comparison
RGAA vs Unruh Act
RGAA (Référentiel général d'amélioration de l'accessibilité, France, 2009) and Unruh Act (Unruh Civil Rights Act, California, United States, 1959) 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 Unruh Act?
California's Unruh Civil Rights Act incorporates the federal ADA and adds statutory damages of $4,000 per violation, making California the highest-litigation US state for web accessibility — accounting for the largest share of demand letters and class actions filed each year.
Maintainer
State of California
Jurisdiction and enforcement
California, United States. California courts; private right of action.
RGAA vs Unruh Act — the key differences
The principal difference is jurisdictional: RGAA applies in France, while Unruh Act applies in California, United States. RGAA is maintained by DINUM (Direction interministérielle du numérique); Unruh Act is maintained by State of California. 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). Unruh Act covers: Any business establishment in California or serving California consumers.
Penalties
RGAA: Up to €50,000 administrative fine. Unruh Act: $4,000 minimum statutory damages 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 Unruh Act 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 Unruh Act. 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
- California Civil Code § 51 — California Legislative Information
FAQ
Frequently asked questions
Cited answers. Sourced. Updated as standards and case law change.
Is RGAA stricter than Unruh Act?
Neither standard is uniformly "stricter" — they cover different regulatory domains. RGAA is more prescriptive about public-sector websites; Unruh Act about any business establishment in california or serving california consumers. 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 Unruh Act?
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 Unruh Act?
California, United States. California courts; private right of action.
What happens if I am not compliant with RGAA?
Up to €50,000 administrative fine
What happens if I am not compliant with Unruh Act?
$4,000 minimum statutory damages per violation Attorney fees Injunctive relief
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