Countries across the globe have established digital accessibility laws, often based on the Web Content Accessibility Guidelines(WCAG) by the World Wide Web Consortium(W3C). These guidelines offer technical standards to make web content accessible to people with disabilities.
Businesses offering online services to users worldwide should be aware of the relevant accessibility standards for different regions and the specific version of WCAG that their services are based on. In this post, we’ll explore the major global digital accessibility regulations—including Section 508, EN 301 549, and Accessible Canada Act, among others—the WCAG version they reference, and how to comply.
Understanding the Web Content Accessibility Guidelines (WCAG)
Before we get started, it’s important to be familiar with WCAG, which has significantly influenced web design and development practices, promoting an inclusive digital environment for everyone.
WCAG is divided into three levels, each representing a progressively higher standard of accessibility.
Level A is the most basic level. It includes essential requirements that eliminate the most significant barriers for users with disabilities. Examples of Level A requirements include providing text alternatives for images and ensuring basic keyboard navigation.
Level AA is considered the legal standard in many countries and is the most commonly adopted level. Requirements at Level AA include sufficient color contrast between text and background and properly labeled form fields.
Level AAA is the highest and most comprehensive level. However, it’s not widely used due to its strictness. Level AAA includes advanced requirements such as providing sign language interpretation for multimedia content.
WCAG 2.0 vs. 2.1 vs. 2.2: What’s the Difference?
While WCAG 2.0 laid the foundational framework for web accessibility when it was published in 2008, newer versions—WCAG 2.1 (2018) and WCAG 2.2 (2023)—expand that framework to address more user needs, especially for mobile users, people with low vision, and individuals with cognitive or learning disabilities.
WCAG 2.0 introduced the original set of 61 success criteria built around the four POUR principles (Perceivable, Operable, Understandable, and Robust). It covered critical accessibility needs for screen reader users, keyboard navigation, and basic interaction. However, it didn’t fully address touch-based interfaces or cognitive impairments—gaps that became increasingly significant with the rise of smartphones and tablets.
WCAG 2.1 added 17 new success criteria to close those gaps. It introduced mobile-friendly requirements such as ensuring content adapts properly to different screen sizes.
WCAG 2.2 added 9 new success criteria, with a stronger focus on cognitive accessibility and usability. A key addition is accessible authentication, which ensures that there are alternative forms of CAPTCHA-style tests to accommodate different disabilities.
Navigating the Major Global Accessibility Laws
United States
Americans with Disabilities Act: The landmark U.S. civil rights law, enacted in 1990, prohibits discrimination against individuals with disabilities in all areas of public life, including in digital spaces. The U.S. government and courts commonly reference the WCAG as the de facto benchmark for compliance, specifically recommending version 2.1 Level AA as the standard for making digital content accessible under the ADA.
Section 508 of the Rehabilitation Act: This is the primary federal accessibility standard, and requires all federal agencies to ensure their digital information is accessible to people with disabilities. It aligns with WCAG 2.0 Level AA.
European Union
EN 301 549 Standard: The European Union’s digital accessibility framework requires all public sector websites and mobile apps to be accessible and is based on WCAG 2.1 Level AA, ensuring that newer considerations such as mobile responsiveness and non-text contrast are included. This regulation applies across all EU member states and is monitored at the national level.
The European Accessibility Act (EAA): Required to be implemented by EU countries by June 2025, the EAA sets accessibility requirements for including websites, mobile apps, e-books, ATMs, banking services, e-commerce platforms, and more. It aligns with WCAG 2.1 Level AA.
Canada
Accessible Canada Act (ACA): Canada’s federal accessibility law came into effect in 2019 and applies to federal government agencies and federally regulated industries such as banking and transportation. Currently, the ACA mandates conformance with WCAG 2.0 Level AA.
Accessibility for Ontarians with Disabilities Act (AODA): At the provincial level, Ontario’s AODA also enforces WCAG 2.0 AA for public and private organizations.
Australia
Disability Discrimination Act (DDA): Similar to the U.S. ADA, this is the key legislation in Australia that prohibits discrimination on the basis of disability, including in digital environments. It recommends compliance with WCAG 2.1 Level AA.
France
RGAA: Référentiel Général d’Amélioration de l’Accessibilité, or the General Accessibility Improvement Framework, is mandatory for all public sector websites and is based on WCAG 2.1 Level A and AA.
Germany
Berlin Barrier-free Information Technology Ordinance (BITV): Updated in 2019, BITV 2.0 now requires conformance with WCAG 2.0. This applies to public sector websites and mobile apps, but private organizations are also encouraged to comply with guidelines.
United Kingdom
The Equality Act of 2010: Mandates that service providers — both public and private — must not discriminate against individuals with disabilities. This includes requiring websites and digital services to make content accessible to all users. However, the Act doesn’t specify technical criteria.
Public Sector Bodies Accessibility Regulations: Requires public sector websites and apps to meet accessibility standards based on WCAG 2.1 at level AA compliance.
India
Rights of Persons with Disabilities Act: An Indian anti-discrimination law that adopts a version of EN 301 549, which uses WCAG 2.1 AA as the compliance standard.
Guidelines for Indian Government Websites (GIGW 3.0): Aligned with WCAG 2.1 Level AA and applies to all government websites and mobile apps.
Japan
Japanese Industrial Standard X 8413-3 (JIS X): Developed by the Japanese Industrial Standards Committee (JISC), this is Japan’s national standard for web accessibility. The most recent version is closely aligned with WCAG 2.0 at the AA level.
Protecting Your Business: The Importance of Global Accessibility Laws
Adhering to the WCAG 2.1 AA standards is increasingly recognized as an essential best practice among businesses. For private companies and public entities operating on a global scale, it’s crucial to understand these accessibility laws to ensure that your digital platforms—such as websites, applications, and online services—are fully accessible to all users.
Whether you play the role of an app developer, website designer, or business owner, having a solid understanding of these international regulations is vital for creating inclusive digital experiences that cater to a diverse audience while also mitigating the risk of legal challenges or penalties.
To tackle ADA issues, businesses should consult accessibility experts like EcomBack, which provides manual testing services and remediation methods to fix the root code issues, removing accessibility barriers.
