On 2 March 2026, DINUM (opens in new tab) (France's interministerial digital directorate) announced that RGAA 5 will publish before the end of 2026. This is a significant update to a standard that has governed digital accessibility compliance in France for over a decade.
If your organisation sells digital products or services in France, here is what is changing and what you should do before the new version is published.
What is the RGAA?
The RGAA (Référentiel Général d'Amélioration de l'Accessibilité) (opens in new tab) is France's national digital accessibility standard. The current version, RGAA 4.1.2, is based on WCAG 2.1 and contains 106 criteria across 13 themes. It covers websites and web applications. In-scope organisations must publish an accessibility declaration, conduct regular audits, and report their conformance level publicly.
The legal framework covers public bodies, companies with annual revenue exceeding €250 million in France, and certain categories of digital service providers.
What's new: WCAG 2.2 integration
RGAA 5 will be built on WCAG 2.2, which introduces nine new success criteria at Level AA or Level A. The ones most likely to require remediation include focus visibility requirements (2.4.11, 2.4.12), drag-and-drop alternatives (2.5.7), minimum target sizes (2.5.8), consistent help placement (3.2.6), redundant entry prevention (3.3.7), and accessible authentication (3.3.8).
Organisations currently compliant with RGAA 4.1.2 should treat the gap analysis as routine maintenance rather than a wholesale restart.
What's new: explicit mobile app coverage
RGAA 4.1.2 focuses on web content. RGAA 5 will include explicit coverage of native mobile applications, aligned with EN 301 549 v3.2.1. For organisations with iOS and Android applications in the French market, mobile accessibility will be a direct requirement.
What's new: document coverage
RGAA 5 will include explicit coverage of office documents: PDFs, Word files, LibreOffice documents, and similar downloadable content. For organisations that distribute PDFs like annual reports, application forms, product documentation will need to meet formal accessibility standards and be included in the scope of accessibility audits.
A properly accessible PDF includes a logical reading order, descriptive alt text for images, accessible form fields, correct heading structure, and a document language declaration. Organisations with large document inventories should begin a review of their key documents before RGAA 5 publishes.
What's new: enforcement authority and centralised declarations
RGAA 5 introduces a clearer enforcement structure, with ARCOM (Autorité de Régulation de la Communication Audiovisuelle et Numérique) (opens in new tab) taking on an expanded role as the supervisory authority for EAA enforcement in France. A centralised declaration registry will also be introduced, moving away from each organisation maintaining its own declaration independently.
Does existing RGAA 4.1.2 work remain valid?
Yes. DINUM has confirmed that existing accessibility declarations will remain valid for 18 months after RGAA 5 publishes, with a maximum duration of three years. The gap between the two versions, primarily the new WCAG 2.2 criteria, formalised mobile requirements, and document scope is manageable for organisations that have already built a solid accessibility programme.
The RGAA is also the French implementation vehicle for the EAA. Any business selling digital products or services to consumers in France regardless of where it is incorporated is subject to French enforcement of EAA requirements and therefore to RGAA 5 once it publishes.
What organizations should do before RGAA 5 publishes?
- Complete an RGAA 4.1.2 audit if you haven't done one recently. It gives you a baseline, satisfies the current declaration requirement, and remains valid for 18 months after RGAA 5 publishes.
- Review your mobile applications against EN 301 549 mobile criteria. This is where the largest gaps are likely to appear.
- Conduct a document accessibility review for your most-distributed PDFs, starting with documents users rely on for access to services.
We know that accessibility is a new focus area for technical teams, especially with these upcoming European regulations. That’s why everyday at Binclusive, we use the power of AI and our expertise to make the compliance process easier for organisations, allowing them to focus on being accessible. We provide structured solutions across web (opens in new tab) & mobile accessibility (opens in new tab), video accessibility, and PDF accessibility (opens in new tab). So, if you are ready to make your digital presence accessible, we are here to help you.