As RGAA 5 (General Accessibility Improvement Framework) is set to arrive at the end of 2026, and the European Accessibility Act (EAA) has been in force since June 2025, many companies and public organizations are turning to AI-based tools to automate their compliance efforts.

It’s an interesting approach, but one that shows its limits when faced with the demanding criteria of a framework that is still evolving.

Guillaume Jiguel, Technical Director at Insign, shares his analysis of the topic.

To quickly assess the current state of compliance, the numbers are clear: a mapping study published in late 2025 by DINUM (Interministerial Directorate for Digital Affairs) shows that 95% of French municipal websites do not meet accessibility standards. The private sector is not spared either, since as of June 2025, businesses, e-commerce players, and service platforms are subject to accessibility obligations under the EAA, and must produce and publish a website audit report—an obligation that is still widely overlooked.

While collective delays have been building for 20 years (since Article 47 of the “February 11, 2005 law for equal rights and opportunities” requiring accessibility), DINUM officially announced on March 2 that RGAA 5 will arrive by the end of 2026. This new version marks a turning point: it incorporates international WCAG 2.2 recommendations and extends criteria to mobile applications and office documents.

The updates introduced in the new RGAA version also strengthen legal obligations and designate Arcom as the oversight authority, which is rolling out an online service for filing and publishing accessibility statements. Simply put: accessibility is no longer optional. With tighter regulations and the urgency to catch up, many organizations are turning to AI-based tools as a faster and less expensive alternative to a full manual audit.

AI for accessibility: big promises… and real limits

Given the perceived complexity of RGAA 4 and its 106 criteria, artificial intelligence can look like a miracle solution, with many tools emerging and promising a full audit in just a few hours (vs. days). These tools can indeed provide a useful first snapshot and detect some obvious technical issues—even though this could already be done in an automated way before AI-based solutions arrived. Automated tools, no matter how powerful they are thanks to AI, only cover part of RGAA criteria. Why this limitation? AI excels at detecting simple, measurable technical issues, but it falls short on anything involving understanding, context, and intent.

The risks of “artificial” compliance

Relying only on a fully automated solution exposes your organization to three major types of risk:

• Legal risk

Since June 2025, inspections by Arcom and the DGCCRF have intensified, and financial penalties have already been issued for non-audited websites. But even audited websites declared “partially compliant” are not out of danger: a single report of difficulty from a person with a disability can trigger a deeper inspection.

Be careful with services that highlight AI and promise instant compliance audits. In most cases, they do not truly verify compliance with all 106 RGAA criteria.

These approaches are also regularly criticized by associations representing people with disabilities.

In the event of an inspection, your liability remains fully engaged, regardless of the tool used.

• Brand and reputation risk

As a reminder, in France, around 10 to 12 million people live with visible, invisible, or cognitive disabilities and are directly concerned by digital accessibility.

As with any of us, a poor user experience immediately translates into a weakened brand image and loss of trust, directly impacting your reputation. The risk is even higher for organizations that promote inclusive values, and today, an organization’s image can be damaged in a very short time. Social media and review platforms are especially powerful amplifiers in this regard.

Using AI as the only accessibility solution—while trendy and innovative for some—can also be seen as a lack of human commitment on a deeply human issue.

• Business risk and missed opportunities

Inaccessibility means excluding potential customers and directly losing revenue. For e-commerce businesses, a non-accessible purchase journey immediately results in lost conversions and cart abandonment.

For companies, it means being unable to bid on public tenders where accessibility has become a mandatory criterion under the EAA. And for municipalities and local authorities, the issue goes beyond all these risks—it is a matter of equality. An inaccessible municipal website immediately prevents citizens from accessing essential services (civil status, school registration, urban planning, and more…)
In the middle of municipal election campaigns, digital public service accessibility is becoming an evaluation criterion for many voters.

What comes next with the new RGAA version?

RGAA 5 is coming, Arcom is stepping into its oversight role, penalties are now enforceable, and the era of complacency is over. But beyond regulatory requirements, accessibility should be viewed for what it truly is: a strategic investment, not a cost.*

Artificial intelligence has its place in this process and is a relevant tool for establishing an initial assessment and identifying major compliance trends on your website. It can also act as an assistant to fix certain simple technical criteria and suggest content improvements, such as text alternatives, before your validation.

But it cannot replace human expertise when it comes to guaranteeing real, relevant, and sustainable accessibility. Because accessibility is not only about technical compliance—it is also about real-life use, understanding how a person with a disability interprets your content and interacts with your site.

An accessible website is not just a compliant website: it is a website that opens its doors to everyone, without exception