Guides Public Sector

Digital Accessibility in the Public Sector: RGAA Requirements and Best Practices

2026-02-25 — 12 min

Let's Be Honest: Where Does the French Public Sector Stand on Accessibility?

Here's the thing — Article 47 of the French law of February 11, 2005 has been around for over two decades. It requires all online public services to be accessible to people with disabilities. The RGAA (General Accessibility Improvement Framework), currently at version 4.1, is the framework the French government put in place to make that happen.

Now, 2026 brings a real game-changer: the European Accessibility Act (EAA) kicks in and pushes requirements way beyond the public sector. But let me be blunt — for public administrations, none of this is new. The rules have been there. What's new is that someone's actually checking. And fining.

Who's Actually Affected?

The list is longer than most people realize:

  • The State: ministries, decentralized services, state operators
  • Local authorities: regions, departments, municipalities (yes, even tiny ones)
  • Public institutions: public hospitals, universities
  • Organizations with delegated public service missions
  • Private companies with more than 10 employees or €2 million turnover (only micro-enterprises are exempt since the EAA of June 2025)

This covers websites, mobile apps, intranets and extranets published after September 2019, and even digital urban furniture. Those interactive kiosks in town halls? Yep, those too.

DINUM: The Orchestra Conductor

If you work in French public administration, you've likely come across the Interministerial Digital Directorate (DINUM). They're the ones steering digital accessibility policy for the government. In practice, they publish and update the RGAA, support administrations through compliance (and I've seen that support improving year after year), verify public site compliance, and maintain the DSFR (French State Design System) with natively accessible components.

The DSFR deserves a special mention. Every component is accessible by default. If your administration uses it, you're starting with a massive head start on RGAA compliance. In my experience, it's one of the most underused advantages out there.

What's Actually Required

1. Accessibility Statement

Every public site must display an accessibility statement. Fully compliant, partially compliant, or non-compliant — it doesn't matter which, you have to say it. That statement needs to include:

  • The audit date and RGAA version used
  • The compliance rate
  • A list of non-accessible content with actual reasons
  • A way for users to report issues
  • A link to the Défenseur des droits if there's no response

2. Multi-year Accessibility Plan

You also need a 3-year accessibility plan. The point is to show you have a strategy, not that you're winging it. This must come with an annual action plan. From what I've seen, this is usually the first document that's missing.

3. Homepage Compliance Badge

Simple but frequently forgotten: the compliance level must be visible on the homepage. "Accessibility: fully compliant," "partially compliant," or "not compliant." Not buried three clicks deep.

Authorities That Are Getting It Right

City of Paris

The paris.fr website exceeds 75% RGAA compliance. Their secret? A dedicated accessibility team and regular staff training. No magic — just method and consistency.

Île-de-France Region

Their regional portal runs on DSFR. The result: full keyboard navigation, screen reader compatibility, AA-compliant contrast ratios. They also have a dedicated accessibility coordinator. That single role makes a huge difference, honestly.

Small Municipalities

Good news: you don't need to be a major city. I've seen municipalities with just a few thousand residents reach 50-75% compliance using WordPress with an accessible theme and some contributor training. Reasonable budget, real results.

Penalties: This Is Getting Real

Decree No. 2019-768 means business:

  • €20,000 per year per site for missing accessibility statements
  • €20,000 per year per application for missing multi-year plans
  • Arcom (formerly CSA) can issue formal notices to public bodies

In 2025-2026, inspections are ramping up and fines are actually landing. This isn't theoretical anymore. If you're in the public sector and haven't started, the time to act was yesterday.

Where to Start: A Practical Approach

  1. Run an initial diagnostic: use RGAA Test at rgaa-test.fr for an automated first look, then follow up with a manual audit
  2. Write your multi-year plan: set realistic 3-year priorities
  3. Train your teams: content editors, developers, designers — everyone needs to be in the loop
  4. Publish your accessibility statement: even if the score isn't great, transparency is required (and it's a first step)
  5. Fix by priority: tackle Level A criteria first, then AA
  6. Test with every release: make accessibility testing part of your routine, not just a yearly thing
Accessibility isn't a project you launch and forget. It's a habit you build. Every new piece of content needs to meet RGAA criteria — otherwise, you're going backwards.

Tools That'll Actually Help

  • RGAA Test (rgaa-test.fr): automated RGAA criteria testing — the perfect starting point
  • DSFR: the French State Design System with ready-to-use accessible components
  • DINUM Guide: the official documentation, well-maintained and regularly updated
  • Pidila: a practical accessibility audit toolkit
  • NVDA / VoiceOver: free screen readers for hands-on testing (I really recommend trying them at least once)
Pretty much everyone in the public sector: websites, mobile apps, and intranets of state administrations, local authorities, public institutions, and organizations with delegated public service missions. And here's what catches people off guard — since the EAA of June 2025, all private companies with more than 10 employees or €2 million turnover are also on the hook — only micro-enterprises are exempt.
Here's the uncomfortable truth: there is no deadline left. The obligation has been in effect since 2012 for the State and 2019 for local authorities. Technically, you should already be compliant. The multi-year plan lets you spread corrections over 3 years, but you need to have at least started.
The fastest way? Run an automated audit with RGAA Test to spot the recurring issues — missing alt text, poor contrast, unlabeled forms. Tackle Level A criteria first — they make up 50% of the framework and that's where you'll see the quickest wins. And if you can use the DSFR, absolutely do it — its components are accessible out of the box.
The bottom line? A €20,000 fine per year per site or app if you're missing your accessibility statement or multi-year plan. Arcom can also issue formal notices. But beyond the financial hit, there's the reputational damage — and fundamentally, it's a failure to uphold equal access to public services. That's becoming increasingly hard to justify.

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