RGAA or EAA: what is the difference?
The RGAA is the French method for checking the accessibility of online services covered by Article 47. The EAA sets requirements for certain consumer products and services across the European Union, including e-commerce. An organisation may fall under both frameworks, so its status and the service it provides need to be assessed.
Sources: RGAA scope · Directive (EU) 2019/882
The four principles of an accessible site
The international WCAG guidelines organise accessibility around four principles. In France, the RGAA provides a detailed testing method; version 4.1.2 has 106 criteria.
Perceivable
Provide text alternatives for images, captions, readable contrast and adaptable content.
Operable
Support keyboard use, allow enough time and make navigation and focus visible.
Understandable
Use clear language, keep behaviour predictable and explain form errors.
Robust
Use structures and components compatible with browsers and assistive technologies.
Who is covered by the RGAA in France?
The RGAA (Référentiel général d’amélioration de l’accessibilité) is the testing framework associated with Article 47 of the French law of 11 February 2005. The following organisations' online public communication services are among those covered:
- public law bodies, including the State, local authorities and public establishments;
- certain private bodies providing a public service or meeting a general interest need under the conditions set by law;
- companies reaching the statutory €250 million threshold, based on average annual revenue generated in France over the previous three closed financial years.
The organisation's status and the exact scope of its service must be checked. A domain name or a site's apparent size cannot establish whether Article 47 applies.
Sources: RGAA scope
Who is covered by the European Accessibility Act?
Directive (EU) 2019/882, known as the EAA, has applied since 28 June 2025 to certain products placed on the market and certain consumer services. Web related service categories include:
- B2C e-commerce;
- consumer banking;
- e-books and dedicated software;
- electronic communications and access to audiovisual media;
- certain digital parts of passenger transport, including websites, apps and electronic tickets.
Microenterprises providing services are exempt if they employ fewer than ten people and their annual turnover or annual balance sheet total does not exceed €2 million. Other exceptions, such as a disproportionate burden, require a documented assessment. An EAA exemption does not automatically remove obligations under other laws.
The same organisation may fall under both frameworks. The RGAA and EAA do not cover precisely the same actors or obligations.
Sources: Directive (EU) 2019/882
What are the practical obligations?
Test real journeys
Check key pages and features with a keyboard and assistive technology against the applicable criteria. Automated tools find only some barriers.
Fix and maintain
Address barriers in forms, navigation, content, media and interactive components, then include accessibility checks in future changes.
Publish required information
For bodies subject to Article 47: an accessibility statement based on an assessment, a homepage notice, a multi year plan and an action plan as required.
Explain EAA service accessibility
Covered service providers must make information about the service and how it meets accessibility requirements accessible.
What are the penalties for non-compliance?
Amounts depend on the legal framework, operator, breach and procedure. A Lighthouse score or number of automated findings cannot determine a fine.
Article 47 / RGAA
After formal notice, Arcom may impose up to €50,000 for breaching the accessibility obligation on bodies covered by points 1 to 3 of Article 47. The cap is €25,000 for publication obligations under paragraphs III and IV, within the scope set by Article 47-1.
EAA / French Consumer Code
The DGCCRF can order compliance, sometimes with a daily penalty and publication. Breaches of accessibility duties under the Consumer Code can be class 5 offences; the DGCCRF cites €7,500 fines for legal entities, which may accumulate according to the offences found.
An issue found by Argos is not a legally established offence. The amounts above are ceilings, applied under the procedure specific to each framework.
Sources: Article 47-1 · DGCCRF guidance
Where should you start?
First identify the organisation, the service, its intended users and applicable legislation. Then conduct a conformance audit on a representative sample, fix blocking journeys and retest with affected users.
- Determine scope: public body, public service mission, large company or a B2C service covered by the EAA.
- Identify technical barriers and priority user journeys.
- Confirm findings through a human audit, then publish required documents where applicable.
Spot the first signals on your site
Argos scans a URL for free and reports technical accessibility, performance, SEO and security findings in a private report.
Test my site with Argos This automated diagnosis is neither a complete RGAA/WCAG audit nor a certification of compliance or legal advice.Frequently asked questions
Is every brochure website automatically covered by the EAA?
No. The EAA targets specific products and services, including consumer e-commerce. The service actually provided must be assessed. Article 47 may apply independently based on the organisation.
Does a high Lighthouse score prove RGAA compliance?
No. Lighthouse detects some issues automatically. An RGAA audit also requires manual checks, notably for keyboard use, focus, understanding and complete journeys.
Does a website built before 2025 have a general grace period until 2030?
No. The DGCCRF explains that a website or app is not a 'product' automatically eligible for the transition for certain products used to provide a service. Transitional rules depend on the specific case.
Official sources
Laws and guides consulted on 6 October 2026. Check their current version and application to your activity before making a compliance decision.