How to Conduct an RGAA 4 Accessibility Audit: A Practical Guide

RGAA 4 (Référentiel Général d'Amélioration de l'Accessibilité) is the French national accessibility standard maintained by DINUM (Direction interministérielle du numérique). It is the official transposition of WCAG 2.1 AA into French law, structured as a set of testable criteria organized into 13 themes.

The key difference with WCAG: RGAA provides explicit, step-by-step test methodology for each criterion — where WCAG defines the success criteria but leaves testing methods open. An RGAA audit follows a precise evaluation grid and produces a compliance rate expressed as a percentage, which is required for the official accessibility statement (déclaration d'accessibilité).

WCAG 2.1 AA has 50 success criteria. RGAA 4 maps these into 106 criteria across 13 themes (images, frames, colors, multimedia, tables, links, scripts, mandatory elements, information structure, presentation, forms, navigation, and consultation). Each criterion has one or more associated test cases.

French law (Loi n°2005-102, reinforced by Décret n°2019-768) makes RGAA audits mandatory for:

• All French public sector organizations: ministries, local authorities, public agencies, hospitals, universities • Private companies with annual revenue above €250 million — this threshold applies from 2025 under the European Accessibility Act (EAA) transposition • Any organization publishing digital services used by the general public under public service delegation

Micro-enterprises (fewer than 10 employees and revenue below €2M) are exempt from most obligations. However, demonstrating good-faith accessibility effort is increasingly expected even for non-obligated organizations, particularly those tendering for public contracts.

DINUM publishes the official RGAA audit methodology, which defines a structured process:

1. Page sample selection: The audit covers a representative sample of pages — typically 15 to 25 pages for a standard site. The sample must include the home page, contact page, login page, and pages covering all major user journeys and functional areas. A more complex site requires a larger sample.

2. Evaluation grid: Each page is evaluated against all applicable RGAA criteria using the official criteria grid (grille d'évaluation RGAA 4). For each criterion, the auditor marks: C (Conforme / Compliant), NC (Non Conforme / Non-Compliant), or NA (Non Applicable / Not Applicable).

3. Compliance rate calculation: The compliance rate = number of compliant criteria ÷ (total criteria − non-applicable criteria) × 100. This rate is what appears in the accessibility statement. Three thresholds matter: fully compliant (100%), partially compliant (≥50%), non-compliant (<50%).

4. Audit report: The auditor produces a detailed report documenting all non-conformities, their impact on users with disabilities, and remediation recommendations.

A complete RGAA audit uses five complementary testing approaches:

1. Automated testing (axe-core, Lighthouse, WAVE): Automated tools scan for detectable issues — missing alt text, form label associations, color contrast ratios, ARIA syntax errors. They catch roughly 30–40% of accessibility issues. Essential for efficiency but never sufficient alone.

2. Manual keyboard testing: The auditor navigates all interactive elements using only the keyboard (Tab, Shift+Tab, Enter, Space, arrow keys, Escape). This validates focus order, focus visibility, keyboard traps, and modal behavior — issues that automated tools cannot detect.

3. Screen reader testing (NVDA/VoiceOver): The auditor uses NVDA+Firefox on Windows and VoiceOver+Safari on macOS/iOS to verify that all content is correctly announced, that interactive elements communicate their role and state, and that dynamic content updates are properly conveyed. TalkBack on Android is used for mobile.

4. Zoom and text resize testing: Content is tested at 200% and 400% zoom to verify reflow compliance (WCAG 1.4.10) and text resize (WCAG 1.4.4). No content should be lost or require horizontal scrolling at 320px equivalent viewport.

5. Color contrast analysis: Contrast ratios are measured for all text (≥4.5:1 for normal, ≥3:1 for large text) and for UI components and focus indicators (≥3:1). Tools like the browser DevTools contrast checker or the TPGi Colour Contrast Analyser are used.

A complete RGAA audit delivers three documents:

1. Audit report: A detailed per-criterion evaluation for each page in the sample, listing all non-conformities with descriptions of the issue, affected users, and remediation recommendations.

2. Compliance rate: The calculated rate (e.g., 67% partially compliant) that must be published in the accessibility statement. Many organizations target ≥75% to demonstrate good-faith compliance.

3. Accessibility statement (déclaration d'accessibilité): The public-facing document — required by law — that declares the conformance status, lists known non-conformities, provides a contact mechanism for users to report issues, and may include a remediation roadmap. It must be published at a predictable URL (typically /accessibilite or /accessibility) and linked from the site footer.

An external RGAA audit conducted by a certified accessibility specialist typically costs between €3,000 and €15,000 depending on the scope:

• Small site (5–10 pages, no complex interactions): €3,000–€5,000 • Medium site (15–25 pages, standard functionality): €5,000–€10,000 • Large or complex application (25+ pages, rich interactions, multi-platform): €10,000–€15,000+

These figures exclude the remediation work that follows — fixing the issues identified in the audit often costs 2–5× the audit fee for teams that haven't built with accessibility in mind from the start.

The most cost-effective approach is to build audit-ready components from the beginning. When each UI component ships with documented WCAG/RGAA criterion compliance, the audit becomes a verification exercise rather than a discovery of hundreds of issues to fix. This is exactly what Konform is designed for.