Web Accessibility (RGAA): What French Law Actually Requires

The legal obligation to comply with the RGAA (France's general framework for improving accessibility) applies first and foremost to public bodies and to companies whose revenue exceeds a threshold set by regulation. Other organisations are not legally required to comply immediately, but accessibility remains recommended good practice for any website, regardless of any legal obligation.

The real problem: confusing legal obligation with good practice

Web accessibility suffers from a common misunderstanding: some believe it only concerns public bodies, while others wrongly assume it already applies to every professional website. The reality is more nuanced and keeps evolving, notably under the European Accessibility Act, which is gradually widening the scope of obligations to include certain private-sector players (online banking, e-commerce, transport, and telecommunications, among others). Understanding precisely who is covered today avoids two symmetrical mistakes: overlooking a real obligation, or wrongly believing an obligation applies when it doesn't concern your organisation.

This article focuses specifically on the legal framework and obligations: who is covered, and what penalties exist. For the practical implementation of accessibility on a website (contrast, keyboard navigation, text alternatives), see our dedicated practical guide to building an accessible website.

Who is legally covered by the RGAA

The French framework, stemming from the law for a digital republic and its implementing decrees, defines several categories of organisations subject to the obligation:

The revenue threshold and the precise list of sectors concerned evolve along with the regulations and their transposition; for an exact assessment of your situation, it is advisable to consult the texts in force or specialised legal counsel, as the rules change regularly.

The concrete obligations for organisations covered

An organisation legally subject to the RGAA must notably:

• Publish an accessibility statement on its website, specifying the level of compliance, any non-accessible content, and any exemptions.
• Draw up a multi-year accessibility plan, generally covering three years.
• Publish an annual action plan detailing the actions planned for the current year.
• Provide a contact channel allowing users to report an accessibility shortfall and be directed to an alternative solution.

The penalties provided for

For organisations legally subject to the rule, failing to meet accessibility obligations (no accessibility statement, no multi-year plan, no response to reports) can lead to a formal notice, followed by an administrative fine if compliance is not achieved. These penalties fall under the authority designated by the regulations and, at this stage, only concern organisations explicitly identified as subject to the obligation.

Why apply the RGAA even without a legal obligation

Outside the strictly mandatory framework, applying RGAA principles remains worthwhile for several reasons unrelated to legal constraint: widening the site's potential audience to people with disabilities or temporary limitations, reducing the risk of discrimination in access to a service, and more broadly improving the site's usability for all visitors (an accessible site is generally also easier to use on mobile or on a slow connection). The scope of legal obligations also tends to widen over time, which makes reasonable anticipation a better approach than a last-minute scramble.

What to remember

• The legal obligation to comply with the RGAA targets public bodies and companies above a revenue threshold set by decree, first and foremost.
• The European Accessibility Act is gradually widening the scope to certain private sectors (banking, e-commerce, transport, telecoms).
• Organisations covered must publish an accessibility statement, a multi-year plan, and an annual action plan.
• Failure to meet these obligations can lead to an administrative fine after a formal notice.
• A very small business or sole trader with no direct legal obligation remains free to apply the RGAA as good practice.
• For the concrete technical implementation, see the dedicated practical guide to building an accessible website.

Frequently asked questions

Is a typical SME legally required to comply with the RGAA? In most cases, no. The obligation targets public bodies and companies above certain revenue thresholds first. An SME can nonetheless apply it as good practice.

What penalties exist for non-compliance for an organisation that is covered? An administrative fine can be issued after a formal notice has gone unanswered, for organisations legally subject to the obligation.

Is a non-profit's website covered by the obligation? It depends on the association's size and status. Associations recognised as being of public utility or delegated a public-service mission can fall within the scope of the obligation; others generally do not.

How do I know precisely whether my website is covered by the obligation? The reference texts set out the thresholds and categories concerned. If in doubt, specialised legal advice or the official resources from the DINUM can help clarify your status.

In summary

The legal obligation for RGAA accessibility today only directly concerns part of the websites out there: public bodies, large companies, and sectors gradually brought in by the European Accessibility Act. This general overview does not replace a precise assessment of your own situation; if in doubt, specialised legal advice remains the most reliable resource. Whether or not your organisation is subject to the obligation, VeryAppi applies baseline accessibility good practices on the websites it builds.