RGAA 5: what changes, the timeline and how to prepare

Updated By Omnireso9 min read

RGAA 5 is the next version of France’s digital accessibility framework. Drafted by DINUM with a working group, it is announced for the end of 2026, builds on RGAA 4.1.2 rather than replacing it wholesale, and adopts WCAG 2.2 as its technical reference.

In brief

Timeline and official status

DINUM officially announced a new RGAA version in March 2026. The official portal states that version 5 is being drafted, with publication planned for the end of 2026. This does not call current work into question: it must be neither suspended nor postponed.

On 24 September 2026 at the Paris Web conference, Aurélien Levy (Temesis) and Stéphanie Nazarian (DINUM) presented the future framework’s structure. A report by Includdy mentions a move from 106 to about 146 criteria; treat this as a working figure, not a final value.

Check before deciding: the final text is not published. See the official RGAA portal (French) for the latest status.

What changes in RGAA 5

1. WCAG 2.2 as technical basis

RGAA 4.1.2 rests on WCAG 2.1. RGAA 5 integrates WCAG 2.2, which adds nine success criteria, six of them at levels A and AA (the only ones retained, as the framework covers A and AA). Criterion 4.1.1 “Parsing” was removed from WCAG 2.2.

2. A wider scope

Native mobile applications and office documents (PDF, Word, LibreOffice) come into scope, in line with EN 301 549. Each test may have a web, mobile or document variant, modelled on Luxembourg’s frameworks (RAWeb for web, RAAM for mobile, RAPDF for PDF).

3. Themes from EN 301 549

Documentation and accessibility features, authoring tools, real-time communication, and a dedicated CAPTCHA theme. The working group builds on RAWeb 1.1 (Luxembourg).

4. Clearer wording

Criteria move from question form to affirmative statements. Provisional example: “The text alternative of each informative image is relevant.” Tests remain phrased as questions.

5. A richer accessibility statement

The future statement template should surface blocking issues, defects that prevent completing a task. The compliance-rate calculation stays the same in version 5.0.

The six WCAG 2.2 criteria to check now

WCAG 2.2 level A and AA criteria entering RGAA 5
CriterionLevelWhere to look in your code
2.4.11 Focus Not Obscured (Minimum)AASticky headers and footers, cookie banner
2.5.7 Dragging MovementsAADrag and drop, kanban boards, sliders
2.5.8 Target Size (Minimum)AAIcon buttons, carousel dots, tight links
3.2.6 Consistent HelpATemplate, footer, chat widget
3.3.7 Redundant EntryACheckout flows, multi-step forms
3.3.8 Accessible Authentication (Minimum)AALogin, one-time codes, CAPTCHA

Concrete example for 2.4.11: an 80 px sticky header can cover the focused element when going back with Shift+Tab. Two lines of CSS reserve the space.

html {
  scroll-padding-top: 6rem;    /* fixed header height + margin */
  scroll-padding-bottom: 5rem; /* fixed footer or banner */
}

For 3.3.8, allow pasting and password managers: autocomplete="current-password", autocomplete="one-time-code", and never onpaste="return false". Details in the WCAG 2.2 page.

What happens to your RGAA 4.1.2 audits and statements?

Per DINUM’s announcement, accessibility statements established on RGAA 4.1.2 remain valid for 18 months after RGAA 5 is published, within three years of their own publication date. After that, a statement based on the new framework will be needed.

In practice: don’t wait to fix issues, but don’t redo a full audit just to “switch versions” before the beta and transition calendar are known.

Preparation checklist, template by template

Almost all of these points are checked by hand. Work template by template: a defect in the header repeats across the whole site and is fixed once.

  1. Tab forward and back (Shift+Tab) under every sticky header, footer or banner: no focused element may disappear.
  2. Measure the clickable area of icon buttons and tight links (24 × 24 CSS px minimum, 44 px recommended for key actions).
  3. Redo every drag-and-drop action with single clicks.
  4. Compare the order of help links (contact, FAQ, chat) across five templates.
  5. Spot any information requested twice in multi-step flows.
  6. Log in with a password manager, then by pasting username and code.
  7. Check that captions and audio description are as easy to switch on as playback.
  8. Switch to dark mode, high contrast and enlarged text, then review the page.

Find tools to automate what can be automated in the tool selection.

Frequently asked questions

When will RGAA 5 be published?

DINUM announces end of 2026, preceded by a beta. No exact date is guaranteed: follow the official portal.

Does RGAA 5 replace RGAA 4.1.2?

It is designed to build on RGAA 4.1.2, not make it obsolete: RGAA 5 criteria clarify or complete version 4 without contradicting it.

How many criteria will RGAA 5 have?

A Paris Web 2026 report mentions about 146 criteria versus 106 today. The number is provisional until the final version is published.

Will RGAA 5 cover mobile applications?

Yes, the announced scope includes native mobile apps and office documents, aligned with EN 301 549.

Should I already test for WCAG 2.2?

Yes. The six A and AA criteria have been published since October 2023. Add them to your user stories and acceptance tests now.

Sources and references