Use <select> components or ARIA comboboxes for choice inputs with options.
  9. Dynamic Content: It’s important to consider accessibility with dynamic content, like time limits and window openings:
    • Control or disable time limits to accommodate all users.
    • Don’t open windows without the user’s consent.
    • Use buttons, submit inputs, links, or elements with warnings for context changes.
    • Rapid flashes should have a frequency less than 3 per second or cover a small area.

How Does RGAA Testing Work?

RGAA testing involves a combination of automated checks and manual evaluations.
  • Audits assess compliance against the 106 RGAA criteria, including keyboard navigation, screen reader behavior, semantic structure, and visual presentation.
  • Testing typically results in a compliance score, a detailed issue report, and an accessibility declaration that must be published.

What Are the Different Exemptions Under RGAA?

RGAA allows limited exemptions, such as archived content, third-party content not under direct control, or content that would impose a disproportionate burden. However, exemptions must be documented and justified transparently.

What Are the Risks of Non-Compliance with RGAA?

  1. Legal & Regulatory Action

    • Organizations that fail to meet RGAA accessibility standards can face legal complaints from affected users.
    • Individuals can escalate accessibility issues to the Rights Defender, depending on the severity and real-world impact of the barriers.
  2. Public Disclosure & Enforcement Measures

    • If accessibility violations are confirmed, the Minister for Persons with Disabilities may publicly name the non-compliant service.
    • This public disclosure can occur within six months of official notification if the issues are not corrected in time.
    • Public reporting of non-compliance can increase scrutiny from regulators, advocacy groups, and the general public.
  3. Exclusion of Users

    • When digital services are not designed to be accessible, people with disabilities may be unable to use essential online programs or information.
    • Any online service launched without accessibility considerations risks excluding users regardless of intent.
  4. Increased Operational & Compliance Burden

    • Organizations may be required to conduct additional accessibility testing and audits to address identified issues.
    • Staff training becomes necessary to prevent recurring accessibility failures across systems and platforms.
  5. Procurement & Resource Allocation Risks

    • RGAA encourages allocating appropriate budgets, tools, and expertise to ensure accessibility obligations are met.
    • Omitting accessibility from procurement processes can lead to costly remediation and delayed compliance later.

How Does Continual Engine Help in Achieving RGAA Compliance?

Continual Engine supports organizations in meeting RGAA compliance through a combination of AI-driven automation and accessibility expertise. Here’s how we can help:
  • RGAA-aligned remediation: Makes websites, PDFs, and digital content compliant with RGAA, WCAG 2.2, PDF/UA, and EN 301 549 standards.
  • Scalable document accessibility: Remediates large volumes of legacy and new documents (PDFs, reports, forms) efficiently without compromising quality.
  • Built-in accessibility checks: Ensures accessibility is validated through testing and ongoing compliance monitoring.
  • Future-ready workflows: Integrates accessibility into everyday content and digital workflows, reducing risk and manual effort.

Ready to Make RGAA Compliance Simple & Scalable?

Let Continual Engine help you build inclusive digital experiences that meet RGAA without slowing down your teams.

Frequently Asked Questions (FAQs)

  1. What is the difference between RGAA and WCAG 2.1 AA?

    WCAG defines global accessibility principles, while RGAA adapts those principles into enforceable French legal requirements with specific testing criteria.

  2. What are common non-compliance issues in RGAA?

    Missing accessibility statements, poor keyboard navigation, insufficient contrast, untagged PDFs, and a lack of feedback mechanisms are some common RGAA-compliance failures.

  3. How does RGAA protect people with disabilities?

    RGAA ensures digital services are usable by people with visual, hearing, cognitive, and motor disabilities by enforcing structured accessibility requirements.

  4. How often should RGAA accessibility audits be done?

    Audits should be conducted at least annually and after major updates, redesigns, or new content deployments.

  5. How can organizations check RGAA compliance?

    Organizations can perform RGAA audits using automated tools, manual testing, screen reader evaluation, and accessibility reports.

Reviewed by:

Debangku Sarma

Digital Marketing Associate
Continual Engine

Vijayshree Vethantham

Senior Vice-President, Growth & Strategy
Continual Engine US LLC

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