RGAA Accessibility Statement: What It Is, Who Needs One, and How to Write It

The RGAA accessibility statement is not optional for covered organizations. It is required by French law and increasingly by European regulation:

• Loi n°2005-102 du 11 février 2005 (for equality of rights and opportunities for disabled persons) — the foundational French accessibility law • Décret n°2019-768 du 24 juillet 2019 — the implementing decree that made the RGAA accessibility statement formally mandatory and defined its required content • European Accessibility Act (EAA) — Directive 2019/882, transposed into French law in 2023, extends obligations to large private companies

The accessibility statement must be published on the website and updated after each significant change or accessibility audit. Failure to publish it exposes public sector organizations to administrative sanctions and user complaints with the Défenseur des droits.

The following organizations are legally required to publish an RGAA accessibility statement:

• All French public sector bodies: central government, local authorities, public agencies, hospitals, universities, public broadcasters • Private organizations under public service delegation • Large private companies with annual revenue exceeding €250 million — this threshold applies from 2025 under the EAA transposition

Exemptions: micro-enterprises (fewer than 10 employees and revenue below €2M) are exempt from the statement obligation. However, voluntarily publishing a statement is good practice and increasingly expected by procurement teams and B2B clients in the public sector supply chain.

For organizations subject to the EAA, the statement requirements align with EN 301 549, which references WCAG 2.1 AA for web content. The French RGAA 4 is the national standard that satisfies this requirement.

The DINUM template for accessibility statements defines the required sections:

1. Conformance status — one of three levels: • Fully compliant (totalement conforme): 100% of applicable RGAA criteria are met • Partially compliant (partiellement conforme): 50% or more of applicable criteria are met • Non-compliant (non conforme): fewer than 50% of criteria are met, or no audit has been conducted

2. Non-conformities — a list of identified accessibility barriers, each with: • A description of the non-conformity • The impact on users with disabilities (e.g., blind users, keyboard users) • The affected pages or sections

3. Derogations (dérogations) — justified exceptions, allowed in limited cases: • Disproportionate burden (charge disproportionnée): when the cost of remediation is disproportionate to the benefit, with documented justification • Third-party content not under your control (e.g., embedded social media widgets) • Archived content that predates the legal obligation and is not actively used

4. Contact mechanism — a way for users to report accessibility barriers and request accessible alternatives. This is mandatory and must include at minimum an email address or contact form.

5. Remediation roadmap (plan d'amélioration) — a timeline for addressing known non-conformities. Not required by law but strongly recommended and increasingly expected.

The RGAA explicitly permits self-audit — organizations can conduct their own accessibility evaluation without hiring an external specialist. The DINUM methodology is publicly available and all tools needed for testing (axe-core, NVDA, VoiceOver, browser DevTools) are free.

A self-audit is sufficient for publishing a valid accessibility statement, provided: • The evaluation follows the official RGAA criteria grid • The evaluator documents their methodology and findings • The compliance rate is calculated correctly • Non-conformities are honestly reported

An external audit by a certified accessibility specialist is recommended (and sometimes required by clients or procurement rules) because it provides independent verification, higher credibility, and expert identification of issues that internal teams may miss — particularly in screen reader behavior and complex interaction patterns.

Regardless of who conducts the audit, the statement must reflect an actual evaluation — not a declaration of intent. Publishing a statement claiming full or partial compliance without performing an evaluation is a legal risk.

Here is a minimal, legally compliant template based on the DINUM model. Replace the placeholder text with your actual audit results.

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Accessibility statement

This website [ORGANIZATION NAME] is committed to making its digital services accessible in accordance with article 47 of Loi n°2005-102 du 11 février 2005.

Conformance status [ORGANIZATION NAME] is [fully compliant / partially compliant / non-compliant] with RGAA 4.1. [If partially compliant: The non-conformities are listed below.]

Non-conformities [List each non-conformity, e.g.:] • Images without text alternatives (RGAA criterion 1.1) — affects users of screen readers • Form fields without associated labels (criterion 11.1) — affects users of assistive technology • Insufficient color contrast on secondary buttons (criterion 3.2) — affects users with low vision

Derogations [If applicable: List any derogations with justification, e.g.:] • Embedded third-party social media widgets: not under our control

Contact and feedback If you encounter an accessibility barrier or cannot access content, contact us: • Email: accessibilite@[ORGANISATION].fr • Response time: we commit to responding within 2 business days

If you do not receive a satisfactory response, you may refer the matter to the Défenseur des droits: defenseurdesdroits.fr

Audit date: [DATE] Next planned audit: [DATE]

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The accessibility statement must be easy to find. Best practices:

• Publish at a predictable URL: /accessibilite (for French-language sites) or /accessibility • Link from the footer on every page — this is required by the DINUM guidelines and expected by users with disabilities who look for it there • Link from the site's legal notices page (mentions légales) • Optionally include a brief accessibility notice in the footer with a link to the full statement

The statement page itself must be accessible — it would be ironic and legally problematic for the accessibility statement page to have accessibility issues.