comparison
Unruh Act vs RGAA
Unruh Act (Unruh Civil Rights Act, California, United States, 1959) and RGAA (Référentiel général d'amélioration de l'accessibilité, France, 2009) 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 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.
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.
Unruh Act vs RGAA — the key differences
The principal difference is jurisdictional: Unruh Act applies in California, United States, while RGAA applies in France. Unruh Act is maintained by State of California; RGAA is maintained by DINUM (Direction interministérielle du numérique). 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
Unruh Act covers: Any business establishment in California or serving California consumers. RGAA covers: Public-sector websites, Large private-sector websites (under EAA transposition).
Penalties
Unruh Act: $4,000 minimum statutory damages per violation. RGAA: Up to €50,000 administrative fine.
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 Unruh Act and RGAA 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 California, United States and have no cross-border procurement exposure, you may only need Unruh Act. The same applies in reverse for RGAA. For organisations selling cross-border, into the EU or US public sector, the safer default is to plan to both simultaneously.
Sources
- California Civil Code § 51 — California Legislative Information
- RGAA 4.1 — DINUM
FAQ
Frequently asked questions
Cited answers. Sourced. Updated as standards and case law change.
Is Unruh Act stricter than RGAA?
Neither standard is uniformly "stricter" — they cover different regulatory domains. Unruh Act is more prescriptive about any business establishment in california or serving california consumers; RGAA about public-sector websites. For organisations exposed to both, a unified WCAG 2.2 AA baseline typically satisfies the technical requirements of both.
Can a single audit satisfy Unruh Act and RGAA?
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 Unruh Act?
California, United States. California courts; private right of action.
Which jurisdictions enforce RGAA?
France. DINUM; ARCOM for audiovisual.
What happens if I am not compliant with Unruh Act?
$4,000 minimum statutory damages per violation Attorney fees Injunctive relief
What happens if I am not compliant with RGAA?
Up to €50,000 administrative fine
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