International Web Accessibility Laws and Policies

The global framework: UN Convention on the Rights of Persons with Disabilities

The foundational international instrument for disability rights is the United Nations Convention on the Rights of Persons with Disabilities (CRPD), adopted by the UN General Assembly on December 13, 2006, and entered into force on May 3, 2008. As of 2026, 191 states are parties. Article 9 of the CRPD specifically addresses accessibility, including information and communications technology, and Article 21 covers freedom of expression and access to information. The CRPD doesn’t directly create enforceable web accessibility requirements at the national level, but it provides the international legal foundation on which many national accessibility statutes are built, and it creates review obligations through the UN Committee on the Rights of Persons with Disabilities.

The Marrakesh Treaty (2013, entered into force 2016) complements the CRPD specifically for accessible published works for people with visual or print disabilities — an important piece for digital publishers and e-book platforms.

Web accessibility policy design

Before surveying national laws, it’s worth outlining what a good organizational accessibility policy actually looks like. Whether your organization is required to comply with a specific statute or voluntarily adopting accessibility standards, the policy components are broadly consistent: a reference standard, a stated level of conformance, defined scope, realistic milestones, handling of third-party content, monitoring procedures, maintenance practices, and a long-term strategy.

A reference standard

The policy should declare which external accessibility standard it adopts. In practice, this almost always means the Web Content Accessibility Guidelines (WCAG) from the W3C — currently at version 2.2 (published October 5, 2023). Most national laws and procurement standards reference WCAG; some adopt it directly (via EN 301 549 in Europe, Section 508 in the US), and others reference it by name.

Conformance level

WCAG specifies three levels — A (minimum), AA (standard target, required by virtually every legal framework), and AAA (enhanced, often aspirational). Most organizations adopt Level AA as their conformance target because that’s what the major laws require. The policy should state the target level explicitly.

Scope

Define which digital properties are covered — public-facing website, internal intranet, mobile apps, third-party hosted services, documents (PDFs, Office files), video and audio content, and so on. Scope decisions materially affect cost and feasibility; the policy should be specific rather than aspirational.

Milestones

Full compliance with WCAG 2.2 AA for a large existing site typically takes 12–24 months of sustained effort. Set phased milestones: audit baseline, prioritize high-traffic pages, remediate critical barriers first, expand coverage systematically. Tie milestones to delivery dates, not open-ended intentions.

Third-party content

Content from vendors, embeds, widgets, social media, and user-generated submissions often fails accessibility requirements. Policy must address:

• Procurement criteria requiring accessibility conformance from vendors
• Review procedures for user-generated content
• Responsibility for embedded third-party widgets (analytics, chat, payment)
• Contractual remedies when vendors fail to meet requirements

Monitoring and review

Accessibility drifts without ongoing monitoring. Policy should specify:

• Automated accessibility scans (axe, WAVE, Lighthouse, Pa11y) on a defined cadence
• Manual audits of critical paths (at least annually)
• Screen reader user testing
• Complaints and feedback processes for users reporting accessibility barriers
• Periodic review of the policy itself as standards and laws evolve

Maintenance

New content, features, and third-party integrations must meet accessibility requirements before they ship. Embed accessibility into your development and content workflows — not as a final gate, but as an ongoing practice with checklists, design reviews, and CI/CD integration.

Long-term strategy

Accessibility isn’t a project; it’s a practice. Long-term, the policy should cover training for staff and contractors, hiring or contracting accessibility specialists, certifications (IAAP’s CPACC, WAS, CPWA, ADS — see our certification guide), regulatory monitoring, and participation in the broader accessibility community.

Australia

Disability Discrimination Act 1992 (DDA)

Australia’s Disability Discrimination Act 1992 prohibits discrimination against people with disabilities in employment, education, accommodation, and access to premises, goods, and services — including online services. The Australian Human Rights Commission has published World Wide Web Access Advisory Notes confirming that websites fall within the DDA’s coverage, and several cases (most famously Maguire v. Sydney Organising Committee for the Olympic Games, 2000) have established that inaccessible websites can constitute unlawful discrimination.

Accessibility ICT Procurement Standard (AS EN 301 549)

In 2016, Australia adopted AS EN 301 549, a technical standard that mirrors the European EN 301 549 standard for ICT procurement. The standard references WCAG 2.0 (current versions reference 2.1); it applies to Australian government ICT procurement and is widely referenced in state and private-sector accessibility policies.

Australian state and territory laws

Each state has anti-discrimination legislation that complements the federal DDA. Commonwealth, state, and territory government websites are generally expected to conform to WCAG 2.1 AA under the Australian Government Digital Service Standard.

Brazil

Lei Brasileira de Inclusão (LBI) 2015

Brazil’s Lei Brasileira de Inclusão da Pessoa com Deficiência (Law 13.146/2015), also known as the Estatuto da Pessoa com Deficiência, established comprehensive disability rights. Article 63 specifically requires government and public-interest websites to be accessible, with reference to international standards including WCAG. The eMAG (Modelo de Acessibilidade em Governo Eletrônico) provides Brazil-specific technical guidance for government websites, mapped against WCAG 2.1 AA. Enforcement is via the Public Ministry and state-level consumer protection agencies; damages and fines have been awarded in accessibility cases.

Canada

Canadian Human Rights Act

The Canadian Human Rights Act (1977, amended multiple times) prohibits discrimination on the basis of disability in services provided by federally-regulated entities — including their websites. Complaints are handled by the Canadian Human Rights Commission.

Accessible Canada Act (ACA) of 2019

The Accessible Canada Act (S.C. 2019, c. 10) received Royal Assent on June 21, 2019 and came into force on July 11, 2019. The ACA’s stated goal is a barrier-free Canada by January 1, 2040. It applies to federally regulated entities including the Government of Canada, Crown corporations, and private-sector organizations in banking, telecommunications, interprovincial transportation, broadcasting, and postal services.

The Accessible Canada Regulations (SOR/2021-241), issued December 2021, established compliance deadlines:

• Government of Canada, Crown corporations, and the Canadian Armed Forces: December 31, 2022 (initial accessibility plans) with ongoing progress reports
• Large federally-regulated private-sector entities (100+ employees): June 1, 2023 (initial plans)
• Smaller entities (10–99 employees): June 1, 2024
• Web pages, mobile apps, and public documents: compliance deadlines of December 5, 2027 or December 5, 2028, depending on the type of organization and content

The technical standard is CAN/ASC-EN 301 549, Canada’s national adoption of EN 301 549, which incorporates WCAG 2.1 AA. Penalties for non-compliance can reach $250,000 per violation. Enforcement is handled by the Accessibility Commissioner (part of the Canadian Human Rights Commission).

Provincial accessibility laws

Several Canadian provinces have their own accessibility laws that apply to provincially-regulated entities:

• Ontario — Accessibility for Ontarians with Disabilities Act (AODA), 2005. Website requirements include WCAG 2.0 AA for large organizations and Ontario government sites; compliance phased in through January 1, 2021.
• Manitoba — Accessibility for Manitobans Act, 2013.
• Nova Scotia — Accessibility Act, 2017.
• British Columbia — Accessible British Columbia Act, 2021.
• Quebec — An Act to Secure Handicapped Persons in the Exercise of their Rights with a View to Achieving Social, School and Workplace Integration; SGQRI 008 standards for provincial government sites.

China

Law on the Protection of Persons with Disabilities (1990, amended)

China’s Law on the Protection of Persons with Disabilities (1990, significantly amended 2008 and 2018) establishes broad principles of non-discrimination and accessibility. The 2018 amendment specifically addressed barrier-free environment construction including information accessibility.

Information Accessibility Standards

China’s voluntary accessibility standards include GB/T 37668-2019 (Web Content Accessibility) and related national standards, which reference WCAG 2.0/2.1. Government websites are required to meet accessibility requirements under the 2020 implementation plan; private-sector compliance is largely voluntary but has been strengthening.

Denmark

Open Standards Agreement and EU Directive transposition

Denmark has implemented EU accessibility directives into national law. The Lov om tilgængelighed af offentlige organers websteder og mobilapplikationer (Act on the Accessibility of Public Bodies’ Websites and Mobile Applications, 2018) transposes the EU Web Accessibility Directive (2016/2102) and requires public-sector websites and apps to meet WCAG 2.1 AA. The EU Accessibility Act (EAA) applies from June 28, 2025 to covered private-sector services.

European Union

Web and Mobile Accessibility Directive (2016/2102)

EU Directive 2016/2102 on the accessibility of websites and mobile applications of public sector bodies was adopted October 26, 2016, and came into force December 22, 2016. Member states had until September 23, 2018 to transpose it into national law. Compliance deadlines:

• New public-sector websites (published after September 23, 2018): compliance by September 23, 2019
• Existing public-sector websites: compliance by September 23, 2020
• Mobile applications: compliance by June 23, 2021

The Directive references the harmonized European standard EN 301 549, which itself incorporates WCAG 2.1 AA. Each member state has a designated monitoring body that conducts periodic audits of public-sector accessibility and handles complaints.

European Accessibility Act (EAA) — Directive 2019/882

The European Accessibility Act, formally Directive (EU) 2019/882, adopted April 17, 2019, extends EU accessibility requirements to the private sector. Member states had until June 28, 2022 to transpose the Directive into national law. Enforcement applies from June 28, 2025, with transition periods continuing to 2030 for some categories.

EAA covers a broad range of private-sector products and services:

• Computers and operating systems, smartphones, smart TVs, self-service terminals (ATMs, ticket machines)
• E-commerce services
• E-books and dedicated software
• Banking services
• Electronic communications services
• Audiovisual media services access
• Elements of passenger transport (air, bus, rail, waterborne) services

The technical standard is EN 301 549 (currently v3.2.1, referencing WCAG 2.1; a future revision is expected to reference WCAG 2.2). Penalties vary by member state but reach into millions of euros for severe violations. EAA is the most consequential accessibility legislation in the world in 2026 given its scope and the scale of EU commerce.

EN 301 549 — the harmonized standard

EN 301 549 is the European harmonized standard for ICT accessibility, developed by ETSI, CEN, and CENELEC. Current version 3.2.1 (published 2021) references WCAG 2.1 AA. EN 301 549 is the technical reference for both the Web Accessibility Directive and the EAA, and is adopted or mirrored by many non-EU countries (Canada’s CAN/ASC-EN 301 549, Australia’s AS EN 301 549).

Finland

Act on the Provision of Digital Services

Finland’s Act on the Provision of Digital Services (306/2019) transposed the EU Web Accessibility Directive. The Act requires public-sector and certain private-sector digital services to conform to WCAG 2.1 AA. Finland was one of the first member states to transpose the Directive and is generally considered to have a mature enforcement regime. The EAA transposition expanded the private-sector scope as of June 28, 2025.

France

Law No 2005-102 Article 47 and RGAA

French Law No 2005-102 (February 11, 2005), Article 47, established accessibility obligations for public-sector online services. Article 47 was strengthened by Law No 2016-1321 (October 7, 2016, the Digital Republic Act) to extend coverage and include penalty provisions.

The technical reference is the Référentiel Général d’Amélioration de l’Accessibilité (RGAA), currently at version 4.1. RGAA is a French interpretation of WCAG 2.1 AA with additional testing methodology. It applies to the State, local authorities, public establishments, and some private entities over €250 million in turnover.

Order of 29 April 2015 on the general accessibility framework

The Order of 29 April 2015 established the detailed accessibility framework for public administrations, later updated by subsequent decrees. France’s implementation of the EAA (Law No 2023-171, March 9, 2023) expanded private-sector coverage in line with EAA requirements, effective June 28, 2025.

Germany

Act on Equal Opportunities for Disabled Persons (BGG, 2002)

Germany’s Behindertengleichstellungsgesetz (BGG) of 2002 establishes broad anti-discrimination obligations for federal public bodies. The BGG was last significantly amended in 2016 to align with the EU Directive.

Federal Ordinance on Barrier-Free Information Technology (BITV 2.0)

The Barrierefreie Informationstechnik-Verordnung (BITV) 2.0 specifies technical accessibility requirements for federal websites and digital services. BITV 2.0 was most recently updated in 2019 to reference EN 301 549 and WCAG 2.1. It applies to federal government entities and is widely used as a reference by German state (Länder) governments.

Accessibility Strengthening Act (BFSG) 2021

Germany’s Barrierefreiheitsstärkungsgesetz (BFSG) — the Accessibility Strengthening Act — was adopted by the Bundestag on July 22, 2021, and has been fully applicable since June 28, 2025. BFSG is Germany’s national implementation of the EU Accessibility Act (Directive 2019/882) and extends accessibility requirements to most private-sector businesses selling products and services to consumers.

BFSG covers:

• E-commerce websites and apps
• E-books and e-readers
• Banking services (online and in-branch terminals)
• Telephony and electronic communications services
• Transport information and ticketing (air, rail, bus, boat)
• Self-service terminals (ATMs, ticket machines, check-in kiosks)
• Consumer computers and smartphones

Technical requirements are based on EN 301 549 and WCAG 2.2 Level AA. Transition periods apply: services using products already in use before June 28, 2025 may continue to operate until June 27, 2030; self-service terminals may remain in use through their economic lifespan (no later than 2040). Fines range from €10,000 to €100,000 per violation. Market surveillance is handled by federal state authorities.

Hong Kong

Guidelines on Dissemination of Information through Government Websites

Hong Kong’s Office of the Government Chief Information Officer (OGCIO) has published accessibility guidelines requiring government websites to conform to WCAG 2.1 AA. Private-sector compliance is voluntary but encouraged under the broader Disability Discrimination Ordinance (1995), which prohibits discrimination in service provision.

India

Rights of Persons with Disabilities Act 2016 (RPwD)

The Rights of Persons with Disabilities Act, 2016 replaced the 1995 Persons with Disabilities Act and significantly expanded disability rights in India. Section 40 requires appropriate governments to take measures to ensure accessibility of information and communications technology. The Guidelines for Indian Government Websites (GIGW) require Indian government sites to conform to GIGW 3.0 (2023), which references WCAG 2.1 AA.

Enforcement has historically been limited, but the 2016 Act created a framework for Chief Commissioners for Persons with Disabilities at both state and central levels, with some authority to investigate and recommend remediation.

Ireland

Disability Act 2005 and European Union (Accessibility of Websites and Mobile Applications of Public Sector Bodies) Regulations 2020

Ireland’s Disability Act 2005 established broad accessibility principles for public bodies. The European Union (Accessibility of Websites and Mobile Applications of Public Sector Bodies) Regulations 2020 transposed the EU Web Accessibility Directive, requiring WCAG 2.1 AA conformance for public-sector websites and apps. Ireland’s EAA implementation (Statutory Instrument No. 636 of 2022) applies from June 28, 2025 to covered private-sector services.

Israel

Equal Rights of Persons with Disabilities Act

Israel’s Equal Rights of Persons with Disabilities Act, 1998 (amended multiple times, most recently 2018) prohibits disability-based discrimination. Israel’s implementing standard is IS 5568, a national accessibility standard based on WCAG 2.0 AA, with Israeli-specific adaptations. Compliance became mandatory for commercial websites in October 2017 under Accessibility Regulations implementing the Equal Rights Act.

Israel has been notably active in accessibility enforcement — among the first jurisdictions to require broad private-sector website accessibility, with specific requirements for screen reader compatibility, keyboard navigation, and accessible forms.

Italy

Stanca Law (Law No. 4/2004) and EU Directive transposition

Italy’s Law 9 January 2004, n. 4 (“Stanca Law”) was one of Europe’s earliest accessibility laws, requiring public-sector websites to meet accessibility requirements. The Stanca Law was updated by Legislative Decree 106/2018 to transpose the EU Web Accessibility Directive. AgID (Agenzia per l’Italia Digitale) manages national accessibility standards, which align with WCAG 2.1 AA and EN 301 549. Italy’s EAA implementation (Legislative Decree 82/2022) extends requirements to private-sector services as of June 28, 2025.

Japan

Basic Act on the Formation of an Advanced Information and Telecommunications Network Society

Japan’s JIS X 8341-3:2016 is the Japanese Industrial Standard for web accessibility, aligned with WCAG 2.0 (and since 2024, updated to align with WCAG 2.1). Japanese government websites are required to conform under administrative guidelines. The Act for Eliminating Discrimination against Persons with Disabilities (enacted 2013, effective April 2016, amended 2021) provides the broader anti-discrimination framework; the 2021 amendment extended reasonable accommodation requirements to private-sector businesses effective April 2024.

Netherlands

Dutch accessibility law and EU Directive implementation

The Netherlands has implemented the EU Web Accessibility Directive through the Tijdelijk besluit digitale toegankelijkheid overheid (Temporary Decree on Digital Accessibility of the Government, 2018), requiring Dutch public-sector websites and apps to meet WCAG 2.1 AA. The Dutch government maintains a public register of accessibility statements from covered bodies. The EAA transposition (Implementation Act of 2022) extends requirements to private-sector services from June 28, 2025.

New Zealand

Human Rights Act 1993 and Digital Service Design Standard

New Zealand’s Human Rights Act 1993 prohibits disability-based discrimination in service provision. The Web Accessibility Standard (issued by the Department of Internal Affairs) requires New Zealand government websites to conform to WCAG 2.1 AA. The standard is regularly updated and monitored through the Government Chief Digital Officer.

Norway

Regulations on Universal Design of ICT Solutions

Norway’s Forskrift om universell utforming av informasjons- og kommunikasjonsteknologiske (IKT)-løsninger (Regulation on Universal Design of ICT Solutions, 2013) applies to both public and private sectors — making Norway one of the few countries to require broad private-sector website accessibility long before the EU EAA. The regulation requires WCAG 2.1 AA conformance. Norway is not an EU member state but participates in the EEA and has implemented directly-parallel requirements. The Norwegian Digitisation Agency (Digdir) enforces compliance through Uu-tilsynet (the Authority for Universal Design of ICT).

Republic of Korea

Act on the Prohibition of Discrimination and Remedies Against Persons with Disabilities

South Korea’s Act on the Prohibition of Discrimination and Remedies Against Persons with Disabilities (2007, amended multiple times) requires accessible information and communication services. The Korean Web Content Accessibility Guidelines (KWCAG 2.2, released 2022) references WCAG and is mandatory for government websites. Compliance is also increasingly required for large private-sector services. The Korea Communications Commission and the National Information Society Agency (NIA) oversee enforcement.

Singapore

Disability Compliance and Infocomm Media Development Authority guidelines

Singapore’s Code on Accessibility in the Built Environment and Enabling Masterplan (currently in its fourth iteration, 2022–2030) set broad accessibility goals. The Infocomm Media Development Authority (IMDA) has published accessibility guidelines for government websites based on WCAG 2.1 AA. The Singapore Disabilities Act provides a foundational anti-discrimination framework; private-sector web accessibility compliance is encouraged but not yet broadly mandated.

South Africa

PEPUDA and SANS 266:2014

South Africa’s Promotion of Equality and Prevention of Unfair Discrimination Act (PEPUDA), 2000 prohibits unfair discrimination including on the basis of disability. The SANS 266:2014 standard (Part 4: Accessibility of websites for persons with disabilities) references WCAG and sets South African technical requirements for public-sector website accessibility. Government websites are required to conform; private-sector compliance is strongly encouraged, particularly for government suppliers.

Sweden

Discrimination Act (2008:567) and Digital Accessibility Act

Sweden’s Discrimination Act (2008:567) prohibits disability-based discrimination and requires reasonable accommodation. The Act on Accessibility to Digital Public Services (2018:1937) transposed the EU Web Accessibility Directive, requiring public-sector WCAG 2.1 AA conformance. Sweden’s EAA implementation extends coverage to private-sector services as of June 28, 2025.

Switzerland

Federal Act on the Elimination of Inequalities for Persons with Disabilities

Switzerland’s Bundesgesetz über die Beseitigung von Benachteiligungen von Menschen mit Behinderungen (BehiG) of 2002 (amended 2022) requires federal administration websites to be accessible. The Accessibility Standard eCH-0059 references WCAG 2.1 AA. Switzerland is not an EU member but often tracks EU requirements voluntarily.

Taiwan

Web Accessibility Guidelines 2.0

Taiwan’s Web Accessibility Guidelines (most recent: WCAG 2.1 alignment through Accessible Web Guidelines 2.0, 2018) are mandatory for government websites, enforced by the National Development Council. Private-sector compliance is voluntary but increasingly expected, particularly for businesses interacting with government.

United Kingdom

Equality Act 2010

The UK Equality Act 2010 consolidated previous anti-discrimination laws, prohibiting discrimination on the basis of disability in services provided to the public. UK courts have repeatedly confirmed that the Equality Act applies to websites; businesses must make “reasonable adjustments” to ensure accessibility.

Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018

The PSBAR 2018 transposed the EU Web Accessibility Directive (2016/2102) into UK law. Despite Brexit, the regulations remain in force and require UK public-sector websites and mobile apps to conform to WCAG 2.1 AA. Compliance deadlines mirrored the EU Directive:

• New public-sector websites (published after September 23, 2018): compliance by September 23, 2019
• Existing public-sector websites: compliance by September 23, 2020
• Mobile applications: compliance by June 23, 2021

Enforcement is via the Cabinet Office’s Government Digital Service (GDS), with monitoring and complaints handled by the Equality and Human Rights Commission. Non-compliance can result in enforcement action under the Equality Act 2010.

Private-sector UK businesses are not subject to PSBAR, but the Equality Act 2010 continues to apply — and UK businesses serving EU consumers may also be subject to EAA requirements despite the UK’s departure from the EU.

United States

Americans with Disabilities Act of 1990 (ADA), as amended

Signed into law July 26, 1990, amended by the ADA Amendments Act of 2008. The ADA prohibits disability discrimination across employment, state and local government services, public accommodations, transportation, and telecommunications. Titles II (state/local government) and III (public accommodations) are most commonly invoked in web accessibility cases. Courts have increasingly ruled ADA Title III applies to business websites; Domino’s v. Robles (Supreme Court declined certiorari 2019) is a leading precedent.

DOJ April 2024 Title II Final Rule

The most significant US regulatory development in over a decade. On April 24, 2024, the US Department of Justice published a Final Rule under ADA Title II requiring state and local government websites and mobile apps to conform to WCAG 2.1 Level AA. Compliance deadlines:

• Entities serving populations of 50,000 or more: April 26, 2027 (extended from April 24, 2026 by the DOJ’s Interim Final Rule of April 20, 2026)
• Entities serving populations under 50,000, and all special district governments: April 26, 2028 (extended from April 26, 2027 by the same IFR)

The rule covers websites, mobile apps, digital documents, online course content, and most content state and local governments produce or control. Limited exceptions apply to archived materials, pre-existing social media posts, password-protected course content (outside K-12), and certain classes of third-party content.

Section 508 of the Rehabilitation Act of 1973, as amended

Section 508 requires US federal agencies to ensure that electronic and information technology they develop, procure, maintain, or use is accessible to people with disabilities. The Section 508 Refresh published by the US Access Board on January 18, 2017 (compliance required January 18, 2018) incorporates WCAG 2.0 Level AA by reference. Federal agency sites conforming to WCAG 2.0 AA automatically satisfy Section 508’s web content requirements.

Section 504 of the Rehabilitation Act of 1973

Prohibits discrimination against people with disabilities by employers and organizations receiving federal financial assistance — including universities, K-12 schools, federally-funded programs, and government agencies. Section 504 overlaps with ADA Title II in many cases; covered entities must comply with the stricter of the two.

Section 255 of the Telecommunications Act of 1996

Requires telecommunications equipment and services to be accessible to and usable by people with disabilities “if readily achievable.” Updated by the 2017 Section 508/255 refresh to reference EN 301 549 and WCAG 2.0 AA.

21st Century Communications and Video Accessibility Act (CVAA) of 2010

Signed October 8, 2010. Requires accessibility of advanced communications services (email, text, video conferencing), closed captioning of internet-distributed video programming (when previously captioned on TV), and accessible video programming devices. Enforced by the FCC.

State-level accessibility laws

Several US states have their own accessibility statutes. California’s Unruh Civil Rights Act allows ADA Title III claims to be pursued as state civil rights claims with statutory damages ($4,000+ per violation); California Government Code §11546.7 (AB 434) requires state agency websites to conform to WCAG 2.0 AA. New York, Colorado (HB21-1110, 2021), and several other states have accessibility statutes with varying scope.

See our United States Web Accessibility Laws guide for deeper coverage of US federal and state frameworks.

Frequently asked questions

What’s the single most important international accessibility law change since 2019?

The European Accessibility Act (EAA) — Directive (EU) 2019/882 — with enforcement beginning June 28, 2025. The EAA extends EU accessibility requirements to the private sector and covers major categories of consumer products and services. Combined with similar national implementations (Germany’s BFSG, France’s digital accessibility law, and parallel laws across all 27 EU member states), the EAA has effectively established WCAG 2.1/2.2 AA as a de facto global standard for any business selling to EU consumers.

Does my US-based business need to worry about the EAA?

Yes, if you sell products or services to EU consumers. The EAA applies to any business placing covered products on the EU market or offering covered services to EU consumers, regardless of where the business is incorporated. E-commerce websites, banking apps, and electronic communications services are all in scope if they serve EU customers. Penalties are enforced through each member state’s national authority.

What’s the relationship between WCAG and EN 301 549?

WCAG (published by W3C) is the international voluntary standard for web content accessibility. EN 301 549 (published by ETSI/CEN/CENELEC) is the European harmonized standard for ICT accessibility generally, which includes web content. EN 301 549 references WCAG for web-specific criteria (currently WCAG 2.1 AA) and adds additional requirements for hardware, software applications, documentation, and support services that WCAG doesn’t cover. Most EU accessibility laws reference EN 301 549, which in turn references WCAG.

Which country has the strictest web accessibility law?

No single answer — “strictest” varies by dimension. Israel was one of the earliest to require broad private-sector website accessibility (2017). Norway applied accessibility requirements to private-sector websites in 2013, before most other countries. The EU’s EAA (2025) affects the largest economic zone. Germany’s BFSG has relatively high fines (up to €100,000 per violation). For US businesses, California’s combination of ADA Title III + Unruh Act statutory damages creates the highest litigation exposure.

Is WCAG 2.2 AA the right target for international compliance?

Generally yes — WCAG 2.2 is fully backward-compatible with 2.1, so conforming to 2.2 automatically satisfies 2.1. Most current laws reference 2.1 AA (DOJ Title II Rule, EAA, EN 301 549 v3.2.1); future revisions will reference 2.2 AA as it becomes more established. Targeting 2.2 AA now positions you ahead of the regulatory curve.

What about WCAG 3.0?

WCAG 3.0 is in active development by the W3C and is expected to eventually replace WCAG 2.x as the primary standard. However, WCAG 3.0 will be a substantial structural change (new scoring model, different conformance approach), and it is not expected to be the referenced standard in any major legal regime before 2028–2030. For 2026 compliance decisions, WCAG 2.1 or 2.2 AA remains the correct target.

Bottom line

International web accessibility law has matured significantly since the late 2010s. The EU Accessibility Act’s June 28, 2025 enforcement, the US DOJ’s April 2024 Title II Rule, Canada’s Accessible Canada Act, Germany’s BFSG, and dozens of national implementations of EU directives have created a dense global web of legal requirements. The practical compliance target for most organizations is WCAG 2.2 Level AA, grounded in EN 301 549 where European requirements apply. Policies should be written specifically to the standards and deadlines that apply to your jurisdictions and customer base — and given the pace of change, reviewed annually as the landscape continues to evolve.