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comparison

RGAA vs EAA

RGAA (Référentiel général d'amélioration de l'accessibilité, France, 2009) and EAA (European Accessibility Act, European Union (all 27 member states), 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.

Lin Chen · IAAP CPACC · Mobile accessibility lead3 min readPublished · Updated

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 EAA?

The European Accessibility Act (Directive (EU) 2019/882) is the EU's prescriptive accessibility law that takes effect 28 June 2025, requiring covered products and services — banking, e-commerce, transport, audiovisual media, ebooks and computer hardware — to meet harmonised accessibility requirements derived from EN 301 549 and WCAG 2.1 AA.

Maintainer

European Commission

Jurisdiction and enforcement

European Union (all 27 member states). Per member state, via national transpositions.

RGAA vs EAA — the key differences

The principal difference is jurisdictional: RGAA applies in France, while EAA applies in European Union (all 27 member states). RGAA is maintained by DINUM (Direction interministérielle du numérique); EAA is maintained by European Commission. 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). EAA covers: Consumer banking services, E-commerce (B2C online sales), Air, rail, water, bus passenger transport, Audiovisual media services and devices, Electronic communications services, E-readers and ebooks, Self-service terminals (ATMs, ticket machines), Consumer computer hardware and operating systems.

Penalties

RGAA: Up to €50,000 administrative fine. EAA: Germany: up to €100,000 administrative fine + suspension of service.

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 EAA 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 EAA. For organisations selling cross-border, into the EU or US public sector, the safer default is to plan to both simultaneously.

Sources

FAQ

Frequently asked questions

Cited answers. Sourced. Updated as standards and case law change.

  • Is RGAA stricter than EAA?

    Neither standard is uniformly "stricter" — they cover different regulatory domains. RGAA is more prescriptive about public-sector websites; EAA about consumer banking services. 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 EAA?

    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 EAA?

    European Union (all 27 member states). Per member state, via national transpositions.

  • What happens if I am not compliant with RGAA?

    Up to €50,000 administrative fine

  • What happens if I am not compliant with EAA?

    Germany: up to €100,000 administrative fine + suspension of service France: up to €75,000 + daily penalty up to €3,000 Italy: up to €40,000 + product/service withdrawal Ireland: up to €60,000 / 18 months imprisonment Spain: up to €1,000,000 for repeat serious infringements

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