If you've been pointed at any of these three names — usually by a compliance email, a procurement checklist, or a search for "EAA requirements" — the confusing part isn't that they conflict. It's that they mostly don't, and once you see how they nest inside each other, the choice of which one to test against stops being confusing.
Short version: WCAG is the content, EN 301 549 is Europe's legal packaging of that content plus more, and RGAA is France's operational testing method for applying it. Here's the detail, checked against the standards bodies' own documents rather than secondary summaries.
WCAG 2.1 AA: the underlying rules
The Web Content Accessibility Guidelines, published by the W3C, are the actual technical rules: things like "text has sufficient contrast against its background" (Success Criterion 1.4.3), "all functionality is available from a keyboard" (2.1.1), "form fields have programmatically associated labels" (4.1.2). WCAG 2.1 has 50 success criteria at the AA conformance level, organized under four principles — content must be Perceivable, Operable, Understandable, and Robust (often abbreviated POUR).
WCAG itself isn't law anywhere by default. It's a technical recommendation. It becomes a legal requirement when a government or regulation points to it — which is exactly what both of the next two standards do.
EN 301 549: Europe's harmonised standard, built directly on WCAG
EN 301 549 is a European harmonised standard, jointly produced by three standards bodies (ETSI, CEN, and CENELEC) under mandate from the European Commission. It's the standard referenced by EU accessibility law, including the European Accessibility Act, when those laws need a concrete technical bar to point to.
The relationship to WCAG isn't loose paraphrasing — it's direct incorporation by reference. Chapter 9 of EN 301 549 (the ETSI-published standard document; the current in-force version is v3.2.1) covers web content, and its clause numbering is deliberately built to mirror WCAG's — clause 9.1.4.3 in EN 301 549 corresponds directly to WCAG success criterion 1.4.3, and so on through the chapter. A WCAG 2.1 AA conformance claim and a Chapter 9 conformance claim are, in substance, the same claim.
Where EN 301 549 goes further than WCAG:
- Chapter 10 applies equivalent WCAG-derived criteria to non-web documents (PDFs, office file formats).
- Chapter 11 applies the same approach to non-web software, including native mobile apps — something WCAG, being a web content standard, was never written to cover.
- Additional chapters address hardware, telecommunications features (like real-time text), and authoring-tool requirements — areas entirely outside WCAG's scope.
So EN 301 549 is best understood as "WCAG 2.1 AA, embedded in full for web content, plus a broader ICT-accessibility standard wrapped around it for everything WCAG doesn't reach." A site that passes WCAG 2.1 AA has satisfied the web-content chapter of EN 301 549; it hasn't automatically satisfied chapters covering non-web software or hardware, if those are relevant to what you're building.
Worth flagging as a coming change, not yet in force: a new version, EN 301 549 V4.1.1, is expected to be harmonised around October 2026 and will upgrade the baseline from WCAG 2.1 AA to WCAG 2.2 AA — adding criteria like focus appearance, dragging-movement alternatives, and accessible authentication. If you're building compliance processes now, it's worth knowing WCAG 2.1 AA is very likely a moving target within this same year, not a permanent bar.
RGAA 4.1.2: France's own testing method, implementing the same base
The Référentiel Général d'Amélioration de l'Accessibilité (RGAA), maintained by DINUM, the French government's digital directorate, is France's national accessibility framework. The current version is RGAA 4.1.2, formally adopted by joint order of the ministers responsible for disability and for digital affairs on 20 September 2019 and updated since.
RGAA isn't a competing standard with different rules — it's a French-specific operational method for testing conformance to the same underlying WCAG-based requirements, translated into 106 concrete test criteria in French, each mapped back to the relevant WCAG success criteria and organized into 13 thematic sections (images, frames, colours, multimedia, tables, links, scripts, mandatory elements, structure, presentation, forms, navigation, consultation). Where EN 301 549 is the EU's legal reference document, RGAA is closer to France's how-to-actually-test-this handbook — it exists because "conform to WCAG 2.1 AA" leaves real interpretation room in practice (how do you concretely verify 1.4.3 on a specific page?), and RGAA closes that gap with named, numbered procedures.
RGAA carries specific legal weight in France beyond the EU baseline: it's the reference method public-sector bodies (and, per the 2023 ordonnance discussed in our France deadline page, certain large private operators) are expected to use when demonstrating conformance, and it's what French accessibility audits are typically conducted against.
So which one should you actually test against?
- If you just want to know whether your site meets the internationally recognised technical bar — test against WCAG 2.1 AA. This is what our own free scanner checks, using axe-core rules mapped to WCAG 2.0/2.1 A and AA success criteria.
- If you're specifically responding to EU accessibility-law obligations (the EAA, procurement requirements referencing EN 301 549) — the relevant technical bar is still WCAG 2.1 AA in substance, packaged as EN 301 549 Chapter 9, plus whatever non-web chapters apply to your product.
- If you're a French public body or an operator specifically required to demonstrate RGAA conformance — you need the RGAA 4.1.2 methodology and its 106 criteria specifically, likely via a human audit; an automated WCAG scan gets you a meaningful head start (RGAA's criteria are WCAG-derived) but won't produce an RGAA-format audit report on its own.
In practice, the three rarely conflict on substance — a page that genuinely satisfies WCAG 2.1 AA is most of the way to satisfying EN 301 549's web chapter and RGAA's web-content criteria too. The differences are about packaging, scope beyond web content, and which document a specific regulator or contract points to — not about different accessibility standards pulling in different directions.