comparison
RGAA vs ACA
RGAA (Référentiel général d'amélioration de l'accessibilité, France, 2009) and ACA (Accessible Canada Act, Canada — federally regulated entities, 2019) are two of the most-referenced accessibility frameworks in digital compliance. This guide compares them side by side — jurisdiction, scope, conformance approach, penalties, and how a single audit can cover both simultaneously.
What is RGAA?
France's Référentiel général d'amélioration de l'accessibilité (RGAA) is the French government's national web accessibility methodology, currently at version 4.1, that operationalises EN 301 549 / WCAG 2.1 AA with 106 control tests and is mandatory for public-sector and (since the EAA transposition) large-private-sector French websites.
Maintainer
DINUM (Direction interministérielle du numérique)
Jurisdiction and enforcement
France. DINUM; ARCOM for audiovisual.
What is ACA?
The Accessible Canada Act (ACA, 2019) requires federally regulated entities — federal government, banks, telecom, broadcasting, transportation — to identify, remove and prevent accessibility barriers, with the explicit goal of "a Canada without barriers by 2040" and detailed regulations layered on top including the ICT regulations referencing EN 301 549.
Maintainer
Accessibility Standards Canada
Jurisdiction and enforcement
Canada — federally regulated entities. Accessibility Commissioner; CRTC for telecom; CTA for transportation.
RGAA vs ACA — the key differences
The principal difference is jurisdictional: RGAA applies in France, while ACA applies in Canada — federally regulated entities. RGAA is maintained by DINUM (Direction interministérielle du numérique); ACA is maintained by Accessibility Standards Canada. The standards differ on scope, conformance grading, and penalty structure — but a well-designed accessibility programme can satisfy both simultaneously by adopting the strictest applicable requirement and cross-mapping findings.
Scope
RGAA covers: Public-sector websites, Large private-sector websites (under EAA transposition). ACA covers: Federally regulated workplaces, Federal services (incl. digital), Federally regulated transportation and telecom.
Penalties
RGAA: Up to €50,000 administrative fine. ACA: Administrative monetary penalties up to C$250,000 per violation.
How to comply with both at once
Adopt the stricter applicable conformance level — typically WCAG 2.2 Level AA — as your engineering baseline. Audit against that baseline once, then cross-map findings to both RGAA and ACA specific requirements. A single Accessibility Conformance Report (ACR) using VPAT 2.5 INT can document both.
When you might need just one
If you operate exclusively in France and have no cross-border procurement exposure, you may only need RGAA. The same applies in reverse for ACA. For organisations selling cross-border, into the EU or US public sector, the safer default is to plan to both simultaneously.
Sources
- RGAA 4.1 — DINUM
- Accessible Canada Act — Government of Canada
FAQ
Frequently asked questions
Cited answers. Sourced. Updated as standards and case law change.
Is RGAA stricter than ACA?
Neither standard is uniformly "stricter" — they cover different regulatory domains. RGAA is more prescriptive about public-sector websites; ACA about federally regulated workplaces. For organisations exposed to both, a unified WCAG 2.2 AA baseline typically satisfies the technical requirements of both.
Can a single audit satisfy RGAA and ACA?
Yes. Both standards ultimately reference WCAG-aligned criteria. A combined audit with cross-mapped findings can produce documentation acceptable to both regulators.
Which jurisdictions enforce RGAA?
France. DINUM; ARCOM for audiovisual.
Which jurisdictions enforce ACA?
Canada — federally regulated entities. Accessibility Commissioner; CRTC for telecom; CTA for transportation.
What happens if I am not compliant with RGAA?
Up to €50,000 administrative fine
What happens if I am not compliant with ACA?
Administrative monetary penalties up to C$250,000 per violation
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