Have you wondered what accessibility legislation applies to your business if you operate in the EU? Or in Canada? The U.S.? I've put together an analysis looking at accessibility legislation currently in effect around the world, focusing on major countries in Europe, North America, Asia and other significant jurisdictions.
It feels like I should say this: I am definitely NOT a lawyer.
United States
The ADA represents one of the most comprehensive disability rights laws globally. While originally focused on physical accessibility, federal courts have consistently ruled that digital platforms constitute places of public accommodation.
Date of enactment: Jul 26th, 1990
Who it affects: Public accommodations, Title II entities (state/local gov), employers
United States
Section 508 mandates that federal agencies make their electronic and information technology accessible to people with disabilities. The law aligns with WCAG 2.0 standards and requires compliance from all federal contractors. Non-compliance can result in contract termination and exclusion from future federal procurement opportunities.
Date of enactment: Aug 7th, 1998
Who it affects: Federal agencies and contractors
United Kingdom
The UK's approach emphasizes the concept of "reasonable adjustments" rather than specific technical standards. Organisations must proactively remove barriers for disabled people, with WCAG 2.2 Level AA serving as the recommended benchmark. The Equality and Human Rights Commission has broad enforcement powers, including investigations, unlawful act notices and court action.
Date of enactment: Oct 1st, 2010
Who it affects: Public sector, private businesses serving public
Germany
Germany's implementation of the EAA through the BFSG creates one of the most robust enforcement frameworks in Europe. The law establishes a centralised market surveillance body based in Magdeburg to ensure consistent enforcement across all German states. Companies face administrative fines and potential cease-and-desist actions from consumer protection associations.
Date of enactment: Jun 28th, 2025
Who it affects: Private companies selling products/services in Germany
France
France operates a dual enforcement system combining existing national law with new EAA requirements. The Montchamp Law already imposed substantial penalties on large private companies, while new EAA provisions classify violations as Class 5 offenses with escalating penalties. France also has the RGAA (Référentiel Général d'Amélioration de l'Accessibilité), the French technical standard for digital accessibility. It's been updated several times, with RGAA 4 being the current version.
Date of enactment: Feb 11th, 2005
Who it affects: Public bodies, private companies with €250M+ turnover
Italy
Italy's Stanca Act was pioneering in extending accessibility requirements to certain private sector companies. The law has been continuously updated to align with EU directives and enforcement by the Agency for Digital Italy (AgID) has become increasingly active.
Date of enactment: Jan 9th, 2004
Who it affects: Public sector, private companies with €500M+ turnover
Spain
Spanish implementation of the European Accessibility Act with tiered penalty system. It includes provisions for business suspension and operational bans for serious violations.
Date of enactment: May 8th, 2023
Who it affects: Private companies providing digital products/services
Canada (Federal)
Federal accessibility legislation creating proactive obligations for federally regulated organisations. The legislation is enforced through the Accessibility Commissioner with graduated penalties.
Date of enactment: Jul 11th, 2019
Who it affects: Federal agencies and federally regulated organisations
Canada (Ontario)
AODA represents one of the most stringent accessibility enforcement regimes globally, with daily accumulating fines that can quickly reach substantial amounts. The law requires WCAG 2.0 Level AA compliance for all public-facing websites and mandates regular compliance reporting.
Date of enactment: Jun 13th, 2005
Who it affects: Public and private organisations with 50+ employees in Ontario
European Union
The EAA is a major moment in global accessibility legislation, extending digital accessibility requirements to private sector businesses across the European Union. The law requires compliance with WCAG 2.1 Level AA standards and covers e-commerce platforms, banking services, transportation services, telecommunications and digital media.
Date of enactment: Jun 28th, 2025
Who it affects: Private companies providing products/services in EU (except micro-enterprises)
European Union
It's an European harmonised standard specifying accessibility requirements for ICT products and services. EN 301 549 provides technical specifications and presumption of conformity for EU accessibility directives. Current version (V3.2.1, March 2021) incorporates WCAG 2.1 Level AA in full. Next version (V4.1.1) planned for 2026 to include WCAG 2.2.
Date of enactment: Mar 1st, 2021
Who it affects: Public sector bodies (via Web Accessibility Directive) and private sector (via European Accessibility Act)
European Union
This EU directives requires public sector websites and mobile applications to be perceivable, operable, understandable and robust. Member states transposed it into national law by September 2018. It requires accessibility statements and monitoring reports every three years.
Date of enactment: Oct 26th, 2016
Who it affects: Public sector bodies including state, regional and local authorities, bodies governed by public law (excludes broadcasters and certain NGOs)
Japan
Japan's accessibility standards are closely aligned with WCAG 2.0 Level AA requirements. While enforcement mechanisms are relatively limited compared to other jurisdictions, the law provides legal protection against discrimination and supports reasonable accommodation requirements.
Date of enactment: Jun 20th, 2004
Who it affects: Government agencies, encouraged for private sector
Australia
Australia's DDA has been increasingly applied to digital accessibility through Australian Human Rights Commission interpretations. The law requires WCAG 2.1 Level AA compliance and emphasises complaint-based enforcement through conciliation and Federal Court proceedings.
Date of enactment: Dec 1st, 1992
Who it affects: Public and private organisations serving the public
China
China's new Barrier-Free Environment Creation Law represents a significant advancement in the country's accessibility framework. The law emphasises accessible information exchanges and social services, with enhanced provisions for digital accessibility and clearer legal responsibilities.
Date of enactment: Sep 1st, 2023
Who it affects: Government agencies, public institutions, encouraged for private sector
South Korea
South Korea's framework combines anti-discrimination legislation with technical standards through the Korean Web Content Accessibility Guidelines (KWCAG). The law requires reasonable accommodation in digital spaces and has enforcement through the National Human Rights Commission of Korea.
Date of enactment: Apr 11th, 2008
Who it affects: Public institutions, large corporations, private sector encouraged
India
India's RPWD Act has seen significantly increased enforcement activity, with the Chief Commissioner for Persons with Disabilities taking action against major companies including Reliance Jio, Airtel and Zerodha for accessibility violations. The law requires compliance with WCAG 2.1 Level AA standards.
Date of enactment: Apr 19th, 2017
Who it affects: Public and private organisations providing services
Brazil
Brazil's LBI creates comprehensive accessibility requirements across digital platforms, requiring WCAG 2.0 Level AA compliance. The law has been increasingly enforced in sectors including finance, health and education, with several organisations facing court action for non-compliance.
Date of enactment: Jan 2nd, 2016
Who it affects: Public and private entities providing services to public
Countries worldwide are moving from voluntary guidelines to mandatory requirements with substantial penalties. WCAG 2.1 Level AA is, at least so far, the de facto standard for accessibility.
Lately, legislation has been expanding from purely public sector requirements to comprehensive private sector coverage, with particular focus on e-commerce, banking and essential services.