RGAA: what is really changing for businesses
The RGAA has 106 criteria. Put like that, the subject is enough to put off any marketing manager or SME owner. But for a business, the real question is not knowing these 106 criteria by heart. It is understanding what they actually change in the way you design and publish your digital content.
In this article, I go through the questions I am asked most often in meetings, with simple answers.
The RGAA in a nutshell
The RGAA (Référentiel général d’amélioration de l’accessibilité) is the French method for checking that digital content can be used by everyone, including people with disabilities. Its current version, 4.1.2, groups 106 criteria into 13 themes: images, colours, tables, links, structure, forms, navigation, downloadable documents…
Each criterion is checked through specific tests. This is what makes it possible to say whether a document is fully, partially or not compliant.
RGAA and the European Accessibility Act: what is the difference?
This is the most common confusion, and it is understandable.
- The European Accessibility Act (EAA) is a European directive that has applied since 28 June 2025. It defines who must make their products and services accessible.
- The RGAA is a technical framework. It defines how to measure the accessibility of digital content.
One sets the obligation, the other is a tool to check that you meet it.
Does this apply to my company?
It all depends on your size and your business. There are three scenarios.
Your turnover in France exceeds €250 million. You are subject to Article 47 of the 2005 French law, in the same way as public bodies. Your websites and online services must comply with the RGAA, and you must publish several documents: an accessibility statement, a multi-year plan and an action plan for the current year.
You offer certain services to consumers. Since June 2025, the EAA has applied in particular to e-commerce, banking services, passenger transport, electronic communications and e-books. In this case, the obligation applies to you, whatever your size, except in the case below.
You are a microenterprise. If you have fewer than 10 employees and your annual turnover or balance sheet total does not exceed €2 million, you are exempt for services.
What if you only sell to businesses? The EAA mainly targets services for consumers. But your key accounts and public-sector clients are paying more and more attention to the accessibility of the documents they receive. Better to see it coming.
What are the risks?
For companies subject to Article 47, Arcom (the French audiovisual and digital communications regulator) carries out checks. After a formal notice, it can impose a penalty of up to €50,000 for failing to meet accessibility rules, and up to €25,000 for other obligations, such as not publishing a statement.
For services covered by the EAA, checks are mainly carried out by the DGCCRF (the French consumer protection authority). A breach is a fifth-class offence, meaning a fine of up to €7,500 per offence for a company, doubled for a repeat offence.
Beyond fines, there is also your image: a customer who cannot read your catalogue will not necessarily complain. They will simply go elsewhere.
What is an accessibility statement?
It is a public page that states the compliance level of your website or service: fully, partially or not compliant. It lists the content that is not yet accessible, any exemptions, and how to contact you if there is a problem.
It is based on an audit carried out according to the RGAA. For companies subject to Article 47, the compliance level must also be shown on the home page.
What about my PDFs?
Yes, they are concerned. Many companies discover this along the way. The RGAA includes a dedicated criterion: every office document offered for download must, where necessary, have an accessible version. A compliant website that offers non-accessible PDF catalogues or brochures therefore sees its compliance level drop.
Under the EAA, office documents published before 28 June 2025 are exempt. Everything you have put online since then may be concerned. Find out more: Is your PDF catalogue still enough?.
What the RGAA actually changes in your content
For a marketing or communications team, the RGAA mainly translates into design habits:
- headings organised in a hierarchy, designed as a table of contents rather than just a visual effect;
- alternative text for images that carry information;
- sufficient contrast between text and background;
- tables built to be read cell by cell;
- explicit links rather than “click here”;
- documents structured from the layout stage, not just at export.
A new version, RGAA 5, has been announced for the end of 2026. It is due to include the latest international recommendations (WCAG 2.2) and strengthen the criteria for office documents and mobile apps. The basics remain the same: what you put in place today will not be wasted.
Anticipate rather than fix
Making a document accessible after the event means reworking its structure page by page. Building it in from the design stage costs much less, and the result is better.
A few good practices to adopt today:
- List your online materials: website, catalogues, brochures, product sheets, downloadable documents.
- Identify the most viewed and start with them.
- Brief your designers and suppliers: accessibility must be in the specification of every new document.
- Use heading styles in your layout tools, rather than enlarging text by hand.
- Plan an accessible version of every new document published online.
On this last point, several misconceptions die hard. Find out more: Digital accessibility: common misconceptions.
Review your materials
The easiest way to find out where you stand is to review your materials. At Connectedbook, we go through your catalogues and PDFs with you, then make them accessible or create an accessible web version.
You come away with a clear view of which materials need work and what to prioritise.