RGAA 5: how to prepare the transition without paying twice
You paid for an audit against the RGAA (référentiel général d'amélioration de l'accessibilité), version 4, in 2025. Your accessibility statement is online. Now an RGAA 5 is announced for the end of 2026, with about forty more criteria. Your money stays well invested if you act in the right order.
The French interministerial digital directorate (DINUM), which owns the standard, put it in black and white in March 2026: work already started on RGAA 4 should not be suspended or postponed. The new criteria clarify and complete the old ones. What you fix today stays fixed tomorrow.
The timeline, the obligations and the order of work
#The dates that set your timeline
RGAA 5 still awaits its date of entry into force. Some milestones are already known, and each one calls for an action on your side. The table sums them up.
| Date | Event | What you do |
|---|---|---|
| June 28, 2025 | The European Accessibility Act (EAA) applies in France | Check whether your consumer-facing services are covered |
| March 4, 2026 | DINUM announces RGAA 5 | Keep going with the fixes already started on RGAA 4 |
| Before publication | Beta version of the standard, with criteria already stabilized | Compare your priorities with the new criteria |
| End of 2026 (target) | Publication of RGAA 5, with a FAQ and a differences view | Read the differences view, adjust the fix plan |
| After publication | Decree that makes RGAA 5 official | Plan the RGAA 5 audit |
| From 2027 | Opening of the online declaration service, with RGAA 5 | Prepare to file your statement on the online declaration service |
| Publication plus 18 months | End of validity of RGAA 4 statements, capped at 3 years after their date | Have published an RGAA 5 statement |
The decree that will make RGAA 5 official does not depend on DINUM: expect anywhere from a few weeks to a few months, depending on whether the procedure falls before or after the 2027 presidential election. As soon as it is published online, RGAA 5 becomes the reference version for new statements.
The 18-month rule is already in the official RGAA obligations: a statement is updated 3 years after its publication, or 18 months after the release of a new version of the standard, whichever comes first.
Eighteen months is short. It has to hold the redesign of your journeys, the audit, then the writing of the statement. If you wait for publication to start, the whole window goes to catching up.
#What RGAA 5 changes, in short
The number going around is impressive: from 106 criteria to about 146. The topics that are truly new and high-impact come down to 6 to 10 criteria.
The rest is rules that serious teams already apply. Three changes matter for an executive:
- WCAG 2.2 built in. The six new level A and AA criteria of the Web Content Accessibility Guidelines (WCAG) 2.2 published by the W3C enter the standard: size of clickable targets, help always in the same place, login without a cognitive test.
- Mobile and office documents. Each test may have a version for mobile apps and documents.
- Reworded criteria. They switch to the affirmative and now read like good practices. All titles remain provisional for now.
What stays put matters just as much: the method for calculating the compliance rate stays the same in version 5.0.
You can aim for WCAG 2.2 today without waiting for the final version. The criterion-by-criterion detail, for your technical teams, is in our dedicated article.
RGAA 5: get compliant before the new version is released
#RGAA, EAA or both: your case
Two texts coexist, with two different logics. Before budgeting anything, put each legal entity of your group in the right box.
The RGAA. It stems from article 47 of the 2005 law. It targets public bodies, their delegates and companies whose revenue in France exceeds €250 million, on average over the last three fiscal years (decree no. 2019-768, article 2). The threshold is assessed company by company.
The EAA. The European Accessibility Act, transposed into the Consumer Code, reasons service by service: online commerce, banking, transport, electronic communications. It applies to all companies that provide these services to consumers, except micro-enterprises with fewer than 10 employees whose revenue or balance sheet does not exceed €2 million (France Num practical guide). Enforcement falls to the French consumer protection authority (DGCCRF).
The difference in logic changes everything. The RGAA calculates a rate on a sample of pages. The EAA looks at whether a customer can complete the service: choose, pay, track an order.
The free test below places you in a few questions.
Free test: is my organization covered by the EAA?One clarification: a private company can follow another public method than the RGAA, provided it supplies a correspondence table with the European standard EN 301 549.
#The accessibility statement today and tomorrow
Two topics often get mixed up in discussions. They need to be kept apart.
Today. The accessibility statement is mandatory for public bodies, their delegates and companies above €250 million in revenue (official scope). It is published on your site, using the template provided by the RGAA.
Tomorrow, from 2027. With RGAA 5, the accessibility statement will have to be filed on a dedicated online declaration service: a service where you enter your data and it stores them automatically. Administrations go first. For companies, a €50 million revenue threshold is being considered, to be confirmed by the texts. Until then, the statement keeps being published on your site, and the online declaration template is still to be published.
The new statement template will bring a substantive novelty: blocking issues. The statement will have to flag the defects that prevent a user from completing a task. A service that has any should no longer be able to call itself "partially compliant". There would be no fixed list: whether an issue is blocking would be assessed according to the function and purpose of the service.
A payment funnel that cannot be used with a keyboard will weigh more than a respectable compliance rate.
Start with the blocking issues.
#Who inspects and what you risk
Three players can knock on your door. The French audiovisual and digital communication regulator (Arcom) enforces the obligations of the 2005 law. For companies above €250 million, it checks the statement, the multi-year plan, the action plan and the compliance mention, with penalties up to €25,000; the €50,000 ceiling for the accessibility failure itself targets the public sector. The DGCCRF enforces the EAA, with fines up to €7,500 per breach for a company, €15,000 for repeat offenses, which can be combined per service.
The third player is associations in court. On May 5, 2026, the Lille judicial court rejected the claim against Auchan E-commerce, which was judged to be below the €250 million threshold. On June 4, 2026, the Caen judicial court ordered Carrefour to bring its grocery site and app into compliance, under a daily penalty.
Two decisions, two outcomes. The legal risk already exists. The detail of penalties and procedures is in our article on the EAA.
EAA and web accessibility: what changes for your business in 2026
#How to prepare the transition without paying twice
Most companies start with an audit. It is the most expensive step to place at the wrong time. A transitional audit between RGAA 4 and RGAA 5 ties up a budget that fixing uses better. The audit validates work already done.
Here is the order we recommend.
- Map your regimes. For each company and each service, note whether the RGAA, the EAA or both apply. A one-page table is enough.
- Calculate your deadline. Take the date of your current statement and apply the rule: 3 years, or 18 months after the publication of RGAA 5, whichever comes first.
- Fix the critical journeys. Cart, payment, login, contact forms: these are the future blocking issues. To spot defects before the audit, the Includdy tool analyzes a page or a component at a time, explains each error and helps prioritize the fixes. An automated tool shortens the list the auditor will have to check.
- Require WCAG 2.2 level AA. Launching a redesign or looking for a service provider? Write this level into the contract and into the acceptance criteria. Every compliant delivery spares you a fix later.
- Read the beta. As soon as it is out, compare the differences view with your plan and add the criteria that affect your journeys.
- Audit last. After publication, within the 18-month window, order an RGAA 5 audit that records work already done, then file the new statement (on the online declaration service from 2027).
An audit measures. Have it measure a site that is already repaired.
To find out where your key pages stand before choosing an auditor, run a first analysis with Includdy.
