RGAA Digital Accessibility: The 2026 Guide to Website Compliance

Since June 28, 2025, the European Accessibility Act (EAA) has changed the game: digital accessibility is no longer just a public-sector matter. Six months after it came into force, 94% of European websites still failed to meet the directive's requirements, according to data compiled by Urbilog. For a French small or medium business, understanding what has changed, who is affected, and how to act is no longer optional: it is a legal obligation backed by very real penalties. Here is the complete method for bringing your website into compliance in 2026.

What changes in 2026: digital accessibility moves beyond the public sector

Until recently, the French General Reference Framework for Accessibility Improvement (RGAA) mainly applied to government bodies, local authorities and public organizations. The EAA has widened the scope of the rules: many private companies must now comply, under an updated technical framework. The version officially in force is RGAA 4.1.2, aligned with the European standard EN 301 549 and with the WCAG 2.1 success criteria, with a clear trend toward WCAG 2.2 (source: Pandiweb).

Another strong signal: the first inspections by the DGCCRF (the French consumer protection authority) began in January 2026, with Arcom supporting enforcement for audiovisual and online communication services. In just a few months, the topic has shifted from a best practice to a compliance risk to be managed on the same footing as GDPR or e-invoicing.

Who is affected by the RGAA in 2026?

The scope is broader than most small and medium businesses tend to assume:

• The entire public sector: government agencies, local authorities and public bodies, regardless of size.
• Private companies with more than 10 employees or over €2 million in annual revenue, as soon as they offer certain digital services (source: Pandiweb).
• E-commerce websites, regardless of industry.
• Online banking and financial services.
• Booking platforms (transport, accommodation, ticketing).
• Public communication and audiovisual services, under Arcom's oversight.

Many small business owners wrongly assume that their company's size automatically puts them outside the scope of the law. If your site sells online or allows bookings, it is worth checking your situation before an inspection happens, not after.

Penalties: what a non-compliant business risks

The figures reported in 2026 are enough to get any business owner's attention:

• Up to €50,000 per non-compliant service, a fine that can be renewed, generally after a six-month period, if the failures persist (source: Pandiweb). This recurrence opens the door to near-annual penalties in cases of prolonged inaction.
• €25,000 can be added for failing to meet disclosure obligations: no accessibility statement, no compliance notice on the homepage, or no published multi-year action plan.
• For the private sector, the amounts most commonly observed range between €7,500 and €15,000 per violation, with regulatory ceilings that can reach €300,000 in the most serious cases (source: RGAA Consulting).

On top of that comes a harder-to-measure but equally real risk: brand image. An inaccessible website shuts the door on part of your customer base, while businesses with a consistent visual identity and experience capture more trust and revenue, as shown by the studies cited in our article on logo redesign and visual identity.

RGAA in practice: the 13 themes to know

The RGAA framework organizes its criteria around 13 broad technical themes. Knowing them helps prioritize an audit without getting lost in its 106 detailed test criteria:

1. Images (alternative text)
2. Frames (iframes)
3. Colors and contrast
4. Multimedia (videos, audio, captions)
5. Data tables
6. Links (explicit labels)
7. Scripts (compatibility with assistive technologies)
8. Mandatory elements (page language, page title)
9. Information structure (headings, hierarchy)
10. Information presentation (formatting, zoom)
11. Forms (labels, error messages)
12. Navigation (menus, sitemap, keyboard access)
13. Consultation (browser and screen reader compatibility)

In practice, most of the most frequent non-conformities cluster around three themes: color contrast, image alternative text, and keyboard navigation.

The 5-step method for bringing your website into compliance

1. Audit what already exists. Start with an automated audit using tools like WAVE, the axe DevTools extension, or Lighthouse (built into Chrome), which catch a good share of technical errors: insufficient contrast, images without alt text, inconsistent heading structure. These tools only cover part of the RGAA criteria, though: a manual audit, including keyboard-only navigation and screen reader testing, remains necessary for a complete diagnosis.
2. Prioritize fixes. Rank the detected issues by real impact on users and effort required to fix. Color contrast and missing alt text usually offer the best impact-to-effort ratio, and they are also the areas where solid work on brand color choices makes a real difference.
3. Fix the technical fundamentals. Semantic HTML structure, heading hierarchy, form labels, fully keyboard-usable navigation, video captions: these fixes demand the most technical rigor, and done well, they also improve overall readability, including on mobile (see our guide on mobile-first design).
4. Publish the accessibility statement and multi-year action plan. These two mandatory documents must be accessible from the homepage. The statement specifies the compliance level (full, partial or non-compliant), the inaccessible content, and how to report an issue. The multi-year action plan sets out an improvement path over several years.
5. Maintain compliance over time. Accessibility is not a one-off project: every content update, new page, or partial redesign can reintroduce errors. Periodic checks, an accessible content style guide for your teams, and vigilance during every site change are essential. This is a topic to address from the design stage, especially during a website redesign.

How much does RGAA compliance cost?

Budgets vary widely depending on the size and complexity of the site. For a standard showcase website, several specialized providers cite a range of €5,000 to €10,000 for a full audit followed by priority fixes (source: Pandiweb). An e-commerce site or a platform with transactional features (payment, booking, customer accounts) generally requires a larger budget, given the volume of user journeys to test. On top of this initial cost comes an ongoing maintenance budget: regular follow-up audits, staff training in accessible content writing, and checks each time new content goes live.

In every case, building accessibility in from the start of a new website costs significantly less than fixing an existing site afterward: a strong argument to raise before any website creation project.

The most common mistakes among small and medium businesses

• Confusing accessibility with responsive design. A mobile-friendly site is not automatically accessible to people with disabilities.
• Relying only on an automated audit. Tools like Lighthouse only catch a fraction of RGAA criteria; human testing remains essential.
• Forgetting the accessibility statement. Even a partially compliant site must publish this statement; its absence alone is grounds for a penalty.
• Treating it as a one-time project. A redesign, a new module, or even a simple content update can push a site back out of compliance.
• Overlooking forms and keyboard navigation, two points that are often invisible to the eye but block assistive technologies entirely.

Accessibility and SEO: a winning combination

Good news for business owners still hesitating to invest: much of the accessibility fix list overlaps with technical SEO best practices. A consistent heading structure, relevant alt text, and well-controlled load times benefit both users of assistive technology and search engine rankings, as detailed in our article on technical SEO and Core Web Vitals. A more accessible website is, ultimately, a more robust one, including for international markets, where accessibility standards are often even stricter than in France (see our guide on multilingual websites).

Frequently asked questions

What is the RGAA?

The RGAA (General Reference Framework for Accessibility Improvement) is the French framework that defines the technical criteria a website, application, or digital document must meet to be usable by people with disabilities. It is based on the international WCAG standards and includes 106 test criteria organized into 13 themes.

Is my business affected if I have fewer than 10 employees?

The threshold most often cited for the private sector is 10 employees or €2 million in annual revenue. Below these thresholds, the direct legal obligation may not apply, but certain activities (e-commerce, financial services, bookings) remain in scope regardless of company size. When in doubt, a quick initial audit clarifies your situation and prepares you for regulatory scope that keeps expanding.

How do you write an accessibility statement?

An accessibility statement must state the level of RGAA compliance (full, partial, or non-compliant), list the inaccessible content with an alternative where possible, and provide a way to report an accessibility issue and exercise one's rights. It must be accessible from the site's homepage, typically via the footer.

What tools can I use to audit my site myself?

Free tools such as WAVE, the axe DevTools extension, or the audit built into Google Lighthouse allow for a first technical diagnosis within minutes: detecting insufficient contrast, images without alt text, or HTML structure errors. They should still be complemented by manual keyboard navigation testing and, ideally, screen reader testing, to cover the full range of RGAA criteria.

What should I do if my site is not yet compliant?

Start with an audit to precisely measure the gap against RGAA criteria, then publish an accessibility statement that honestly states the current compliance level along with an upgrade timeline through the multi-year action plan. This proactive approach, even if it takes time, significantly reduces the risk of penalties compared with taking no action at all. For any question about bringing your website into compliance, our team is available through the contact page.