Understanding RGAA: France’s Accessibility Law and What It Means for You

Introduction

In keeping with the EU's commitment to inclusivity, member states throughout the EU are enacting country-specific accessibility regulations as the historic European Accessibility Act (EAA) takes effect on June 28, 2025. By guaranteeing equitable access to society's digital and physical places, these initiatives seek to empower people with disabilities. The RGAA 4.1.2 web and digital accessibility law is essential in France. This legislation is dedicated to creating accessible digital environments, ensuring that websites and online services are usable by everyone, including people with disabilities.

What is RGAA?

Rooted in the principles of the United Nations’ 2006 Convention on the Rights of Persons with Disabilities (UNCRPD) and the Web Content Accessibility Guidelines (WCAG) established by the World Wide Web Consortium (W3C), France’s RGAA (Référentiel Général d’Amélioration de l’Accessibilité) stands as a cornerstone for digital accessibility compliance. RGAA, or the General Accessibility Improvement Framework, is a comprehensive collection of rules designed by the French government to ensure that all websites and digital apps are accessible. Although RGAA mainly borrows from WCAG, it modifies these ideas to conform to French law and cultural nuances. Its main objective is to eliminate the technological obstacles that keep disabled persons from participating fully in online activities. In order to ensure inclusion for users with a variety of disabilities, such as visual, auditory, cognitive and physical impairments, RGAA compliance is required for both public and private sector organizations.

Businesses operating in the European Union (EU) should be ready for the European Accessibility Act (EAA) and start planning their accessibility journey now. Look at how Barrierbreak can help businesses understand the importance of EAA and how they can ensure that their digital products and services are accessible and compliant.

What is the compliance deadline and actions required?

All deadlines for RGAA compliance have passed, underscoring the importance of immediate action for organizations that have not yet met the requirements. Public sector websites were mandated to be accessible by September 2020, while mobile applications, software, and digital interfaces such as ticket kiosks were required to comply by June 2021. For organizations still lagging behind, upgrading and implementing accessibility measures should be an urgent priority to avoid legal risks.

Key Compliance Actions Required

To align with RGAA, organizations must take the following steps:

• Publish an Accessibility Statement: Provide an online declaration of the website's current accessibility status to ensure transparency.
• Display RGAA Compliance Percentages:
  • Fully compliant: 100%
  • Partially compliant: 50% or higher
  • Noncompliant: Below 50%, or if the compliance status is unknown or untested. Include a link to the accessibility page or statement on all pages.
• Implement a Feedback Mechanism: Enable users to report any accessibility challenges they encounter.
• Provide Contact Information for the Rights Defender (Défenseur des droits): Allow users to escalate their concerns if site administrators fail to address reported issues.

Organizations that take these actions demonstrate their commitment to inclusivity, compliance, and improved user experiences for everyone.

Who needs to comply?

The foundation of RGAA compliance lies in Article 47 of France’s Law No. 2005-102 of February 11, 2005, which focuses on equal rights, opportunities, participation and citizenship for people with disabilities. With the groundwork established through the Decree of May 14, 2009, the accessibility obligations extend to various entities providing public communication services online.

Entities Required to Comply:

1. Public Sector Organizations:
   • All legal entities under public law.
2. Private Entities with Public Service Roles:
   • Organizations delegated with public service missions or established to meet general-interest needs (non-industrial or non-commercial). Compliance applies if:
     • Their activities are primarily financed by public authorities.
     • They are managed under public control.
     • Over half of their administrative, management, or supervisory members are appointed by public authorities.
3. Private Entities Formed by Public Authorities:
   • Companies created by public entities to fulfill general-interest needs (excluding industrial or commercial activities).
4. Large Private Companies:
   • Enterprises with an annual turnover exceeding 250 million euros, based on an average of the last three financial years in France.

Craft a practical and budget-friendly action plan for swift implementation of EAA with our accessibility consultants.

Why is Accessibility Crucial for Key Sectors?

While all organizations have a responsibility to ensure accessibility, certain sectors carry a heightened duty due to the critical nature of their services. Government agencies, healthcare providers, educational institutions and e-commerce platforms must prioritize accessibility to serve diverse populations effectively.

For public services, inclusivity is paramount to ensuring that everyone, regardless of ability, can access essential information and services. For businesses, complying with RGAA not only fulfills legal obligations but also demonstrates a commitment to broader societal inclusion, enhancing their reputation and reach. By championing RGAA compliance, these organizations lead the way in creating equitable digital experiences for all.

Who all are exempted?

While RGAA aims to make digital spaces accessible to all, certain services and content are exempt from the accessibility obligation. These exemptions are designed to acknowledge technical limitations, historical content and the scope of specific organizational roles. Here's a closer look at who and what is not affected:

Entities Exempted:

1. Online Public Communication Services:
   • These are defined as electronic communication processes providing signs, signals, writings, images, sounds, or messages to the public or categories of the public, as long as they do not constitute private correspondence.
2. Audiovisual Media Service Providers:
   • Media companies offering broadcast or on-demand audiovisual content are not subject to RGAA requirements.
3. Private Non-Profit Organizations:
   • Non-profits that do not provide essential public services or services specifically targeting people with disabilities are exempt from the legal obligations.

Content Exemptions:

Certain types of digital content fall outside the legal scope of RGAA, recognizing historical, technical, or functional constraints:

• Office Files Published Before September 23, 2018: Unless these files are essential for administrative procedures related to the organization’s tasks.
• Pre-Recorded Audio and Video Content Published Before September 23, 2020: Including content with interactive components.
• Live Audio and Video Content: Regardless of publication date.
• Maps and Mapping Services: As long as essential location or routing information is provided in an accessible format.
• Third-Party Content: Content not funded, developed, or controlled by the organization.
• Heritage Collection Reproductions: If making them accessible would compromise their preservation or authenticity, or if automated and economical solutions are unavailable for text transcription.
• Intranet and Extranet Content Published Before September 23, 2019: Exempt until these platforms undergo a significant redesign.
• Archived Content: Content on websites or mobile applications that are not necessary for ongoing administrative procedures and have not been updated or modified since September 23, 2019.

Key Considerations in RGAA

1. Content:
   • Use Logical Headings: Employ semantic heading tags like <h1>, <h2>, etc., to structure your content hierarchically.
   • Define the Language: Set the language attribute in your HTML to help screen readers interpret the text correctly.
   • Utilize Landmark Elements: Incorporate elements such as <header>, <footer>, <nav>, <main>, <article>, <section>, and <aside> where applicable to improve navigation.
   • Structure Lists Properly: Use <ul>, <ol>, <li>, <dl>, <dt>, and <dd> to create clear and accessible lists.
   • Provide Meaningful Links: Ensure links are descriptive. For linked images, use title attributes or provide clear text descriptions.
2. Color Contrast:
   • Prioritize Contrast: Use colors with sufficient contrast. Text smaller than 24px should maintain a ratio of 4.5:1, while larger text and UI elements need at least 3.0:1.
   • Understand Exceptions: Elements like disabled controls, logos and decorative text aren’t subject to these rules but should still consider usability.
3. Images:
   • Text Descriptions: Use the alt attribute for <img> tags or the aria-label attribute for elements like <svg>, <canvas> and <object>.
   • Hide Decorative Images: Mark purely decorative visuals with alt="" or aria-hidden="true.
4. Navigation:
   • Keyboard-Only Navigation: Users should be able to access every feature with the keyboard.
   • Visible Focus Indicators: Make sure focusable elements have a visible state, not just a subtle color change.
   • Multiple Navigation Options: Offer at least two ways to navigate, such as menus, sitemaps or search features.
   • True Hidden Content: Hide elements from screen readers using display: none or aria-hidden="true.
5. Multimedia:
   • Subtitles: Provide subtitles for audio and video content.
   • Avoid Autoplay: Allow users to initiate playback.
   • Accessible Downloads: Ensure downloadable media is accessible or provide alternatives.
6. Tables:
   • Define Headers: Use <th> tags for rows and columns.
   • Add Captions and Titles: Include a <caption> for description and a title attribute for clarity.
   • Tabular Data: Use tables only for depicting tabular data. Avoid using it for layout purposes.
7. Forms:
   • Label Inputs Clearly: Use <label>, aria-label, or aria-labelledby for every input.
   • Group Related Fields: Wrap similar inputs like checkboxes in <fieldset> with a <legend>.
   • Accessible Choice Inputs: Use <select> components or ARIA-compliant comboboxes for dropdown options.
8. Dynamic Content:
   • Avoid Rapid Flashes: Keep animations or flashes under 3 per second to prevent triggering seizures.
   • Prevent Sudden Changes: Avoid unexpected window openings or navigation without user initiation.
   • Control Time Limits: Allow users to disable or extend time-based actions.

Go through this comprehensive Web Accessibility Playbook to deep dive into how you can comply to RGAA.

Consequences of Non-Compliance

Organizations operating within French borders are legally obligated to adhere to RGAA standards. Failure to comply can lead to fines, administrative sanctions and lawsuits filed by individuals encountering accessibility barriers. However, the consequences of non-compliance extend far beyond financial and legal penalties. They affect brand reputation, user engagement and inclusivity on a profound level.

Brand Reputation

Accessibility is a critical pillar of inclusivity and ignoring it sends a clear message to the public about an organization’s priorities, or lack thereof. According to the National Institute of Statistics and Economic Studies (INSEE), 12 million people in France live with some form of disability, making up 24% of the active population and 18% of the total population. These numbers are growing as the population ages, making accessibility a vital issue for a significant portion of society. Imagine people with disabilities facing difficulties to proceed to the checkout page due to inaccessible design on an ecommerce website. This tarnished the brand image leading to decline in revenue and lost opportunities.

Fines, Administrative Sanctions, and Potential Lawsuits

Non-compliance with RGAA can lead to substantial financial penalties and administrative sanctions. Moreover, affected individuals or advocacy groups may file lawsuits against organizations failing to meet accessibility requirements, potentially resulting in prolonged legal battles and even higher costs. Taking the example from the previous point, an inaccessible ecommerce website can also lead to lawsuit from resulting in not only hefty fines but also mandatory accessibility overhauls.

Locked Out of Essential Engagement & Data

When people with disabilities are excluded from digital platforms, they lose access to vital services, opportunities and information. The societal cost of non-compliance transcends monetary implications, as it denies millions of individuals their basic rights to education, employment and engagement. Imagine a student with motor impairment unable to navigate university’s website, or a visually impaired job seeker unable to access online job portals or an elderly person excluded from online healthcare services just because the website is inaccessible.

These are not hypothetical scenarios. They represent the real, lived experiences of millions of people with disabilities across the globe who face these barriers on a daily basis.

Conclusion

Accessibility should not be viewed as a daunting challenge. Rather, it’s an opportunity to broaden your audience, improve user experience and demonstrate your organization’s commitment to equality.

The French government offers a wealth of resources, including online guides, training programs and accessibility audits, available in French, English and other languages, to guide organizations through the RGAA compliance process. These tools are designed to make accessibility an attainable goal, empowering businesses to take meaningful steps toward inclusivity.

At BarrierBreak, we specialize in helping organizations like yours navigate the RGAA landscape with ease. From detailed accessibility audits to implementing user-friendly designs, our expert team ensures your digital platforms not only meet regulatory standards but also deliver exceptional experiences for all users.

Ready to make your digital platforms RGAA-compliant and create an inclusive future? Let’s get started. Contact us today at sales@barrierbreak.com