What is RGAA 3?

There has been an increasing level of legislative and regulatory activity around the world about digital accessibility,

More than 12 million French citizens are affected by disability. ‘Référentiel Générale d’Accessibilité pour les Administrations’ or ‘Reference Document for the Improvement of Accessibility’ (RGAA 3) is the certification standard for public web sites in France. It defines the evaluation process and requirements to determine whether a website is accessible.

The WCAG 2.0 guidelines are the basis for RGAA 3.

How is RGAA 3 Evolving?

In 2005, Article 47 for equal rights and opportunities, participation, and citizenship of people with disabilities was passed in France.

For all public websites, such as research, towns, and services, the French central government websites were mandated as per RGAA2 in 2011 and in 2012.

RGAA 2.2 was updated in April 2015, where new technologies, such as Accessible Rich Internet Applications (ARIA) and HTML5 were considered.


Version 3.0 of the RGAA contains updates on the approach followed to determine compliance. It also includes technical updates to consider the evolutions of HTML.

Businesses That Need to Comply with RGAA 3

All sites funded by the public sector and businesses earning more than 250 million euros in annual revenue in France (three-year average) are required to comply.

The RGAA requires businesses to make websites, mobile apps, and other online services that have been localized for France accessible to people with disabilities.

Online businesses are expected to comply with the Web Content Accessibility Guidelines version 2.1, Levels A and AA, or ETSI/EN 301 549 v.2.1.2 (2018-08).

Businesses are expected to satisfy several other testing, notification, training, and documentation requirements in addition to meeting this accessibility requirement.

All websites created on or after October 1, 2019, are subject to the RGAA 3. The compliance obligations will become effective for software, mobile apps and other online services on July 1, 2021.

The inclusion of unit tests, which define how to determine compliance with each requirement, is an interesting addition in the RGAA.

This ensures that conformance with the standard can be tested through the execution of a series of unit tests on a site.

What are the Penalties for Non-conformance to RGAA 3?

Depending on the nature of the damage suffered, an aggrieved user may request for compensation from the judge or mediation from the Rights Defender.

Towards administrative sanctions, within six months of a demand raised by the competent authority, the Minister for ‘Persons with Disabilities’ will publish the name of that service as a non-conforming communication service, unless already corrected.