What is the difference between RGAA and WCAG?

WCAG (Web Content Accessibility Guidelines) is the international standard published by the W3C. The RGAA (Référentiel Général d'Amélioration de l'Accessibilité) is the French operational framework that translates WCAG 2.1 level AA into 106 testable criteria. In practice, a site that fully complies with RGAA 4.1 also meets WCAG 2.1 AA requirements.

Who is legally required to comply with RGAA in France?

Since 2005, all French public sector websites must comply. The European Accessibility Act (EAA), transposed into French law and effective June 2025, extends obligations to many private-sector companies—especially e-commerce sites, banking services, and businesses with revenue above €2 million or more than 10 employees. By 2026, enforcement and penalties will ramp up significantly.

RGAA Accessibility Audit: Complete Methodology for an Accessible Website in 2026

Why an RGAA Accessibility Audit Matters More Than Ever

Web accessibility is no longer optional. With the European Accessibility Act (EAA) taking effect in June 2025 and French enforcement tightening through 2026, thousands of organizations—public and private—must prove their websites are usable by everyone, including people with disabilities.

The RGAA 4.1 framework is France’s official benchmark. It contains 106 criteria organized into 13 themes (images, colors, forms, navigation, etc.), each directly mapped to WCAG 2.1 level AA. Non-compliance can result in fines up to €50,000 per year for public entities and serious reputational risk for private businesses.

The question isn’t whether you should audit—it’s how to do it right.

Step-by-Step RGAA Audit Methodology

Step 1: Define the Scope and Sample Pages

An RGAA audit doesn’t test every single page. Instead, you select a representative sample that covers:

The homepage
The legal notice and accessibility statement pages
The site map or main navigation page
At least one page for each distinct template (product page, blog post, contact form, checkout flow, etc.)
Pages with the highest traffic or critical user journeys

For a typical e-commerce site, this sample usually includes 15 to 25 pages. The goal is to capture every unique component and interaction pattern.

Step 2: Run Automated Scans

Automated tools like axe DevTools, WAVE, or Tanaguru can quickly flag common issues—missing alt attributes, insufficient color contrast, empty links, or broken ARIA roles.

But here’s the critical caveat: automated testing detects only 30–40% of RGAA criteria. Issues related to content relevance (e.g., is the alt text actually meaningful?), keyboard navigation logic, or screen reader announcement order require human judgment.

Automation is a starting point, never the finish line.

Step 3: Perform Manual Expert Testing

This is where the real depth of the audit happens. A trained auditor will:

Navigate every sampled page using keyboard only (Tab, Enter, Escape, arrow keys)
Test with at least one screen reader (NVDA on Firefox, VoiceOver on Safari)
Verify that every form field has a properly associated label
Check that dynamic content (modals, accordions, carousels) communicates state changes to assistive technologies
Validate that text can be resized to 200% without loss of content or functionality

At Lueur Externe, our auditors follow a criterion-by-criterion grid, documenting pass/fail status and severity for each of the 106 RGAA tests across every sampled page.

Step 4: Calculate the Compliance Score

The RGAA compliance rate is calculated as:

Compliance rate = (Conformant criteria ÷ Applicable criteria) × 100

A score of 100% means full conformity. French law requires organizations to publish this score in their accessibility statement. Most sites score between 40% and 65% on their first audit—there’s almost always significant room for improvement.

Step 5: Deliver the Remediation Roadmap

A good audit doesn’t just list problems. It prioritizes them. We typically categorize issues into three tiers:

Critical – Blocks access entirely (e.g., a checkout form unusable by keyboard)
Major – Causes significant difficulty (e.g., missing headings structure, poor contrast on key CTAs)
Minor – Causes inconvenience (e.g., decorative image with unnecessary alt text)

Each issue comes with a concrete fix recommendation, code examples, and an estimated effort level so your development team can plan sprints effectively.

Common Pitfalls to Avoid

Relying solely on overlays or widgets: Accessibility overlays do not make a site RGAA-compliant. They often introduce new bugs and give a false sense of security.
Treating accessibility as a one-time project: Content changes, new features, and CMS updates can reintroduce issues. Plan for annual re-audits at minimum.
Ignoring PDFs and media: Downloadable documents and videos must also be accessible—think tagged PDFs, captions, and audio descriptions.

Conclusion: Make 2026 the Year Your Site Becomes Truly Accessible

An RGAA accessibility audit is not just a legal checkbox. It improves user experience for everyone, boosts SEO performance (search engines reward semantic, well-structured HTML), and opens your site to the 12 million+ people living with disabilities in France.

With over 20 years of experience in web development and compliance, Lueur Externe helps businesses across France navigate the full audit-to-remediation cycle with precision. Whether you run a PrestaShop store, a WordPress site, or a custom platform, our certified team delivers actionable audits that get results.

Ready to make your website accessible and compliant before deadlines hit? Contact Lueur Externe today and let’s get started.