23 laws and standards across 19 jurisdictions. For each one: who it covers,
which version of WCAG it points at, and the dates that matter. Because the useful question
is almost never "is there a law", it is "which version, at which level, and by when".
The laws
This is not legal advice. It is a working map, written
to help you ask the right question and read a tender without panic. Laws change, dates
move, and the detail that decides your case is usually local. Before anything binding,
check the current text in the jurisdiction that applies to you, and take advice.
The pattern behind almost all of them
Read a dozen of these and the same shape appears every time. It is worth learning once,
because after that every new country takes about two minutes to understand.
1
A right, usually from the CRPD
Almost every country on this page has ratified the same treaty. That is where the
obligation comes from, and it is why the laws look so similar.
2
A national law, which is vague on purpose
It says do not discriminate, or make reasonable adjustments. It almost never
contains a measurement, because a law that named pixel values would be obsolete in
three years.
3
A pointer to a technical standard
This is where the actual requirement lives. EN 301 549, JIS X 8341-3, IS 17802,
GB/T 37668, Israeli 5568. Open any of them and you find WCAG underneath.
4
Which means the real question is the version
WCAG 2.0 AA, 2.1 AA or 2.2 AA. That is the whole difference between most of these
regimes, and building to 2.2 AA satisfies the older ones.
The one sentence that covers most of the planet. Build to
WCAG 2.2 level AA. It is newer than what almost every law on this
page currently demands, so it satisfies them, and it puts you ahead of the updates already
in progress. Then handle whatever your jurisdiction adds on top, which is usually a
published accessibility statement, a feedback route, and sometimes a report.
Country by country
United Nations
UN Convention on the Rights of Persons with Disabilities (CRPD)
Who it covers
Every country that has ratified it, which is most of them, including the Maldives.
What it points at
No technical standard of its own. It creates the obligation that the rest deliver.
Status and dates
In force since 2008. Article 9 covers accessibility, Article 21 access to information.
This is the treaty above everything else on this page. When you need to argue from principle rather than from a rulebook, quote Articles 9 and 21.
Maldives
Disability Act 8/2010
Who it covers
Public bodies and services, with duties on the state to secure access and to protect against discrimination. Its full name is the Protection of the Rights of Persons with Disabilities and Provision of Financial Assistance Act.
What it points at
No named technical standard for digital work, which is the practical gap.
Status and dates
In force. The Maldives signed the CRPD in 2007 and ratified it in 2010. The CRPD Committee reviewed the country for the first time at its 33rd session and adopted its concluding observations on 25 August 2025, published as CRPD/C/MDV/CO/1.
This is the one to read properly if you work here. There are now formal recommendations on the record, which is a far stronger thing to cite to a ministry or a board than a general argument. And because no digital standard is named locally, contracts should still specify WCAG 2.2 level AA themselves, and ISO 21542 for buildings. Write it into the scope rather than assuming it.
United States
Americans with Disabilities Act (ADA), Titles II and III
Who it covers
Title II covers state and local government. Title III covers businesses open to the public.
What it points at
The ADA itself names no web standard. The Title II rule adopts WCAG 2.1 level AA.
Status and dates
The Title II rule took effect in June 2024. In April 2026 the Department of Justice pushed the compliance dates back, so they now fall on 26 April 2027 for state and local governments serving 50,000 people or more, and 26 April 2028 for smaller ones and for special district governments. The standard itself did not change. Title III has no rule, and courts lean on WCAG regardless.
This is the most litigated accessibility law in the world. For Title III the practical standard is WCAG 2.1 AA or better, because that is what settlements keep landing on.
United States
Section 508 of the Rehabilitation Act
Who it covers
Federal agencies, and anybody selling technology to them.
What it points at
The 2017 refresh incorporates WCAG 2.0 level AA.
Status and dates
In force. A refresh to a newer WCAG version has been pushed for but is not yet in effect.
This is why a US federal buyer asks for a VPAT, meaning an accessibility conformance report. Read the remarks column rather than the headline, since "supports" with a paragraph of exceptions underneath is not the same as supports.
Canada
Accessible Canada Act (ACA)
Who it covers
Federally regulated organisations, including banking, telecoms, transport and the federal government.
What it points at
Points to EN 301 549 and WCAG through its standards work.
Status and dates
In force since 2019, with a stated goal of a barrier free Canada by 2040.
Federal only. Provincial law sits alongside it, which is why Ontario has its own act.
Canada, Ontario
Accessibility for Ontarians with Disabilities Act (AODA)
Who it covers
The public sector, and private and non-profit organisations. Two thresholds matter. From 20 employees you have to file a compliance report, and from 50 the website standard applies to you as well.
What it points at
WCAG 2.0 level AA.
Status and dates
In force. Compliance reports are filed every three years, and the next one falls due on 31 December 2026, through Ontario's online reporting portal.
Older standard, still enforced. Meeting WCAG 2.2 AA covers it comfortably, so build to the newer one and report against the older.
European Union
European Accessibility Act (EAA), Directive 2019/882
Who it covers
The private sector, for a defined list including e-commerce, banking, e-books, transport ticketing and telecoms.
What it points at
EN 301 549, whose web chapter is WCAG.
Status and dates
Applied from 28 June 2025. 2026 is the first full year of supervision. Enforcement is by each member state, so penalties differ by country.
This is the one that reaches ordinary businesses rather than only government. If you sell into the EU, it reaches you even from outside it.
European Union
Web Accessibility Directive, 2016/2102
Who it covers
Public sector websites and mobile apps.
What it points at
EN 301 549, which currently maps to WCAG 2.1 level AA.
Status and dates
In force since 2016 and transposed by every member state.
It also requires a published accessibility statement and a feedback route, which is the reason those pages exist across European government sites.
European Union
EN 301 549
Who it covers
Not a law. The harmonised standard that both EU directives point at, and the thing public bodies buy against.
What it points at
Contains WCAG for the web chapter, then adds hardware, documents, software and support services.
Status and dates
The harmonised version today is V3.2.1, which aligns with WCAG 2.1 AA. V4.1.1 brings it up to WCAG 2.2 AA and is scheduled to be cited in the Official Journal around the end of 2026, at which point it replaces V3.2.1. Dates in this process slip, so check before you price it.
If a tender says EN 301 549, meeting WCAG 2.2 AA gets you through the web part, and you still have to answer for hardware, documents and your support desk.
United Kingdom
Equality Act 2010
Who it covers
Everybody providing a service to the public, private sector included.
What it points at
Names no technical standard. It requires reasonable adjustments so disabled people are not put at a substantial disadvantage.
Status and dates
In force since 2010.
Because no standard is named, WCAG is what courts and regulators reach for in practice. The absence of a named standard is not an absence of a duty.
United Kingdom
Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018
Who it covers
UK public sector bodies.
What it points at
WCAG 2.1 level AA, plus a published accessibility statement.
Status and dates
In force. Monitored by the Government Digital Service.
The statement is not optional and its absence is itself a finding.
Germany
BFSG, plus BITV 2.0 for the public sector
Who it covers
BFSG implements the EAA for the private sector. BITV 2.0 covers federal public bodies.
What it points at
EN 301 549.
Status and dates
BFSG applicable from June 2025 alongside the rest of the EAA.
Germany enforces actively, so treat a German market entry as a real compliance project.
France
RGAA, under the law of 11 February 2005
Who it covers
Public bodies, and private companies over 250 million euro of turnover. That figure is revenue earned in France, averaged over the three most recently closed financial years, not worldwide revenue, so check which number a client is quoting you.
What it points at
RGAA, a French method built on top of WCAG. The current version is 4.1.2, which works through 106 tests.
Status and dates
In force, with a declared conformance level required on the site itself. The 2023 ordinance and decree, 2023-859 and 2023-931, raised the penalties sharply and made them renewable while you stay non-compliant. Published figures vary, so check the current one before you quote it to a client.
France expects a declared conformance percentage and a multi-year plan published openly, which is stricter reporting than most.
Norway
Regulations on universal design of ICT
Who it covers
Both public and private sector, which made Norway unusual for years.
What it points at
WCAG, adopted into the regulation. The public sector moved to WCAG 2.1 level AA, through EN 301 549, and has to publish an accessibility statement.
Status and dates
The ICT regulation took effect on 1 July 2013. Norway then took on the EU Web Accessibility Directive through the EEA agreement, and those public sector requirements applied from 1 February 2023. The regulator, Uutilsynet, audits sites and can impose coercive fines.
Worth knowing as the early example that private sector coverage is workable rather than theoretical, and as one of the strictest regimes anywhere.
Ireland
Disability Act 2005, plus the EAA transposition
Who it covers
Public bodies under the 2005 act, private sector under the EAA.
What it points at
EN 301 549.
Status and dates
In force.
Ireland's public procurement rules reference the standard directly, so it turns up in tenders.
Australia
Disability Discrimination Act 1992 (DDA)
Who it covers
Anybody providing goods, services or facilities to the public.
What it points at
Names no standard. The Human Rights Commission formalised WCAG 2.2 level AA as the minimum in April 2025, and said the duty reaches apps, SaaS and AI tools too, not just websites.
Status and dates
In force since 1992. The government Digital Experience Policy took effect on 1 January 2025 for new services and July 2025 for existing ones.
Same shape as the UK. A broad duty with no named standard, and WCAG is what everybody actually uses.
New Zealand
Human Rights Act 1993, plus government web standards
Who it covers
Public sector under the web standards. Broader duty under the Human Rights Act.
What it points at
The New Zealand Government Web Accessibility Standard. Version 1.2 replaced 1.1 on 17 March 2025 and moved the target to WCAG 2.2 level AA.
Status and dates
In force. The standard has been mandatory for public service and non-public service agencies since 1 July 2019.
Mandatory for public service agencies rather than for private business. Worth noting as one of the few national standards already pointing at WCAG 2.2 rather than 2.1, which is another reason to build to 2.2 and report against whatever the contract names.
Japan
Act on the Elimination of Discrimination against Persons with Disabilities
Who it covers
Public bodies, and since 2024 the private sector too.
What it points at
JIS X 8341-3, the Japanese standard aligned with WCAG.
Status and dates
The April 2024 revision made reasonable accommodation mandatory for private businesses rather than merely encouraged.
That 2024 change is the significant one. Private sector duties in Japan are no longer voluntary.
India
Rights of Persons with Disabilities Act 2016 (RPwD)
Who it covers
Government and, increasingly, regulated private sectors.
What it points at
IS 17802, the Indian ICT accessibility standard, which is built on WCAG, alongside GIGW for government sites.
Status and dates
In force since 2016. In April 2025 the Supreme Court held that digital access is part of the right to life under Article 21. The securities regulator, SEBI, then made it concrete for finance in a July 2025 circular, requiring third party accessibility audits by 30 April 2026 and remediation by 31 July 2026.
India is the clearest example of a country moving from principle to dated, enforceable obligations sector by sector. Finance went first. Watch whichever regulator governs your client.
South Korea
Act on Welfare of Persons with Disabilities, and anti-discrimination law
Who it covers
Public bodies and a wide range of private services.
What it points at
The Korean Web Content Accessibility Guidelines. KWCAG 2.1, published in 2019, aligns with WCAG 2.1 and adds mobile and Korean language criteria of its own.
Status and dates
In force, with certification marks in common use.
Korea enforces through certification, which is a different mechanism from the audit and complaint model used in most of Europe.
China
Barrier-Free Environment Construction Law, plus GB/T 37668
Who it covers
Government sites, and large platforms under sector guidance.
What it points at
GB/T 37668, the national ICT accessibility standard.
Status and dates
The Barrier-Free Environment Construction Law took effect on 1 September 2023, the first law China has written specifically for this. It covers accessible information exchange and social services alongside the built environment, and it carries chapters on supervision and on liability. GB/T 37668 was published in 2019, and a ministry programme has been working through the major apps and sites.
Until 2023 this ran almost entirely through the ministry programme rather than the courts. The new law puts a statutory duty and a liability chapter behind it, so treat older guidance that calls China guidance-only as out of date.
Israel
Equal Rights for Persons with Disabilities Law, standard 5568
Who it covers
Public bodies and most businesses above a size threshold.
What it points at
Israeli standard 5568. The current revision is IS 5568:2020, which aligns with WCAG 2.1 level AA. You will still see the older WCAG 2.0 baseline quoted, so check which revision a contract actually names.
Status and dates
In force, with an accessibility statement expected on the site. Fines run to around NIS 50,000.
One of the earlier countries to apply digital accessibility broadly to private business.
Brazil
Brazilian Inclusion Law (LBI), Law 13.146/2015
Who it covers
Public and private, for websites and digital services.
What it points at
ABNT NBR 17060:2022, the national standard, which sets 54 WCAG based requirements for web pages and mobile apps and backs article 63 of the law. eMAG remains the government model.
Status and dates
In force since 2016, with the standard published in October 2022. Putting a mobile product on the market that does not meet NBR 17060 is an administrative infraction, so there are fines and suspension behind it rather than guidance alone.
The largest accessibility law in Latin America by reach.
Nothing matches that. Try a shorter word, or
.
If your country has no digital accessibility law
Plenty do not, and the Maldives is among them for digital work specifically. That is not
the end of the conversation, it just changes which argument you lead with.
The CRPD still applies if your country ratified it, and most have.
Articles 9 and 21 are the ones to quote.
Write the standard into the contract yourself. If no law names one,
your scope of work can. "WCAG 2.2 level AA" in the deliverables section is enforceable
between you and your client even where no statute mentions it.
Your clients' other markets have laws. A resort selling to European
guests is inside the EAA's reach. An exporter selling into the EU is too. The absence
of a local law does not make you unreachable.
Buildings usually are covered even where digital is not, through
building codes and the local disability act. Do not assume the whole area is empty
because the web part is.
Reading a tender without panic
When a document says something like "must conform to EN 301 549 and WCAG 2.1 AA", here is
what to actually check before you price it.
What to check in an accessibility clause in a tender, and why each one matters.
Check
Why it changes the price
Which WCAG version and level
2.2 adds six criteria at A and AA and removes one, so 2.2 AA is 55 criteria against 50 for 2.1 AA. AAA is a different project entirely, and is usually asked for by mistake.
EN 301 549, or WCAG alone
EN 301 549 adds hardware, documents, software and support services. If you are only quoting for the website, say so explicitly.
Documents in scope
Every PDF you inherit is a separate piece of work, and PDF/UA is its own standard. Ask how many there are.
Who signs it off
A third party audit is a real line item. A self assessment is not the same thing and should not be priced as one.
Whether a statement is required
Most European regimes want a published accessibility statement and a feedback route. Small, and easy to forget until the end.
Legacy content
Older archived material is often exempt. If it is not exempt in this contract, it may be the largest part of the job.
