Web Accessibility Compliance Standards

Why every one of these laws points back to WCAG

The list above looks like nine different problems. In practice it is closer to one problem with nine jurisdictions attached. The ADA in the United States, Section 508 for federal agencies, the European Accessibility Act, AODA in Ontario, BITV in Germany, RGAA in France, the DDA in Australia and the ACA in Canada all converge on the same technical standard: the Web Content Accessibility Guidelines, almost always at level AA.

What differs between them is scope and consequence, not the technical bar. They disagree about who is covered, from what date, with what enforcement, and whether a formal statement or audit has to be published. They largely agree about what an accessible page is. That is why one scan against WCAG 2.1 and 2.2 AA is a reasonable starting point regardless of which of these applies to you.

Working out which one applies to you

Follow your users and your money rather than your servers. If you sell to or serve the public in a jurisdiction, its accessibility law generally reaches you, whether or not you have an office there — this is the point most often missed by companies who assume a law stops at a border. Public-sector bodies and their suppliers are usually held to a stricter and earlier standard than private companies. Sector matters too: education, healthcare, banking and transport frequently carry additional obligations.

If you operate in several of these places, work to the strictest one that applies. In practice that almost always means WCAG 2.1 AA as a minimum, which is exactly what the scan measures. Pick the standard that covers you from the list above for the specific detail, and start from a scan so you know where you actually stand.

Compliance questions

Do I need a separate audit for each regulation?

Usually not. They reference the same technical standard, so one WCAG 2.1 AA audit covers the technical baseline for all of them. What can differ is the paperwork — some regimes expect a published accessibility statement or a formal conformance report.

Does this apply to a small business website?

Frequently yes. Most of these laws are written around serving the public rather than around company size, and small businesses have been the subject of accessibility complaints. Thresholds and exemptions vary by jurisdiction, which is what the individual standard pages cover.

We are outside the EU. Does the European Accessibility Act reach us?

It can. The EAA applies to products and services offered to consumers in the EU, so selling into the EU can bring you within scope regardless of where you are based.

Is WCAG 2.2 required, or is 2.1 enough?

Most regulations currently reference 2.1 AA, and 2.2 adds a small number of additional criteria on top of it rather than replacing it. Building to 2.2 is the safer choice because it satisfies 2.1 as well and puts you ahead of the references being updated.