Digital accessibility laws now apply across most major markets. These laws require digital platforms and content to be usable by people with disabilities. This includes websites, apps, documents, and services across both public and private sectors.
This guide explains what digital accessibility laws require, how different countries enforce them, and the standards organizations must follow to stay compliant.
Accessibility laws ensure people with disabilities can use digital tools and services without barriers. These laws are not technology-specific, but they have a clear expectation: digital experiences must be usable without relying on vision, hearing, or fine motor skills.
Most laws refer to accessibility standards like WCAG. But enforcement and consequences vary widely depending on jurisdiction. Knowing what applies to your geography and sector is essential.
Compliance with accessibility laws brings several non-negotiable implications for organizations:
While thresholds and enforcement vary, these groups are typically required to comply:
In the US, digital accessibility is primarily regulated through two federal laws: the ADA and Section 508. These laws create parallel obligations for private businesses and federal agencies, respectively.
1. Americans with Disabilities Act (ADA)
The ADA is a civil rights law that prohibits discrimination based on disability. While it was passed before digital services became mainstream, courts and the Department of Justice (DOJ) interpret the law to include websites and apps.
Under Title II, it applies to public sector entities. Under Title III, it applies to private businesses considered places of public accommodation. Although the ADA does not define a technical standard, WCAG 2.1 Level AA is broadly recognized as the legal benchmark.
Non-compliance can lead to civil penalties of up to $75,000 for a first offense and $150,000 for repeat violations. Lawsuits can be filed without prior notice. The DOJ may also initiate investigations and enforce remediation through settlement agreements.
2. Section 508 of the Rehabilitation Act
Section 508 applies to federal agencies and contractors. It mandates accessibility across all ICT, including internal platforms, websites, mobile applications, emails, and software. The law prescribes WCAG 2.0 Level AA as the minimum conformance level.
Agencies must verify compliance through procurement documentation. Violations can result in contract loss, procurement delays, and administrative complaints through the Office for Civil Rights.
Canada enforces accessibility at both the federal and provincial levels. Federally regulated industries must follow the ACA, while individual provinces like Ontario have their own accessibility laws that may impose stricter requirements.
1. Accessible Canada Act (ACA)
The ACA applies to federal government agencies and industries under federal regulation, such as banking, telecom, and transport. It requires organizations to identify, remove, and prevent accessibility barriers in digital systems.
While not prescriptive, WCAG 2.1 Level AA is strongly encouraged and referenced in enforcement actions. Organizations must submit multi-year accessibility plans, show ongoing progress, and respond to public feedback. Non-compliance can result in fines up to CAD 250,000 per violation and reputational consequences through published investigations.
2. Accessibility for Ontarians with Disabilities Act (AODA)
AODA mandates that organizations with 50 or more employees, whether public or private, conform to WCAG 2.0 Level AA for websites and online documents. It applies only within Ontario but is one of the most prescriptive regional accessibility laws in Canada.
Failure to comply can result in fines up to CAD 100,000 per day for corporations and CAD 50,000 for individuals. Auditors may conduct surprise inspections and issue compliance orders.
The EU uses two legal instruments to govern digital accessibility: the Web Accessibility Directive for public services and the European Accessibility Act for key private sectors. Both rely on EN 301 549, which includes WCAG 2.1 AA as the required standard.
1. Web Accessibility Directive
The directive covers public sector websites and mobile apps across all EU member states. It requires compliance with EN 301 549, which itself incorporates WCAG 2.1 Level AA. Covered institutions include government departments, municipalities, public universities, and health agencies. Each country conducts periodic audits and publishes reports.
Institutions that fail to meet compliance may receive warnings, be subject to investigations, or lose eligibility for EU funds.
2. European Accessibility Act (EAA)
The European Accessibility Act (EAA) requires private companies that offer essential services in the EU, such as banking, e-commerce, telecommunications, and ticketing, to make their products and services accessible to people with disabilities. Any business providing these services in the EU, even if based outside the EU, must comply.
To meet the requirements, companies must follow the EN 301 549 accessibility standard. This includes making websites, apps, and digital tools usable by people with different disabilities, similar to meeting WCAG 2.1 AA guidelines.
Penalties for non-compliance vary by country but may include fines up to €100,000, removal from the market, or lawsuits from advocacy groups.
The UK enforces accessibility through both civil rights and technical compliance laws. After Brexit, the UK retained and continues to enforce both the Equality Act and its own public sector regulations.
1. Equality Act 2010
The Equality Act prohibits discrimination against individuals with disabilities. Inaccessible websites, mobile apps, and digital services are considered violations under this law. It applies to both public and private sector organizations. Disabled individuals can bring civil lawsuits. Courts may issue injunctions, and organizations often face reputational fallout as a result of legal proceedings.
2. Public Sector Bodies Accessibility Regulations 2018
This regulation enforces WCAG 2.1 Level AA for all public sector websites and mobile applications. Institutions must publish an accessibility statement and offer a channel for user feedback. Enforcement includes scheduled audits, compliance warnings, and publication of non-conforming organizations.
India addresses digital accessibility through civil rights legislation and mandatory government IT guidelines. Public sector websites and apps must follow strict standards, and private sector involvement is increasing through court directives.
1. Rights of Persons with Disabilities Act (RPwD)
This Act recognizes digital access as a basic right for persons with disabilities. It holds public-facing government platforms legally accountable for digital inclusion. Non-compliance may trigger intervention from the judiciary. Several public interest litigations have resulted in court directives enforcing WCAG conformance.
2. GIGW (Guidelines for Indian Government Websites)
GIGW, maintained by the Ministry of Electronics and Information Technology, mandates WCAG 2.1 AA conformance for websites and mobile apps. GIGW 3.0 expands the scope to digital forms and transactional platforms. Central and state government portals are subject to regular audits. Violations may result in plan rejection and removal from central procurement platforms.
Australia governs accessibility through its national anti-discrimination law. While it does not prescribe WCAG by name, government guidance and legal cases have made the expectation clear.
1. Disability Discrimination Act (DDA)
Australia’s DDA prohibits discrimination on the basis of disability across all services, including digital offerings. Although the Act is technology-neutral, inaccessible websites have been repeatedly judged as non-compliant in legal proceedings.
The Australian Government endorses WCAG 2.0 AA for public digital services. Complaints can be escalated to the Human Rights Commission and eventually to the Federal Court.
Japan uses a two-part system: a civil rights law for government agencies and a national technical standard for implementing accessibility. Compliance is enforced through ministry oversight and public pressure.
1. Act on the Elimination of Discrimination Against Persons with Disabilities
This law establishes the responsibility of government institutions and public service providers to avoid discrimination, including through digital interfaces. While the law does not include detailed technical requirements, it clearly states that all reasonable efforts must be made to ensure accessibility across services.
This creates a legal framework for digital inclusion without explicitly naming WCAG. It applies mainly to government and quasi-government services, but private companies are also encouraged to comply when receiving public funding or providing public-facing services.
2. JIS X 8341-3
JIS X 8341-3 is the Japanese Industrial Standard for web accessibility. It is based on WCAG 2.0 Level AA and is treated as the technical benchmark for accessibility in the country. Public institutions are required to follow it, and ministries often evaluate compliance during site assessments or funding reviews.
While it is not legally binding on private companies, it is widely used by larger enterprises to demonstrate accessibility maturity in public tenders. Some municipalities conduct accessibility rankings, which put additional public pressure on underperforming organizations.
Brazil enforces digital accessibility under national civil rights law, supported by federal technical guidelines. Both public and private digital platforms are covered.
1. Brazilian Inclusion Law (Statute of Persons with Disabilities)
This law requires that all digital platforms offering services to the public must be accessible to people with disabilities. It defines digital accessibility as a core civil right and extends its application to websites, mobile apps, self-service terminals, and digital documents.
The law grants individuals the right to seek redress if they are denied access due to digital barriers. Civil claims under this statute are increasingly common, particularly when accessibility is missing from public services or banking and telecom platforms.
2. e-MAG (Electronic Government Accessibility Model)
e-MAG is Brazil's official accessibility guideline for digital government. It incorporates WCAG 2.0 AA and supplements it with usability and documentation requirements specific to Brazilian administrative systems. All federal websites and platforms must comply with e-MAG, and regular audits are conducted by internal control bodies.
Penalties for non-compliance can include fines from R$500 to R$100,000 per day, depending on the severity and duration of the violation. e-MAG is also used as a procurement requirement, disqualifying vendors that fail to meet its benchmarks.
Israel’s accessibility regulations are among the most detailed in the Middle East. They apply across sectors and mandate conformance with WCAG.
1. Equal Rights for Persons with Disabilities Regulations
This regulation mandates WCAG 2.0 AA conformance for any service offered online to the public. It applies across both private and public sectors, including mobile apps and internal digital systems.
Fines of up to 50,000 Israeli Shekels can be imposed even in the absence of proven harm. Courts can set strict compliance deadlines, and government publications may list non-conforming entities.
Meeting digital accessibility laws is not just a development checklist—it requires a coordinated effort across design, engineering, content, procurement, and governance. Compliance depends on understanding the legal expectations and aligning your product and delivery processes to meet them consistently.
Here are the six practical pillars for ensuring legal compliance:
Design choices often create the earliest accessibility barriers. Fonts, colors, focus styles, and interactive elements need to work for users with visual, motor, and cognitive impairments.
Accessibility relies on how screen readers and assistive tech interpret the structure of a page, not just how it looks visually.
Compliance also depends on how content is structured and described, particularly for users relying on screen readers or voice input.
Testing accessibility on real devices is necessary because emulators and local previews miss key issues. Simulated environments do not accurately replicate how screen readers announce content, how keyboard focus behaves across browsers, or how zoom and reflow work on physical screens.
For example, screen readers may skip labels or read out incorrect elements in real usage, even if they appear correct in code.
BrowserStack Accessibility Testing allows teams to run accessibility checks on real devices and browsers under the same conditions that actual users face.
One-off accessibility training is not enough. Each team needs to understand what accessibility means for their specific responsibilities.
Sustaining accessibility means putting controls in place that prevent regressions and hold teams accountable.
Legal complaints and enforcement actions are often triggered by a handful of predictable failures. These are not edge cases, but are recurring problems that can be addressed with the right process and attention.
Here are the most common violations that lead to non-compliance, and how to prevent them:
1. Missing or Incorrect Alt Text
Violation: Images lack descriptive alternative text or include misleading or irrelevant descriptions. Decorative images are not marked with alt="", leading screen readers to read file names or unnecessary labels.
Fix: Provide clear, concise alt text that describes the function of the image. Use empty alt text for purely decorative images.
2. Inaccessible Forms
Violation: Form fields are not associated with labels, error messages are not announced, and required fields aren’t identified clearly. Some forms break tab order or skip elements entirely.
Fix: Use <label> elements properly connected to each input. Provide aria-describedby for instructions and error messages. Ensure all fields are reachable via keyboard.
3. Low Contrast Text
Violation: Text on buttons, navigation, or body copy fails minimum contrast requirements. Users with low vision or color blindness cannot read the content.
Fix: Check that all text and interactive elements meet at least a 4.5:1 contrast ratio for normal text and 3:1 for large text.
4. Lack of Keyboard Access
Violation: Some interactive elements can only be activated with a mouse, such as dropdowns, sliders, modals, or hidden menu items.
Fix: Ensure all components can be navigated and activated using the keyboard alone. Focus order must follow the visual layout.
5. Improper Use of ARIA
Violation: ARIA attributes are used to force structure where native HTML would suffice, often resulting in incorrect labeling or screen reader confusion.
Fix: Prefer native elements whenever possible. Only use ARIA roles and attributes when absolutely necessary and test their behavior using real assistive technologies.
6. No Screen Reader Support for Dynamic Content
Violation: Pop-ups, modals, alerts, or form validation messages are not announced by screen readers. Users don’t know that the content has changed.
Fix: Use ARIA live regions or role="alert" for dynamic updates. Ensure focus moves to new content when appropriate.
7. Video Without Captions or Audio Without Transcripts
Violation: Multimedia content lacks captions or transcripts, making it inaccessible to users who are deaf or hard of hearing.
Fix: Provide closed captions for all videos and transcripts for audio content. Captions should include both speech and relevant sounds (e.g., “[laughter]”).
8. PDF and Document Accessibility
Violation: Digital documents (PDFs, DOCX, PPT) are not tagged for accessibility, making them unreadable by screen readers.
Fix: Tag documents properly before publishing. This includes reading order, logical headings, alt text for images, and table structure.
Digital accessibility is now a legal requirement across most major markets, not just a best practice. From the ADA in the U.S. to EN 301 549 in the EU and e-MAG in Brazil, governments are holding both public and private organizations accountable for ensuring their digital services work for everyone, including users with disabilities.
To stay compliant, accessibility needs to be treated as a long-term responsibility, not a one-time fix. This means assigning ownership, setting up review processes, testing with real users, and tracking accessibility issues like any other product defect.
Run Accessibility Tests Seamlessly
Get visual proof, steps to reproduce and technical logs with one click
Continue reading
Try Bird on your next bug - you’ll love it
“Game changer”
Julie, Head of QA
Try Bird later, from your desktop