Digital accessibility is becoming a critical requirement for organizations serving users in France. With RGAA 5 expected by the end of 2026, website owners, developers, and compliance teams should prepare for the upcoming revision without delaying their existing accessibility work. France’s Interministerial Directorate for Digital Affairs (DINUM) is currently developing the new version. The current reference framework remains RGAA 4.1.2.
For organizations, the priority is clear: identify existing accessibility gaps, strengthen testing and remediation processes, and establish a sustainable approach to compliance. Preparing now can reduce future rework while making digital services more usable for people with disabilities.
What is Confirmed About RGAA 5?
RGAA 5 is currently being developed with input from public-sector organizations and various accessibility association. DINUM has clarified that existing accessibility work must not be postponed while waiting for the new version. (Official announcement)
Key development expected:
- Integration of WCAG 2.2: The updated framework is expected to incorporate the newer international accessibility guidelines, expanding on the WCAG 2.1 requirements used by RGAA 4.1.2.
- Broader technical coverage: New criteria and tests are planned for native mobile applications and documents.
- Clearer assessment criteria: Existing criteria are expected to be reformulated and simplified to make accessibility assessment easier to interpret.
- Regulatory oversight: ARCOM (the French Audiovisual and Digital Communication Regulatory Authority) is expected to serve as the designated oversight authority.
- Digital declaration service: A dedicated online service is planned for submitting and publishing accessibility statements.
Please note: RGAA 4.1.2 is France’s current technical accessibility framework, while WCAG 2.1 is the international standard on which its technical assessment methodology is based. Specifically, RGAA 4.1.2 uses 50 WCAG 2.1 Level A and AA success criteria selected through the relevant European accessibility standard to establish the applicable technical requirements. It translates these requirements into 106 RGAA control criteria, supported by detailed tests and implementation guidance. Therefore, WCAG 2.1 provides the underlying accessibility requirements, while RGAA 4.1.2 offers a France-specific method for evaluating compliance.
Who should prepare for RGAA 5?
Under Article 47 of France’s Law of February 11, 2005, accessibility obligations cover public-sector legal entities and certain private organizations performing public-service functions or meeting other specified public-interest criteria. Applicability depends on the organization’s legal status, activities, and applicable provisions.
Entities within scope should review their accessibility readiness across:
- Public-facing websites: Corporate information, public-service portals, and online information resources.
- Digital services and transactions: Registration, account management, application forms, payments, and other essential user journeys.
- Dynamic interfaces: Menus, modal dialogs, interactive components, and JavaScript-driven functionality.
- Digital content: Images, videos, downloadable documents, tables, and forms published through covered services.
- Third-party integrations: Embedded tools, payment interfaces, booking systems, and externally supplied components that affect accessibility.
Even organizations with different legal obligations can benefit from adopting the same accessibility-first practices. Doing so helps reduce usability barriers and supports more inclusive digital experiences.
Organizations should also distinguish between RGAA obligations and the European Accessibility Act, which has a different legal scope and applies to specified products and services.
A Practical Roadmap for Preparing for RGAA 5
Organizations should follow a roadmap that provides a structured approach to identify risks, address barriers, and prepare for the updated framework.
1. Audit the website against RGAA 4.1.2
Start with a baseline accessibility audit using the currently applicable RGAA methodology. An audit helps establish the website’s existing accessibility status and identifies issues that need remediation.
Review a representative sample of pages, including high-traffic pages, key conversion journeys, forms, search results, and interactive features. Include different page templates and states rather than testing only the homepage.
Assess common accessibility barriers such as:
- Missing or inappropriate text for informative images.
- Insufficient color contrast between text and backgrounds.
- Incorrect heading structures and page landmarks.
- Keyboard navigation failures and inaccessible interactive controls.
- Form fields without appropriate labels or useful error messages.
- Missing captions or alternatives for relevant multimedia content.
- Inaccessible tables, links, and downloadable documents.
2. Track RGAA 5 developments without speculating
The final RGAA 5 criteria should guide future adjustments once the official version is published. Until then, teams should monitor updates from DINUM and the official RGAA website.
Assign an accessibility lead or compliance owner to review official announcements, assess changes against the existing audit, and coordinate the response across relevant teams.
Maintain an accessibility requirements register that records:
- Current applicable requirements and the website’s compliance status.
- Identified accessibility barriers and remediation progress.
- Official RGAA 5 updates requiring further assessment.
- Owners, target dates, and verification evidence for corrective actions.
3. Prioritize remediation by user impact
Not every accessibility issue carries the same practical consequences. Prioritize barriers that prevent users from accessing essential information or completing important tasks.
A practical prioritization model should consider:
Severity: Does the issue completely block a task or make it significantly harder?
Reach: How many pages, templates, or user journeys are affected?
Frequency: How often are users likely to encounter the issue?
Dependencies: Does the problem originate in a shared component or third-party service?
Effort: What resources are needed to implement and verify the correction?
4. Integrate accessibility into design and development
Accessibility should be built into the development lifecycle instead of treated as a final compliance check.
Designers should consider contrast, text resizing, visible focus indicators, understandable labels, and consistent interaction patterns from the beginning. Developers should use semantic HTML, accessible names, appropriate ARIA attributes where necessary, and predictable keyboard behavior.
Content teams also have an important role. They should write descriptive link text, provide meaningful image alternatives, structure headings logically, and ensure that published documents and multimedia are accessible.
5. Expand testing beyond automated scans
Automated accessibility scanners are useful for detecting recurring technical problems, but passing an automated scan does not establish full RGAA conformance.
A robust testing process should combine automated checks with manual inspection and assistive technology testing.
Manual testing should be integrated into development and release workflows to verify real-world accessibility. Key activities cover testing keyboard-only operation, checking focus order and management in interactive components, reviewing screen reader output, verifying usability at increased zoom levels, and testing form validation, including accessible error identification and announcements.
Retest corrected issues and run regression tests before releasing updates. This helps verify that remediation works as intended without introducing new accessibility barriers.
6. Strengthen accessibility governance and documentation
Technical remediation is only one part of accessibility readiness. Organizations also need clear accountability and transparent documentation.
The current French framework requires covered organizations to publish an accessibility statement and provide information about their multi-year accessibility plan and annual action plan. The required homepage compliance status must also reflect the applicable assessment rules.
As part of their preparation, organizations should:
- Maintain a multi-year accessibility strategy and an annual action plan.
- Document audit results, known barriers, corrective actions, and retesting outcomes.
- Review the accessibility statement when assessment results change.
- Train teams to recognize and prevent recurring accessibility issues.
- Monitor official RGAA 5 announcements and reassess the roadmap after publication.
Documentation should reflect actual audit evidence and remediation progress. A published statement or accessibility widget alone does not demonstrate that a website meets all applicable requirements.
Common mistakes to avoid when preparing for RGAA 5
Organizations can undermine their preparation by focusing on isolated fixes instead of addressing the accessibility of the complete user experience.
Avoid these common mistakes:
- Treating an accessibility overlay as a complete solution: Widgets may provide useful supplementary features, but they do not replace accessible code, content remediation, and conformance testing.
- Ignoring content and third-party components: PDFs, embedded services, and interactive tools can introduce significant barriers.
- Failing to retest fixes: An issue should not be considered resolved until the correction has been verified.
- Treating compliance as a one-time project: Website updates can reintroduce previously resolved accessibility defects.
Avoiding these mistakes helps organizations build a sustainable process that can adapt to the updated framework.
How Skynet Technologies Supports Accessibility Readiness?
Preparing for RGAA 5 requires more than identifying accessibility issues. Organizations need a practical remediation strategy, technical expertise, and ongoing verification to maintain accessible digital services.
Our accessibility audit tool helps teams identify potential issues and prioritize corrective action. By combining automated detection with expert evaluation and verified remediation, organizations can establish a stronger accessibility foundation before RGAA 5 is finalized. The result is a more maintainable approach to accessibility that supports compliance efforts while improving the digital experience for users with disabilities.
Next Steps for RGAA 5 Readiness!
RGAA 5 is expected by the end of 2026. Its preparation should be a measurable process, not a last-minute compliance exercise. Organizations that address existing accessibility barriers, establish clear ownership, and validate fixes through continuous testing will be better positioned to respond to the revised framework. The priority is to turn accessibility findings into verified improvements that make digital services more reliable, inclusive, and ready for evolving requirements.
Start with a comprehensive accessibility audit, remediate the highest-impact barriers, and establish a continuous testing process. Reach out us to assess your French website’s accessibility gaps and develop a remediation roadmap aligned with current requirements and future RGAA developments. Request a free quote!
