RGAA 4.1 for French local authorities: digital accessibility moves into control mode

Digital accessibility for French local authorities rests on three texts that have stacked without always converging. The 11 February 2005 law (article 47), setting the principle of accessibility for public sites. The RGAA (Référentiel Général d'Amélioration de l'Accessibilité), version 4.1 published in 2023, breaking down 106 technical criteria (based on WCAG 2.1 AA). The European Accessibility Act (directive 2019/882, transposed into France in 2023, applicable on 28 June 2025), which extends to private services but also tightens public-side controls.

The 2026 wake-up: from declarative to control

For 18 years, the accessibility obligation operated largely on a declarative basis. Local authorities published an "accessibility declaration" that could show 30, 40 or 50% conformity, with no consequence. The legal sanction (up to €25,000) was theoretical, applied at the margin on a few symbolic cases.

The European Accessibility Act changes the game for two reasons. First, it extends the perimeter of controlled services: town-hall sites, online services (civil status, town planning, schools), mobile apps, but also self-service terminals in town halls or libraries. Second, it introduces a structured control mechanism: the DGCL and prefectures are organized to perform targeted controls, with transmission to CSA-Arcom for follow-up.

What RGAA 4.1 requires, in practice

RGAA 4.1 breaks down 106 criteria across 13 themes: images (text alternatives), frames, colours (contrast), multimedia, tables, links, scripts, mandatory elements (lang, title), information structuring, presentation, forms, navigation, and consultation. Each criterion has precise operational tests (e.g., "every button without visible label must have an aria-label attribute").

For a service to be declared "fully conformant", it must validate 100% of applicable criteria. "Partially conformant" means 50-99%. "Non-conformant" means below 50%. Most French local-authority sites are "partially conformant" with a rate between 60 and 75%. Moving to 100% is substantial work — and that work becomes unavoidable.

Three blind spots that trip up local authorities

Inaccessible PDFs

A large share of content published by local authorities goes through PDF: deliberations, minutes, town-planning documents, practical guides. For a PDF to be accessible, it must be properly tagged (PDF/UA), with explicit reading order, text alternatives for images, structured tables. Most public PDFs are scanned or exported without tagging — not accessible.

Legacy online services

"Legacy" online services (civil status, canteen payment, after-school registration, town planning) often rest on old application stacks (Berger-Levrault, JVS, Ciril, Localtis) whose frontend components are dated. Vendors gradually publish accessible versions, but deployments drag — between available version and installed version, count 12 to 24 months.

France Connect and accessibility

France Connect, the state's identity federation system, is broadly accessible. But integration on the local-authority side isn't always — redirects, authentication errors, transition screens are sometimes inaccessible. A screen-reader user trying to pay their canteen bill via France Connect can end up stuck on an error screen with no text alternative.

Practices that work

Local authorities that achieved high conformity share a few practices. First, accessibility at order time, not at acceptance: every public tender tied to a digital service includes an accessibility clause with precise criteria and penalties. Second, annual audit by an independent specialist firm (Access42, Tanaguru, Atalan) rather than self-assessment. Third, an internal accessibility lead, dedicated part-time on the topic, who steers the technical roadmap over 2-3 years.

For a 20,000-100,000-inhabitant authority, typical annual investment to reach and maintain 90%+ RGAA conformity is €30k-80k (audit, progressive redesign, training, lead). To compare with risks (sanctions, litigation, image) which rise quickly with the EAA.