RGAA 5: what’s changing in France’s accessibility standard

Key points

• RGAA 4.1.2 remains the reference until RGAA 5 is published, with its 106 criteria based on WCAG 2.1 AA.
• RGAA 5 builds on version 4.1.2 without contradicting it: what you fix today stays fixed.
• Existing accessibility statements remain valid for 18 months after its publication.

The six new WCAG 2.2 criteria

RGAA is aligning with version 2.2 of the international WCAG guidelines, published by the W3C in October 2023. It adds six success criteria at levels A and AA, the two levels required in France.

2.4.11 Focus Not Obscured (Minimum)

The element that receives keyboard focus must not disappear behind a fixed header, a cookie banner or a sticky navigation bar.

2.5.7 Dragging Movements

Anything done by dragging, like a slider or drag-and-drop sorting, must also be possible with a single click or tap.

2.5.8 Target Size (Minimum)

Clickable areas must be at least 24 × 24 pixels, or spaced far enough apart not to be hit by mistake.

3.2.6 Consistent Help

When help is offered on several pages, whether contact details, a chat or an FAQ, it must be in the same place.

3.3.7 Redundant Entry

Information already entered in a process must not be requested again, unless there’s a valid exception: it is pre-filled or available to select.

3.3.8 Accessible Authentication (Minimum)

Logging in must not require a cognitive test, like remembering or retyping a code, without an alternative: allowing copy and paste, a password manager or a login link.

A testing method for mobile apps

Until now, RGAA was designed for the web. RGAA 5 brings a testing method dedicated to iOS and Android apps. Testing an app means checking how it works with the phone’s screen readers, VoiceOver and TalkBack, with gestures, in both orientations and with the system text sizes. App publishers will finally have a French standard to measure and declare their compliance.

Criteria for documents

Published documents, whether PDF, Word, Excel or PowerPoint, will have their own criteria. Annual reports, downloadable forms, terms and conditions: any document put online will have to be structured, tagged and readable by assistive technologies, or offered in an accessible version.

Stronger oversight and rewritten criteria

• Arcom, France’s digital and media regulator, is designated as the supervisory authority for the standard. It can already issue formal notices and impose penalties: its first public formal notice, targeting impots.gouv.fr, the French tax administration’s website, was published in France’s official journal (Journal officiel) in June 2026.
• An online service will let organizations file and publish their accessibility statements on a single platform.
• Rewritten criteria, with simpler wording that is less open to interpretation.

What you can do now

1. Measure against RGAA 4.1.2

   An audit carried out today remains valid: RGAA 5 doesn’t call the existing criteria into question, and your statement remains valid for 18 months after its publication.

2. Get ahead on the six WCAG 2.2 criteria

   Target size, focus visible under banners, alternatives to drag-and-drop: these issues can often be fixed once and for all in the design system.

3. Take stock of your documents and apps

   These are the two new areas covered by the standard. Identify your most-viewed documents and the key journeys in your mobile apps.