French accessibility standard — Preview
RGAA 5 (Preview)
The upcoming version of France's Référentiel Général d'Amélioration de l'Accessibilité, announced by DINUM for late 2026. RGAA 5 will integrate WCAG 2.2 criteria, extend scope to mobile applications and office documents, and maintain Arcom as the accessibility enforcement authority.
What is RGAA 5 (Preview)?
RGAA 5 is the next major version of France's accessibility standard, announced by DINUM in early 2026 for release in late 2026. It builds on RGAA 4.1.2 (106 criteria, 13 themes) and incorporates three major changes: (1) integration of the 6 new WCAG 2.2 Level AA criteria (2.4.11, 2.5.7, 2.5.8, 3.2.6, 3.3.7, 3.3.8); (2) extension of scope beyond websites to mobile applications and office documents (Word, PDF); and (3) clarification of the role of Arcom (Autorité de régulation de la communication audiovisuelle et numérique) as the enforcement authority with stronger audit powers. The expected total criterion count is approximately 110–120 criteria.
RGAA 5 will apply to the same organizations as RGAA 4.1.2 (all French public sector bodies and private companies with annual French revenue above €250 million), plus new scope additions: mobile application developers must address Chapter 11 requirements aligned with EN 301 549 software criteria, and organizations producing office documents (PDFs, Word files distributed publicly) must audit those documents against RGAA 5 document criteria. Existing accessibility statements based on RGAA 4.1.2 remain valid for 18 months after RGAA 5 is officially published.
RGAA 5's legal basis derives from the 2023 ordinance transposing the EU Web Accessibility Directive and the EAA. DINUM has confirmed that RGAA 5 will be the reference standard for Arcom's enforcement audits starting in 2027. Organizations that complete an RGAA 4.1.2 audit in 2026 before the RGAA 5 publication will need to plan for a partial update audit covering the new WCAG 2.2 criteria and any new mobile/document criteria. The DINUM GitHub repository for RGAA source data (criteres.json) will be the canonical source for scan-access.com's ingestion of RGAA 5 when it becomes available.
Key criteria
The 10 requirements most frequently flagged in automated audits by scan-access.com.
- New: 2.4.11 equiv.
Focus Not Obscured (WCAG 2.2 new — expected)
RGAA 5 will add a criterion equivalent to WCAG 2.2 SC 2.4.11: when a component receives keyboard focus, at least part of it must remain visible and not be hidden by sticky headers or overlays.
Official spec →WCAG 2.4.11 - New: 2.5.7 equiv.
Dragging Movements (WCAG 2.2 new — expected)
RGAA 5 will require a non-drag alternative for all drag-based interactions. French public sector platforms using drag-and-drop (e.g., file upload zones, kanban tools) will need pointer alternatives.
Official spec →WCAG 2.5.7 - New: 2.5.8 equiv.
Target Size Minimum (WCAG 2.2 new — expected)
Interactive targets must meet a 24×24 CSS pixel minimum, or have adequate spacing. French digital services and public apps will need to audit button and link target sizes.
Official spec →WCAG 2.5.8 - New: 3.3.7 equiv.
Redundant Entry (WCAG 2.2 new — expected)
Information previously entered by users must be auto-populated in later steps of the same process. Important for French e-government multi-step forms.
Official spec →WCAG 3.3.7 - New: 3.3.8 equiv.
Accessible Authentication (WCAG 2.2 new — expected)
Authentication must not require solving a cognitive puzzle (CAPTCHA) unless an accessible alternative is provided. France Connect and public sector login portals will be in scope.
Official spec →WCAG 3.3.8 - Mobile: SC 11.x
Mobile applications (new scope)
RGAA 5 extends scope to native iOS and Android apps published by organizations in scope. Criteria map to EN 301 549 Chapter 11 (non-web software) requirements.
- Docs: PDF criteria
Office documents — PDF (new scope)
RGAA 5 will add criteria for PDFs and office documents distributed to the public, aligned with EN 301 549 Chapter 10. Tagged PDF structure, accessible tables, and form field labeling in PDF will be auditable.
- 1.1 (retained)
Images — Alternative text (retained from 4.1.2)
Core criteria from RGAA 4.1.2 are retained in RGAA 5. Image alt text (criterion 1.1) remains mandatory and unchanged.
Official spec →WCAG 1.1.1 - 3.2 (retained)
Contrast ratio (retained from 4.1.2)
The 4.5:1 contrast requirement for normal text and 3:1 for large text is retained in RGAA 5, consistent with WCAG 2.2 and EN 301 549.
Official spec →WCAG 1.4.3 - Arcom enforcement
Arcom audit powers (new in RGAA 5 framework)
RGAA 5 reinforces Arcom's audit authority. Organizations failing accessibility audits can face fines up to €20,000 per service per year. Arcom can now initiate audits proactively, not just in response to complaints.
How scan-access.com covers RGAA 5 (Preview)
scan-access.com coverage
scan-access.com will support RGAA 5 on day of DINUM publication
scan-access.com ingests RGAA criteria from the official DINUM GitHub repository (criteres.json). As soon as DINUM publishes the RGAA 5 criteres.json (expected late 2026), scan-access.com will automatically map axe-core rules to the new criteria, including the 6 new WCAG 2.2 Level AA criteria. In the interim, organizations can use RGAA 4.1.2 scanning to identify the ~100 retained criteria. The 6 new WCAG 2.2 criteria can be audited via the WCAG 2.2 AA scan mode available today. Subscribe to the scan-access.com newsletter to be notified when RGAA 5 support launches.
Free scan against RGAA 5 (Preview). No account required.
Frequently asked questions
When will RGAA 5 be released?
DINUM has announced RGAA 5 for late 2026. The exact date is not confirmed as of May 2026. The RGAA 5 specifications will be published on accessibilite.numerique.gouv.fr, with the criteres.json source file available on the DISIC GitHub repository. scan-access.com monitors this repository and will ingest RGAA 5 as soon as it is published.
What are the main changes in RGAA 5?
RGAA 5 introduces three major changes compared to RGAA 4.1.2: (1) integration of 6 new WCAG 2.2 Level AA criteria (2.4.11, 2.5.7, 2.5.8, 3.2.6, 3.3.7, 3.3.8); (2) extension of scope to mobile applications (mapped to EN 301 549 Chapter 11) and office documents/PDFs (Chapter 10); (3) reinforcement of Arcom's enforcement powers with the ability to initiate proactive audits.
Do existing RGAA 4.1.2 statements remain valid after RGAA 5?
Yes. The 2023 ordinance provides that existing accessibility statements based on RGAA 4.1.2 remain valid for 18 months after RGAA 5 is officially published. Organizations will need to update their statements and re-audit against RGAA 5 within that transition period. Planning the RGAA 5 audit gap analysis — especially for the 6 new WCAG 2.2 criteria and mobile scope — should begin before the official publication.
Will RGAA 5 apply to mobile apps?
Yes. RGAA 5 explicitly extends scope to native mobile applications (iOS and Android). The mobile criteria will align with EN 301 549 Chapter 11 requirements, which require platform accessibility API integration, including VoiceOver (iOS) and TalkBack (Android) compatibility. This is a significant new obligation for French public sector organizations with iOS/Android apps.
What is Arcom's role in RGAA 5 enforcement?
Arcom (Autorité de régulation de la communication audiovisuelle et numérique) replaced the CNIL as the enforcement authority for web accessibility in France in 2023. Under RGAA 5, Arcom gains strengthened audit powers: it can initiate proactive compliance audits (not only in response to complaints), publish non-compliance findings publicly, and levy fines of up to €20,000 per non-compliant service per year for organizations that fail to remediate within the required timeframe.